Privacy Policy
Privacy Policy
This privacy policy was last updated on 12 August 2024.
Background
We take your privacy seriously and are committed to keeping secure any information we obtain from you or about you.
Please read this privacy policy (Policy) carefully as it contains important information about our practices with respect to your personal data which we may collect, store, use and share when you use our website, applications, and other services. This Policy also explains your rights in relation to your personal information and how to contact us or relevant supervisory authorities in the event you have a complaint.
In this Policy, when we refer to personal data we mean any information relating to an identified or identifiable individual. When we refer to sensitive personal data we mean any personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric, and data concerning health, sex life or sexual orientation.
This Policy applies to the processing of personal information collected by us when you:
- visit our website;
- use our mobile application(s);
- 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;
- register for, attend or take part in our events or webinars; or
- use any of our other products or services which may from time to time involve the processing of your personal information,
each of the above collectively defined in this Policy as Services.
This Policy also applies to the processing of any personal information collected by us from publicly available sources. This Policy does not however apply to personal data which we process on behalf of our business customers (such as users of Vantage). Our use of that data is governed by the relevant customer agreement covering access to and use of those offerings.
When we collect, store, use and share personal information about you do so, we are subject to relevant data protection laws and regulations relating to the processing, privacy and use of that information including (without limitation) the UK General Data Protection Regulation, the EU General Data Protection Regulation and the California Consumer Privacy Act (herein defined as the Data Protection Laws). The Data Protection Laws which apply to you will depend on (amongst other things) where you are based and where you access or use our Services.
Who we are
We, Adarga Limited of Embassy Tea House, 195-205 Union Street, London, United Kingdom, SE1 0LN (collectively referred to as Adarga, we, us or our in this Policy) are the controller of your personal information for the purposes of relevant Data Protection Laws. We are responsible for your personal data.
If you have any questions about this Policy, please get in touch with our Data Protection Officer using the details provided below.
Contact details
- Full name of legal entity: Adarga Limited
- Email address: dpo@adarga.ai
- Postal address: Embassy Tea House, 195-205 Union Street, London, United Kingdom, SE1 0LN
- Telephone: +44 (0)800 8611 087
Changes to the Policy and your duty to inform us of changes
We regularly review this Policy and it may therefore change from time to time. If we do update this Policy, the changes will be posted on this page and, where appropriate, may be notified to you when you use our Services. For example, when using our mobile application(s), any new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the application.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our Services may from time to time contain links to and from the websites of partner networks, advertisers, third parties and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
Personal information we collect about you and how we collect it
We may collect, use, store and transfer different kinds of personal information about you as follows:
- Identity and/or Contact Data: first name, last name, username or similar identifier, title, company information, email address and telephone number. This data may be collected and processed by us if, for example, you create an account on one of our mobile application(s), you request additional information about our Services, you use the “Contact Us” button on our website or you sign up for an event or webinar.
- Device Data: type of device you use, a unique device identifier, your device operating system, the type of browser you use. We may collect this data when you browse our website or use our mobile application(s).
- Profile Data: your username and password. For example, the username and password you use to login to our mobile application(s).
- Usage Data: details of your use of any of our Services or your visits to any of our websites, such as the content you view or engage with, the features you use and the actions you take, your time zone, country, time and date of access, user agent and version, type of computer or mobile device, and computer connection.
- Marketing and Communications Data: your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Social Media Data: personal information that you choose to provide to us when you interact with our social media accounts which we may operate from time to time such as Instagram, LinkedIn, X and Facebook.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under Data Protection Law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing our website or mobile application(s). However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any special categories of personal information about you unless we have requested such information and you have provided your express consent in accordance with applicable Data Protection Laws.
How and why we use your personal information
We will only use your personal data when applicable Data Protection Laws allow us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing i.e. you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us using the details provided in this Policy.
- Where we need to perform a contract we are about to enter or have entered with you. Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We may carry out an assessment when relying on legitimate interests, to balance our interests against your own. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal or regulatory obligation that we are subject to.
We will obtain your consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
The table below explains what we use your personal information for and our reasons for doing so:
|
Purpose or activity |
Type of data |
Lawful basis for processing |
|
To provide our products and/or Services |
· Identity · Contact · Device · Profile |
· Your consent · Performance of our contract with you |
|
To install our mobile application(s) on your device and register you as a user of an application |
· Identity · Contact · Device · Profile |
· Your consent · Performance of our contract with you |
|
To operate and administer our website and to provide you with website content |
· Identity · Contact · Device · Profile |
· Your consent · Legitimate interest
|
|
To manage our relationship with you including notifying you of changes to our Services |
· Identity · Contact · Profile · Marketing and Communications |
· Your consent · Performance of a contract with you · Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) · Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
|
To manage payments by you |
· Identity · Contact |
· Your consent · Performance of our contract with you |
|
To administer and protect our business and our Services via troubleshooting, data analysis and system testing |
· Identity · Contact · Device |
· Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
|
Promoting the security of our Services (including our website and mobile application(s)) |
· Identity · Contact · Device |
· 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 Us” and user support requests |
· Identity · Contact |
· Consent · Performance of our contract with you · Legitimate interest |
|
To send you marketing communications, to contact you to undertake customer satisfaction surveys, to invite you to provide product reviews or for market research |
· Identity · Contact · Marketing and Communications |
· Your consent. · With regard to direct marketing via a business user, we may also rely on legitimate interest to improve our products and services and/or to grow our business |
|
To host events or webinars |
· Identity · Contact · Marketing and Communications |
· Consent · Legitimate interest to grow and develop our business |
|
To register office visitors |
· Identity |
· Legitimate interest to protect our offices and our confidential information against unauthorised access |
|
External audits and quality checks |
· Identity · Contact · Device · Profile · Usage · Marketing and Communications |
· To comply with our legal and regulatory obligations · Legitimate interest to maintain our accreditations so we can demonstrate we operate at the highest standards |
|
To deliver content and advertisements to you, and to make recommendations to you about goods or services which may interest you
|
· Identity · Contact · Device · Profile · Usage · Marketing and Communications |
· Consent · Necessary for our legitimate interests (to develop our products/Services and grow our business) |
|
To measure and analyse the effectiveness of the advertising we serve you and to monitor trends so we can improve the App |
· Identity · Contact · Device · Profile · Usage · Marketing and Communications |
· Consent · Necessary for our legitimate interests (to develop our products/Services and grow our business) |
|
Other processing necessary to comply with legal and regulatory obligations that apply to our business |
· Identity · Contact
|
· To comply with our legal and regulatory obligations |
Cookies
We may use cookies and/or other tracking technologies to distinguish you from other users of our Services and to remember your preferences. This helps us to provide you with a good experience when you use our Services or and also allows us to improve our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookies policy here.
Who we share your personal information with
When you provide us with your personal data, if required under applicable Data Protection Laws, we may also ask for your consent to share your personal data with certain third parties. 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, cloud services, website support and security, and performance, research and analytics;
- with our affiliates, meaning any corporate entity which controls or is controlled by or under common control of us;
- 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 our DPO using the details provided in this Policy.
We do not sell or share personal information for cross-contextual behavioural advertising (as those terms are defined under applicable Data Protection Laws). We also do not process sensitive personal information for the purposes of inferring characteristics about a consumer.
International transfers
If we ever transfer your personal data outside the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- We will use specific contracts approved by the UK which gives personal data the same protection it has in the UK.
Data security
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your personal information, we will use strict procedures and security features to prevent it from being accidentally lost, used or accessed in an unauthorised way. Those processing your personal 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
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, or for other legitimate business purposes such as resolving disputes or for safety, legal or security reasons. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us. How long we may retain your personal data will depend on a number of factors including (without limitation) the amount, nature and sensitivity of the data, potential risk of harm, our reason for processing such data.
In some circumstances you can ask us to delete your data.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, depending on location and applicable Data Protection Laws, you have one or more of the following rights in relation to your personal data.
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which may override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us using the details provided at the start of this Policy. In the case of withdrawing consent to receive marketing communications from us, you may also withdraw consent by clicking the unsubscribe button on the relevant marketing communication.
Please note the legal rights outlined above may be limited, for example if fulfilling any one or more of the request(s) would reveal personal data about another person, or if you ask us to delete information that we are required by law or have legitimate interest to retain.
For further information on each of those rights, including the circumstances in which they apply, please contact our DPO using the contact details provided in this Policy or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK General Data Protection Regulation .
If you would like to exercise any of those rights please email, call or write to our DPO. Our DPO will then confirm next steps or any other information we require before we are able to respond to your request such as proof of your identity and/or address.
How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your personal information.
The UK General Data Protection Regulation also gives you the right to lodge a complaint with the supervisory authority in the UK, the Information Commissioner, who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.
If you are based in the United States, you can refer to your local data protection authority.