External privacy notice

Summary – This Notice

This Notice explains how we collect and Process Personal Data. This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

This Notice is issued by Adapteo Group on behalf of its subsidiaries and its affiliates (“Adapteo”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our websites (the “Sites”), users of our services, personnel of corporate customers and vendors (together, “you”). The defined terms used in this Notice are explained in Section “Definitions” below.

Our Site may also contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own policies, which Adapteo has no control over. You should carefully evaluate the policies of these websites before submitting any personal data to them.

Who is responsible for the Processing

The Controller of your Personal Data is the Adapteo Group company with which you interact in the relevant context, for example the company you contact or that provides services to you.

To identify the relevant Controller for a specific interaction, please see the relevant contract, order documentation, email signature, or the local website/legal imprint (where available).

If you have questions about this Notice or wish to exercise your rights, please contact: privacy@adapteo.com

What Personal Data we collect

Depending on how you interact with us, we may Process:

  • Website and device data (if you visit our Sites): IP address, device identifiers, cookie identifiers, pages visited, approximate location, browser information, and consent and choice signals.

  • Identity and contact details: name, company, role and title, email, phone, address (typically when you contact us, request information, sign up, or enter into a business relationship).

  • Enquiry and relationship data: messages, meeting notes, Customer relationship management records, and order and service history.

  • Marketing preferences: newsletter preferences, consent status, opt-out status.

We do not intend to collect or otherwise Process special categories of Personal Data (for example, health data or information revealing religious beliefs or trade union membership). Please do not provide such information to us unless we specifically request it.

Where we Process special categories of Personal Data, we do so only to the extent necessary for the relevant purpose and subject to appropriate safeguards.

We collect Personal Data:

  • directly from you: for example, through forms, email, phone, meetings, events),

  • automatically through cookies and similar technologies when you use our Sites (please see our Cookie Policy for further information),

If you only visit our Sites, we typically Process only website and device data (and your cookie status, where applicable). The other categories above are generally collected only if you contact us or subscribe to our newsletter.

Why we use your data

In general, we Process your Personal Data to provide the services and products you request or have selected, to communicate with you and support our business relationship, to provide relevant information and solutions, to protect you and Adapteo against fraud, misuse and security incidents, to perform and administer our contracts, and to comply with applicable laws and regulatory requirements, including requirements relating to information security and data protection.

Below we set out examples of the purposes for which we Process Personal Data and the corresponding legal bases under the GDPR. The purposes and legal bases that apply to you will depend on how you interact with us:

Purpose

Legal basis

Responding to enquiries and managing our relationship, including handling requests, day-to-day contact, maintaining contact and relationship records.

Legitimate interests (Article 6(1)(f)): to manage communications and develop business relationships.

Contract and steps prior to entering into a contract (Article 6(1)(b)): where necessary to take steps at your request or to perform a contract.

Providing services and fulfilling contracts, including delivery, administration, support, invoicing, and contract management.

Contract (Article 6(1)(b)).

Legal obligation (Article 6(1)(c)): where processing is required by applicable law, for example accounting, tax, and statutory record keeping.

Sales, marketing and relationship management (newsletters, invitations, relevant updates, relationship communications).

Consent (Article 6(1)(a)): where required under applicable marketing rules (including ePrivacy rules where applicable).

Legitimate interests (Article 6(1)(f)): business-to-business marketing and relationship communications where permitted by law, and subject to your right to object at any time.

Operating, protecting and securing our websites and information technology systems, including security logs, access management, preventing fraud and abuse, and incident handling.

Legitimate interests (Article 6(1)(f)): to ensure network and information security, prevent misuse and fraud, maintain system availability, and protect our organisation and users.

Legal obligation (Article 6(1)(c)): where specific information security, documentation, or reporting obligations apply.

Analytics and improving our websites (measuring usage, improving content and user experience)

Consent (Article 6(1)(a)): where required for analytics cookies, pixels, or similar tracking technologies under applicable Privacy rules.

Compliance and legal claims (compliance controls, audits, investigations, responding to authority requests, establishing, exercising, or defending legal claims)

Legal obligation (Article 6(1)(c)): where processing is required to comply with applicable law or binding authority requests.

Legitimate interests (Article 6(1)(f)): to conduct compliance work, prevent misconduct, and protect our legal rights and interests.

Where relevant for legal claims, processing may also be necessary for the establishment, exercise, or defence of legal claims (Article 9(2)(f), if and to the extent special categories of personal data are processed).

When we rely on legitimate interests, our interests typically include: operating and improving our business, communicating with customers and prospective customers, ensuring network and information security, preventing fraud and misuse, and protecting our legal rights.

Where we rely on legitimate interests, you have the right to object to that Processing on grounds relating to your particular situation.

You also have the right to object at any time to the Processing of your Personal Data for direct marketing purposes. If you do so, we will stop Processing your Personal Data for such purposes.

Who we share Personal Data with

We may share your Personal Data with:

  • Adapteo Group companies where necessary for internal administration, service delivery, reporting, or support functions;

  • Service providers (acting as Processors) such as IT hosting, website providers, analytics providers, customer relationship management, marketing platforms, auditors and professional advisors, under contractual confidentiality and data protection obligations;

  • Authorities where required by law;
    Potential buyers and transaction counterparties in connection with mergers, acquisitions, or reorganisations (subject to appropriate safeguards).

We only share Personal Data to the extent necessary for the purposes described in this Notice.

International transfers

In some cases, we use IT suppliers, business partners, and professional advisers who may, where necessary to provide their services, access Personal Data from locations outside the EU/EEA, even if the Personal Data is normally stored within the EU/EEA.

Such transfers may take place either to countries that have been formally recognised by the European Commission as providing an adequate level of protection for Personal Data, or – if the destination country is not covered by such a decision – subject to appropriate safeguards, such as the EU Standard Contractual Clauses. As part of this, we enter into the required contractual arrangements with recipients (for example, data processing agreements where the recipient acts as our Processor, or appropriate controller-to-controller terms where the recipient acts as an independent Controller), and we restrict access and use to what is necessary for the relevant purpose. Where required, we also assess whether additional technical and organisational measures are needed to protect the data in practice.

How long we keep your data (retention)

We keep Personal Data only as long as necessary for the purposes described above or as required by law. Typical examples:

  • Website logs: kept for a limited period for security and diagnostics.

  • Enquiries or customer relationship management records: kept while the relationship is active and thereafter for a reasonable period or as required for documentation and limitation periods.

  • Marketing preferences: kept until you withdraw consent or opt out.

Your rights

Subject to applicable law, you may have rights to:

  • access your Personal Data,

  • rectify inaccurate data,

  • erase data (in certain cases),

  • restrict processing,

  • object to processing, including objecting to direct marketing

  • data portability (where applicable),

  • withdraw consent at any time (where processing is based on consent), and

  • lodge a complaint with your local data protection authority.

To exercise rights, contact privacy@adapteo.com . We may need to verify your identity before responding. We will respond within one month, which may be extended by up to two further months where necessary.

Mandatory vs optional data

Where we request Personal Data, providing it is generally optional, but if you choose not to provide certain data we may not be able to respond to your enquiry, provide services, or process an application.

Automated decision-making

We do not make decisions solely based on automated processing that produce legal or similarly significant effects. If this changes for a specific process, we will inform you.

Contact details

You are always welcome to contact us at privacy@adapteo.com if you have any questions about how we Process your Personal Data.

Definitions

“Personal Data”, “Process/Processing”, “Controller”, “Processor”, “EEA”, “UK”, “Sites”, and related terms have the meanings given in applicable data protection law (including GDPR).

References to “Article” or “Articles” in this Notice mean the relevant provisions of the General Data Protection Regulation.

Cookie Notice

This Notice is issued by Adapteo Group (“Adapteo”, “we”, “us” and “our”). 


This Notice applies to the website www.adapteo.com (the “Site”). 

What are cookies? 

Cookies are small text files that may be stored on your device when you visit a website. They are generally used to make websites work, to keep track of your movements within the website, to remember your login details, to remember your preferences and interests, and so on. 

There are different types of cookies, and they can be distinguished on the basis of their origin, function and lifespan. Important characteristics of cookies include the following: 

  • First-party cookies are cookies that are placed by the website you are visiting, while third-party cookies are placed by a website other than the one you are visiting. Please note that we do not control the collection or further use of data by third parties.  
  • Necessary cookies are necessary to allow the technical operation of a website (e.g., they enable you to move around on a website and to use its features).
  • Performance cookies collect data on the performance of a website such as the number of visitors, the time spent on the website and error messages.
  • Functionality cookies increase the usability of a website by remembering your choices (e.g. language, region, login, and so on). 
    Targeting/advertising cookies enable a website to send you personalized advertising. 
    Session cookies are temporary cookies that are erased once you close your browser while persistent or permanent cookies stay on your device until you manually delete them or until your browser deletes them based on the duration period specified in the persistent cookie file. 


More information on all aspects of cookies can be found at www.allaboutcookies.org. Please note that Adapteo has no affiliation with, and is not responsible for, this third-party website. 

Why do we use cookies? 

We may use cookies to: 

  • distinguish between visitors;  
  • improve the use and functionality of our Site;
  • enable/analyse the provision of third-party functionalities, such as social media plugins;
  • tailor our Site and services to your needs and preferences; and
  • analyse how our Site is used and compile anonymous and aggregate statistics. 

We do not use the collected information to create visitor profiles. 

Cookie Declaration

How can you control cookies and web beacons?  


Most internet browsers are set to automatically accept cookies. Depending on your browser, you can set your browser to warn you before accepting cookies, or you can set it to refuse them. Please refer to the ‘help’ button (or similar) on your browser to learn more about how you can do this. 

Disabling cookies may impact your experience on our Site. 

If you use different devices to access our Site, you will need to ensure that each browser of each device is set to your cookie preference. 

More information on how to manage cookies is available at: http://www.allaboutcookies.org/manage-cookies/. Please note that Adapteo has no affiliation with, and is not responsible for, this third-party website. 

In addition, you may opt-out from certain cookies by visiting the following third-party websites and selecting which company cookies you would like to opt out from: http://www.aboutads.info/choices/#completed and http://www.youronlinechoices.com/. Please note that Adapteo has no affiliation with, and is not responsible for, these third-party websites.