This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Adappt Ltd is “an Information technology service company”. We are registered in England and Wales as a limited company under number: 07684366 and our registered office is at 3 Ilex House, 94 Holly Road, Twickenham, TW1 4HF.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a data protection manager. Our data protection manager is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
We obtain personal data about you, for example, when:
The information we hold about you may include the following:
We may process your personal data for purposes necessary for the performance of our contract with you or your employer or our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes. We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
We may use your personal data in order to:
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you, alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
“Third parties” includes third-party service providers and other entities within our company or the members of our firm’s network. The following activities are carried out by third-party service providers: Bookkeeping and accountancy services, IT and cloud services, professional advisory services and administration services. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law. Occasionally your data may be handled by staff working outside of the EU, performing repair work to your data. In these circumstance, they securely access the data remotely on our server. This activity is necessary for the performance of a contract made in your interest.
We will not transfer the personal data we collect about you outside of the EEA.
Should you require further information about this protective measure[s], please contact us using the contact details outlined below.
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Under certain circumstances, by law you have the right to:
If you want to exercise any of the above rights, please email our data protection point of contact firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact email@example.com
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
A cookie is a small piece of information sent by a web server to a web browser, which lets us collect information from the browser.
Most browsers will allow you to turn off cookies. Unfortunately, turning off cookies may mean our website won't retain your personalised settings and may restrict use of the site.
|Cookie||What it does||How to disable and consequences|
|_gat#||Enables Google Analytics regulate the rate of requesting. It is a HTTP cookie type that lasts for a session.||Disable in browser settings. No user impact|
|_ga||It records a particular ID used to come up with data about website usage by the user. It is a HTTP cookie that expires after 2 years.||Disable in browser settings. No user impact|
|_gid||Keeps an entry of unique ID which is then used to come up with statistical data on website usage by visitors. It is a HTTP cookie type and expires after a browsing session.||Disable in browser settings. No user impact|
|_tlbcpv||Used to record unique visitor views of the consent banner.||No user impact|
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Notice.
Any changes we may make to our privacy notice in the future will be updated on our website at: http://www.adappt.co.uk
This privacy notice was last updated on 20 June 2020
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact our data protection team on on +44 (0) 203 289 0001 or firstname.lastname@example.org
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office:-
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns