Protecting your privacy means a lot to us. We respect your identity and privacy and ensure that your Personal Data is processed in accordance with applicable laws, including European data protection law.
The term “Personal Data” means any information which can be used to directly or indirectly identify you. This might include your name, company name, phone number, e-mail address, company address and/or any device ID (such as your IP address), which would identify you (either by itself or when linked with other Personal Data).
Who is responsible for the processing of your Personal Data?
Adeya SA operates the Site and is the data controller in respect of your Personal Data – this means that Adeya SA decides what Personal Data will be collected about you and how it will be used.
Saint Louis 2
or by e-mail: email@example.com.
What Personal Data do we collect from you?
When you download reports/white papers, we collect the following Personal Data: Name and surname, company name (if any), phone number and e-mail address, as well as the source of your request (e.g. our website, partners’ websites, etc.).
We may also collect some Personal Data when you contact us to request information or ask questions.
What Personal Data do we generate or receive from third parties?
We may generate or collect information about you ourselves – much of this is set out in our Cookies Notice. Sometimes, we also receive information about you from third parties. For example, we may receive information from your employer to enable you to use our goods and services – this information might include your [name, company, address, phone number, email address]. Additionally, if you participate in activities on non-Adeya sites or apps – such as participating in a Facebook application – you may allow us to have access to Personal Data held by Facebook, or other site or app owners.
How do we use your Personal Data and what is the legal basis for this use?
We process your Personal Data for the following purposes:
|Purpose||Legal grounds for use (EU)|
|To send you information and offers about our products and services.||Individuals’ consent where required or legitimate interests (i.e. keep you informed of Adeya activities and products / services).|
|To communicate with you about participating in market research surveys. The results of the survey are used to assist us with customizing, analyzing and improving our products and services.||Individuals’ consent where required and legitimate interest grounds (i.e. making improvements to our products and services by obtaining feedback from you in relation to those products and/or services that you have utilized).|
|To perform our contractual obligations with you or your employer (including but not limited to verifying your identity, administration of customer relationships, assisting with technical issues and facilitating payment transactions).||Contractual necessity, legal requirements, legitimate interest grounds (i.e. assessing your eligibility for a project).|
|To provide products and services you have requested, and respond to any comments or complaints you may send us.||Contractual necessity and legitimate interest grounds (i.e. ensuring that products and services can be provided).|
|To compile statistics and analysis about the use of our Site and related services, which statistics are used to enable us to provide a better service, features and functionality to you and other Site users – see our Cookies Notice for further information.||Individuals’ consent and legitimate interest grounds (i.e. ensure that our services function smoothly and we understand your interests).|
|To help prevent fraud and other prohibited or illegal activities.||Legal requirements.|
|In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).||Legal requirements and legitimate interest (i.e. to ensure that Adeya can participate and defend itself in legal proceedings).|
|To provide you with reports/white papers you request/download.||Contractual necessity and legitimate interest.|
Withdrawing consent or otherwise objecting to direct marketing.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message (every email has an unsubscribe link) or by opting out by e-mail to firstname.lastname@example.org.
What cookies and/or tracking technologies do we use?
When you visit our Site, we may collect, process and use Personal Data about you and your use of the website, including any forums you visit and how you arrived at our Site. Such information may be collected through “traffic data” and may entail the use of “cookies” or other tracking technologies, IP Addresses or other numeric codes used to identify your computer. For more information on Cookies please click on the link to our Cookies Notice.
Who will we share this data with, where and when?
We will share your Personal Data with relevant third parties for the purposes set out above.
Personal Data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal Data will also be shared with third party service providers, who will process it on behalf of Adeya for the purposes identified above. Such third parties include providers of website hosting, maintenance, identity checking and are registered in Switzerland.
Adeya is based in Switzerland and so any Personal Data that you provide to us will be processed in Switzerland. Whilst Switzerland is not in the EEA, Switzerland has been officially recognized by the European Commission as providing an adequate level of protection for data transfers from the EEA.
How long will your Personal Data be retained for?
Your Personal Data will be deleted once it is no longer required for the purpose for which it was collected (e.g. as part of a contractual relationship). In particular:
- Where we process Personal Data in the provision of our products or services, we do this for as long as you are an active user of our products or services and for 6 years after this.
- Where we process Personal Data for marketing purposes or with your consent, we process the Personal Data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Personal Data indefinitely so that we can respect your request in future.
- Where we process Personal Data in connection with performing a contract or for a competition, we keep the Personal Data for 6 years from your last interaction with us.
- Where we process Personal Data to monitor and compile statistics about the use of our Site, we keep the Personal Data in accordance with our Cookies Notice.
- Where we process Personal Data to meet legal requirements, we hold this for as long as the law requires.
What rights do you have in relation to your Personal Data?
You have the following rights in relation to your Personal Data:
- You can ask for a copy of your Personal Data we have stored
- You can ask for your Personal Data to be corrected, deleted or for any active processing of your Personal Data to be restricted
- You can obtain the Personal Data you provide to us for a contract or with your consent in a structured, machine readable format
- You can object to the processing of your Personal Data in some circumstances, for example, where we are using your Personal Data for marketing purposes
Additionally, if you have set up a user account, you can delete this or ask us for it to be deleted.
These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise these rights, you can get in touch with us using the details set out in the section above.
If you have unresolved concerns, you have the right to complain to a competent authority. In the EU this may be a data protection authority where you live, work or where you believe a breach may have occurred.
Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with Adeya. All other provision of your information is optional.
Last updated: November 2018