Effective date: Jan 2025
Last updated: Oct 2025

1. Data Controller

Elefant Commissions / Hern Creates Ltd
Company No. 14854475
Email: contact@elefantcommissions.com

2. Purpose of Processing

We process personal data to:

• Manage commissions, enquiries, payments and deliveries.

• Maintain customer and supplier relationships.

• Send marketing updates or newsletters (where consented).

• Comply with legal obligations including tax, accounting, and anti-fraud measures.

3. Categories of Data

• Contact details and identifiers.

• Commission/order data and transaction records.

• Technical and analytics data.

• Communication and correspondence data.

4. Legal Basis

As per the UK GDPR:

• Contractual necessity.

• Legitimate interests.

• Consent (marketing/cookies).

• Legal obligation.

5. Data Sharing & Transfers

We may share data with selected third-party providers (payment, shipping, hosting) under written agreements.
If data is transferred outside the UK, we ensure suitable safeguards such as Standard Contractual Clauses.

6. Data Retention

Data is kept only as long as necessary for the stated purposes or as legally required. Thereafter it is securely erased or anonymised.

7. Your Rights

You have rights to access, rectify, erase, restrict, object, or transfer your personal data, and to withdraw consent at any time.
To exercise these rights, contact contact@elefantcommissions.com.
If dissatisfied, you may complain to the ICO via https://ico.org.uk.

8. Automated Decision-Making

We do not engage in automated decision-making or profiling that has legal or significant effects.

9. Contact

Elefant Commissions / Hern Creates Ltd
The Workshop, 9 Wilton Road, Malvern, WR14 3RG, UK
Email: contact@elefantcommissions.com