Effective Date:

December, 2020


This is the Privacy Policy for Eleven Digital Ltd. (“Eleven Digital”) and its affiliates. It covers our handling of:


Personal data we handle for our own business (“Business Data”), other than for our own human resources activities. This includes certain data collected on our own website, such as newsletter signup forms, as well as data collected through other marketing-related efforts. Under applicable law, Eleven Digital is a “controller” of this data.


This Privacy Policy has details specific to Business Data, and information relevant to our handling of this data.

  1. Privacy Practices Specific to Business Data
    Types of Business Data

    We collect:


      • Contact details and professional details, e.g., name, email address, phone number, title, and name of company;

      • Information about customers’ experience with our Services;

      • Information about actual or prospective customer personnel’s other interactions with Eleven Digital;

      • Information about actual or prospective users’ interests; and

      • Payment information for Eleven Digital products and services.


We also collect Business Data through cookies and other automated data collection tools described in Section 2.
We obtain Business Data directly from the relevant individuals, and also from third-party sources, such as their employers, marketing or lead generation companies, data brokers, and social networking platforms (e.g., LinkedIn).


Uses and Disclosures of Business Data
Eleven Digital uses and discloses Business Data as follows:


      • To manage our customer relationships and deliver our services;

      • To send you information about our products and services, including marketing communications;

      • To respond to your questions, concerns, or customer service inquiries;

      • To analyze market conditions and use of our services;

      • To customize the content and advertising you see on our website, across the Internet, and elsewhere;

      • To enforce the legal terms that govern our business and online properties;

      • To comply with law and protect rights, safety and property (for example, making disclosures that we believe are required or otherwise appropriate for national security or law enforcement);

      • As part of an actual or potential business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization; and

      • For other purposes requested or permitted by our customers or users.


For those purposes, we may share information with our affiliates and other entities that help us with any of the above.

c. Legal Basis for Processing Business Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing Business Data are as follows:


      • Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

      • Customer service

      • Marketing

      • Protecting our customers, personnel and property

      • Analyzing and improving our business

      • Managing legal issues

      • We may also process personal data for the same legitimate interests of our customers and business partners.

      • Consent: Where required by law, and in some other cases, we handle personal data on the basis of consent.

      • To honor our contractual commitments to you: Some of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ request in anticipation of entering into a contract with them.

      • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.


We process Service Data pursuant to our contracts with our customers and applicable law.

  1. Additional Information About Our Privacy Practices

  1. Security and Data Retention

    We use different safeguards to help secure Business Data.
    We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

  2. Personal Data Rights and Choices (including Direct Marketing Opt-Out)

    You can unsubscribe from Eleven Digital’s own marketing emails by clicking the "unsubscribe" link they contain. Controls related to third-party cookies and other automated data collection are described in the section below.
    Residents of the European Economic Area, Switzerland and certain other and many other jurisdictions have certain legal rights (including, in certain cases, under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks) to obtain confirmation of whether we hold personal data about them as part of our Business Data, to access any such personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. In limited cases, they have the right to receive information we hold about them in portable form and to have it transmitted to a third party.
    They also have rights to object to our handling of their personal data, to restrict its processing, and to withdraw any consent they have provided.
    For example, individuals have a right to opt-out of our processing of Business Data for direct marketing purposes.
    Many of the rights described here are subject to significant limitations and exceptions under the Privacy Shield Frameworks and applicable law. For example, objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect.
    To exercise those rights for Business Data, they may contact us as described at the end of this Privacy Policy.


  3. Cookies and Automated Data Collection

    In our websites, apps, and emails, we and third parties may collect certain information by automated means such as cookies, Web beacons, JavaScript and mobile device functionality. This information may include unique browser identifiers, IP address, browser, and operating system information, geolocation, other device information, Internet connection information, as well as details about individuals’ interactions with our apps, websites, and emails (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in our websites).
    We and third parties may use automated means to read or write information on users’ devices, such as in various types of cookies.
    Cookies are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from a user’s device for the purposes described in this Privacy Policy, such as recognizing the device, service provision, record-keeping, analytics, and marketing, depending on the context of collection.
    You may be able to set your web browser to refuse certain types of cookies or to alert you when certain types of cookies are being sent. However, if you block or otherwise reject our cookies, JavaScript or other technologies, certain websites (including our own websites) may not function properly.
    These technologies help us (a) keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you; (b) remember your settings on the pages you visit, so that we can display your preferred content the next time you visit; (c) display personalize content; (d) perform analytics, and measure traffic and usage trends, and better understand the demographics of our users; (e) diagnose and fix technology problems; and (f) otherwise plan for and enhance our business.

    Also, in some cases, we arrange for the collection of information by advertising services administered by third parties. The ad services may track users’ online activities over time by collecting information through automated means such as cookies, and they may use this information to show users ads that are tailored to their individual interests or characteristics and/or based on prior visits to certain sites or apps, or other information we or they know, infer or have collected from the users. For example, we and these providers may use different types of cookies, other automated technology, and data (a) to recognize users and their devices; (b) to inform, optimize, and serve ads; and (c) to report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps).


  4. Notification of Changes

    Eleven Digital may change this Privacy Policy to reflect changes in the law, our data handling practices or the features of our business. The updated Privacy Policy will be posted on


  5. Contact Information

    If you have questions regarding our practices or this Privacy Policy, or to send us requests or complaints relating to personal data, please contact us:

    Eleven Digital Ltd
    2/F-3/F Dorset House Taikoo Place, 
    979 King's Rd, 
    Quarry Bay

To submit a Data Subject Rights Request in relation to our Business Data, please email and reference the request in the subject line. For requests relating to Service Data (personal data that we process on behalf of our customers), please contact that customer directly.

Privacy Policy

© 2020 by Eleven Digital Limited