Last updated May 15, 2025. 

This privacy Policy outlines how In Between by Elena (“we”, “us”, or “our”) collects, uses, and protects any personal data when you visit or interact with our website, “www.inbetweenbyelena.com”, or engage with our services. We are committed to safeguarding your personal data in accordance with the General Data Protection Regulation (EU GDPR), UK GDPR, and other applicable data protection laws. If you have any questions or concerns, please contact us at contact@inbetweenbyelena.com 

1. What information do we collect?  

Personal information that you voluntarily provide us when you express an interest in obtaining information about us, our products and services, when you participate in activities on the services, or otherwise when you contact us.

The personal information we collect may include the following: names, phone numbers, authentication data, billing addresses, project-related content or submissions. 

Sensitive information. We do not knowingly collect or process special categories of personal data, such as health or genetic information, unless it is necessary for a specific project and with your explicit consent. 

We do not collect personal information from third parties. 

2. How do we process your information?  

We process your information to provide, improve and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. This includes: 

• To deliver and facilitate services to the user. We may process your information to provide you with the requested service. 
• To respond to user inquiries or offer support to others. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. 
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. 
• To fulfil and manage your orders. 
• To enable user-to-user communications. 
• To save or protect an individual’s vital interest. 
• To comply with legal obligations. 
• To manage payments or process transactions. 
• To maintain a professional record. 
• To create contracts or agreements.

We do not sell, lease, or distribute your personal data to third parties unless legally required. 

We may use secure third-party services providers (such as email, invoicing, or website hosting platforms) to assist in processing your personal data, and we ensure that they comply with applicable data protection laws. 

3. What legal bases do we rely on?  

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases we rely on, in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: 

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our services or at your request prior to entering into a contract with you. 
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. 
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. 
• Legitimate interests. We may process your personal data when it is reasonably necessary for our legitimate business interests, provided that such interests do not override your rights and freedoms. 

4. Cookies 

This website may use cookies to analyse traffic and improve functionality. You may decline cookies through your browser settings, though this may affect your user experience. 

We use cookies and similar technologies to improve website functionality and analyse site traffic. Non-essential cookies (such as analytics or marketing) are only used with your consent. You can manage your cookie preferences through your browser or via our Cookie Consent Tool. 

5. How long do we keep your information?  

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). 

Your personal data will be retained for no longer than one year after the completion of the services, unless otherwise required by law. 

Certain records, such as invoices or tax-related documents, may be retained for up to seven years as required by law. When data is stored in backups, we will securely store your personal information and isolate it from any further processing until it can be safely deleted. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

6. How do we keep your information safe?  

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. We use SSL encryption, secure hosting, and password protection to ensure your data remains safe. We also ensure that any service providers we work with are compliant with relevant data protection standards. However,  despite our safeguards and efforts to secure your information, no electronic transmission over the internet is 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment. 

7. Do we collect information from minors? 

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@inbetweenbyelena.com

8. Privacy Rights  

Under the GDPR, you have the right to:

• Access the personal data we hold about you. 
• Request correction or deletion of your data. 
• Withdraw consent where applicable. 
• Lodge a complaint with a data protection authority. 

To exercise your rights, please contact: contact@inbetweenbyeelna.com

9. Changes to this policy 

We might update this Privacy Policy occasionally. Please review this page from time to time to stay informed. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification. This policy was last updated on 15 May 2025.

10. Contact  

For any questions or data-related requests, please contact In Between by Elena  at contact@inbetweenbyelena.com