PRIVACY POLICY
INTRODUCTION
Welcome to ADC's Privacy Policy.
ADC respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Our Privacy Policy complies with the General Data Protection Regulation (EU) 2016/679) GDPR and Organic Law 3/2018 (Spain), of 5 December, on the Protection of Personal Data and guarantee of digital rights.
This Privacy Policy is dated October 21, 2020.
Content:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
ADC wants to ensure you understand what information we have about you, how we will use it and for what purpose. This Privacy Policy aims to give you information on how ADC collects and processes your personal data through your use of this website, including but not limited any data you may provide through this website when you subscribe to the latest news and updates, sign up to our newsletter, would like to join our Collaborator and Broker program or request more information about our current opportunity by filling in the form.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
CONTROLLER
ADC is the controller (collectively referred to as ADC, "we", "us" or "our" in this privacy policy) and responsible for deciding how we hold and use certain personal information about you.
We have not appointed a Data Protection Officer. If you have any question about anything in this policy, please do not hesitate to contact Data Protection Team using the details set out below.
CONTACT DETAILS
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Team in the following ways:
Full name of legal entity: Associated Developers Consortium S.L.
Email address: enquiries@adcequity.com
Postal address: C.C. Camoján Corner, Local 7, Marbella, Málaga, Spain, 29602.
You have the right to make a complaint at any time to the Spanish Data Protection Agency, which oversees data protection compliance in the Spain. Details of how to do this can be found at http://www.agpd.es/.
We would, however, appreciate the chance to deal with your concerns before you approach the Spanish Data Protection Agency, so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We may update this Privacy Policy in line with changes to how we process personal data. We will publish any new version of the Privacy Policy on our website.
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 your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
DATA PROTECTION PRINCIPLES
We will ensure that the personal information we hold about you is:
used lawfully, fairly and in a transparent way;
collected only for specified and legitimate purpose that we have clearly explained to you and not used in a way that is incompatible with those purposes;
adequate, relevant and limited to what is necessary in relation to the purpose we have told you about;
accurate and kept up to date;
not kept in a form which permits your identification for longer than necessary and kept only as long as necessary for the purpose we have told you about;
kept securely;
not transferred to another country without appropriate safeguards being in place.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Whilst, LLP’s, Trust structures or other vehicles, please note that we would ultimately be obtaining personal information about the individuals behind the relevant vehicle.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, nationality, gender, tax status and information, passport / national identity card details and country of domicile, your employment and employment history, job title and role, educational profile, interests and other information relevant to our provision of professional services].
Contact Data includes [billing address, delivery address, home / business address, email address and telephone numbers].
Financial Data includes [income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details, payment card accounts and other information necessary for processing payments and for fraud prevention purposes].
Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
Usage Data includes [information about how you use our website, products and services].
Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We 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 in 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 a specific website feature. 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 privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through (most of the information we collect is obtained from you):
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· apply for our services;
· place and order,
· email our general enquires address,
· directly interact with us personally,
· subscribe to our latest news and updates;
· request marketing to be sent to you;
· request more information about our current opportunities by filling in the form,
· would like to join our Collaborator and Broker program; or
· give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from public registries and various third parties (including your organization, agents, advisers, intermediaries or custodians of your assets and our clients or those involved in the matter which we rare engaged.)
We may also collect personal information about you from persons or entities authorized by you to provide us with information.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING
We use mailing lists to manage how we contact you. This enables us to record and manage how we contact you, and to manage your preferences and bookings for our events.
This data helps us to ensure our mailing list remains up to date; it also provides us with some basic information about our interests and to personalize our communications with you.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
COOKIES
As you interact with our website, we may automatically collect personal information about you.
We collect this personal data by using cookies and other similar technologies. Cookies are used to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We use Google AdWords Remarketing to advertise trigger across the Internet. AdWords remarketing will display relevant ads tailored to you based on what parts of the TriggerApp website you have viewed by placing a cookie on your machine. This cookie does not in any way identify you or give access to your computer The cookie is used to say “This person visited this page, so show them ads relating to that page.” Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Such third parties include your organization, our own client in a particular matter, third-party service provider or third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. INTERNATIONAL TRANSFERS
We may transfer our personal information outside the EEA. If we do, you can expect a similar degree of protection in respect of your personal information.
7. DATA SECURITY
We take the security of your personal information very seriously and we have put in place internal controls and security measures to protect it.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Personal data will only be transferred to a data processor if he agrees to comply with those measures, or if he puts in place adequate measures himself. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WE WILL USE YOUR PERSONAL DATA
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. The longest period of retaining your data is 6 years from the date the matter has concluded.
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.
9. YOUR LEGAL RIGHTS
You have certain rights in relation to your personal data as summarized here:
Right to be informed and provided with clear, transparent and easily understandable information about how we use your personal data and your rights; this is why we are providing you with the information in this privacy notice.
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 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.
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.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.