We collect, use and are responsible for certain personal information about you. When we do so we are subject to laws relating to the processing, privacy and use of that personal information, including the UK General Data Protection Regulation, and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
- visit our website;
- visit our branded social media pages;
- visit our offices;
- receive communications from us such as emails or phone calls;
- use our cloud products and services where we act as a controller of your personal information; or
- register for, attend or take part in our events or webinars.
It also applies to the processing of any personal information collected by us from publicly available sources.
Our website and services may contain links to other websites, applications and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy policies which you should review.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Adarga Limited, company number 09742902, registered office Embassy Tea House, 195-205 Union Street, London, SE1 0LN|
|Our Data Protection Officer||Please see below 'How to contact us'|
|Personal information||Any information relating to an identified or identifiable individual|
|Special category personal information||
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
It would be helpful to start by explaining some key terms used in this policy:
2.Personal information we collect about you and how we collect it
We may collect and use the following personal information about you:
- if you express an interest in obtaining additional information about our services, request customer support, use the “Contact” button on our website or similar features or sign up for an event or webinar, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
- if you purchase our products or services, we may require that you provide to us contact information and also financial information, such as billing name and address or bank account information;
- if you attend an event, we may ask you to provide to us personal information such as name, title, company name, address, phone number and email address;
- if you use and interact with our services, we may automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as personal information; and
- if you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival; and
- from time to time we may also collect personal information about you from publicly available sources such as open source data sets or media reports.
We do not collect special category personal information.
3. How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg: to comply with our legal and regulatory obligations; for the performance of our contract with you or to take steps at your request before entering into a contract; for our legitimate interests or those of a third party; or where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal information for and our reasons for doing so:
|What we use your personal information for:||Our reasons for using your personal information:||If legitimate interest is listed as one of the reasons, details of such legitimate interest:|
|Providing products and/or services||Performance of our contract with you|
|Providing our website||Legitimate interest||To operate and administer our website and to provide you with website content|
|Managing payments||Performance of our contract with you|
|Promoting the security of our services and website||Legitimate interest||To promote the safety and security of our services, systems and applications and to protect our rights and the rights of others|
|Handling contact and user support requests||Performance of our contract with you and/or legitimate interest||Fulfilling your requests and communicating with you|
|Developing and improving our website and services||Legitimate interest||To grow our business|
|To send you marketing communications, to contact you to undertake customer satisfaction surveys, to invite you to provide product reviews or for market research||Legitimate interest||To improve our products and services and/or to grow our business|
|To host events or webinars||Legitimate interest||To grow our business|
|To register office visitors||Legitimate interest||To protect our offices and our confidential information against unauthorised access|
|External audits and quality checks||To comply with our legal and regulatory obligations
|To maintain our accreditations so we can demonstrate we operate at the highest standards|
|Other processing necessary to comply with legal and regulatory obligations that apply to our business||To comply with our legal and regulatory obligations|
We may use your personal information to send you marketing communications about our products and/or services. We have a legitimate interest in processing your personal information for marketing purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you marketing communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes. You have the right to opt out of receiving marketing communications at any time by contacting us at firstname.lastname@example.org or by using the “unsubscribe” link in emails.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
5. Who we share your personal information with
We may share your personal information with the following third parties:
- with our contracted service providers, who may provide services such as system administration and hosting, website security and performance, research and analytics;
- if you sign up to one of our services which includes the provision of data from one of our third party partners, with such third party partners;
- with professional advisers such as lawyers, bankers and insurers;
- with auditors, for example in relation to ISO accreditation;
- with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations; or
- with other parties, such as potential buyers of some or all of our business or during a re-structuring.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
6. Where your personal information is held and transferring your personal information outside of the UK and EEA
Information may be held at our offices and those of the third parties detailed above (see above ‘Who we share your personal information with’).
We do not currently transfer personal information to any third parties outside of the UK or the EEA. If in the future we need to transfer personal information outside of the UK or the EEA we will ensure the transfer complies with data protection law and all personal information will be secure. For example, we may ensure that the country to which the personal information is transferred has been assessed by the European Commission as providing an adequate level of protection for personal information or we may use standard data protection contract clauses that have been approved by the European Commission.
7. How long your personal information will be kept
We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it. If there is any personal information that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
8. Your rights
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information - in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information - in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations|
|To object||The right to object:
-at any time to your personal information being processed for direct marketing (including profiling)
-in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
|The right to withdraw consents||
If you have provided us with a consent to use your personal information you have a right to withdraw that consent easily at any timeWithdrawing a consent will not affect the lawfulness of our use of your personal information in reliance on that consent before it was withdrawn
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation .
If you would like to exercise any of those rights, please:
- email, call or write to our Data Protection Officer - see below 'How to contact us';
- let us have enough information to identify you (eg your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
9. Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.
We may change this privacy notice from time to time. If we do so we will inform you via our website and/or by email.
12. How to contact us
Name: The Data Protection Officer
Address: Adarga Limited, Embassy Tea House, 195 - 205 Union Street, London, SE1 0LN
Email address: email@example.com
Telephone number: +44 (0)800 8611 087