This policy was last updated on 3rd April 2019
This website (the “Website”) is operated and owned by ADWConnect Ltd (“ADWConnect Ltd”, “ADWConnect”, “we”, “we”, “us” or “our”). ADWConnect is committed to protecting and respecting your privacy.
We have been making our best efforts in order to comply with Data Protection Law (“Data Protection Law”), including without limitation applicable US law, EU law, including without limitation the European General Data Protection Regulation (“General Data Protection Regulation”, “GDPR”), EU-US and Swiss-US Privacy Shield Frameworks as well other with other relevant data protection rules.
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.
This Website is not intended for children and we do not intentionally collect data relating to children.
This Website may include links to third-party websites, applications or plug-ins. 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.
ADWConnect Ltd is a legal entity registered under the law of England and Wales with its registered number: 06432381.
We act as Data Controller in respect of your personal data that we process. If you have any questions about how we collect, store or use your data, please contact us via e-mail: firstname.lastname@example.org
INFORMATION WE COLLECT ABOUT YOU
We collect certain information from you when you use or register on our Website, subscribe to a newsletter or any of our Services or enter information on our Website. The information we collect from you may include following personal data: name, email address, date of birth, telephone number, country of your residence, certain credit card/bank account details, computer’s internet protocol (IP) address. You hereby agree that we also may collect certain personal data from third party websites (including without limitation phonebook contacts from Google, Yahoo, Microsoft).
When processing your personal data we are governed by following principles:
- personal data is processed lawfully, fairly and in a transparent manner in relation to you;
- personal data is collected only for specified, explicit and legitimate purposes;
- personal data is always adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
When you pay us for our Services we may collect, process or use certain your payment data. Generally all data during the payment process is collected, processed or stored by Stripe which is independent payment service provider. During the payment process we collect and store 4 (four) last digits of your credit card/bank account number. We do it exclusively for security measures and in order to make your payment process more comfortable and easy for you.
PURPOSES OF PROCESSING OF PERSONAL DATA
We may process your personal data for a number of different purposes. We may use certain personal data we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the Website, or use certain other website features in the following ways:
- To improve our Website in order to better serve you.
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To allow us to better service you in responding to your customer service requests.
- To administer a contest, promotion, survey or other Website feature.
- To quickly process your transactions.
- To ask for ratings and reviews of Services or Products
For each purpose we must have a legal ground for such processing.
Generally such legal grounds are as follows:
- you have given us explicit consent to the processing of your personal data;
- processing is necessary for the performance of a contract to which you are the party or in cases you requested us to process your prior to entering into a contract;
- processing is necessary for compliance with our legal obligation to which we are the subject;
- processing is necessary in order to protect the your vital interests or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority laid upon us as controller;
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
What do we mean when we say “Legitimate Interest” and “Performance of contract”?
Legitimate Interest shall mean our interest as a business in conducting and managing. We hereby confirm that 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 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).
Performance of 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.
We use Service Providers to perform Services on our behalf or to assist us with the provision of Services to you. For example, we may engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalize and optimize our Service, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data about users’ interactions with our Website or Services, and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal data or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If you are resident of the EU please be informed that some of our third parties may be based outside the EU which means that the processing of your personal data will involve a transfer of data outside the EU.
Whenever we transfer your personal data out of the EU, we ensure that 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 by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the USA.
If there is neither adequacy decision nor appropriate safeguards implemented we still may transfer your personal data out of the EU due to following justifications:
- we have been informed you about the possible risks of transfers of your personal data and you has explicitly consented to the proposed transfer of your personal data out of the EU;
- the transfer is necessary for the performance of a contract concluded between you and us. or if you requested us to perform pre-contractual measures;
- the transfer is necessary for the conclusion or performance of a contract concluded between us and other natural or legal person for your benefit;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for the establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect your vital interests or interests of other persons in cases where you are physically or legally incapable of giving consent;
Please feel free to contact us in case if you want to get more information on the specific mechanism used by us when transferring your personal data outside the EU.
Certain third party businesses (companies and/or individuals) may have a right to provide or facilitate certain aspects of the services offered through this Website or our Services on our behalf. You hereby agree that we may provide these third-party service providers with access to your personal data in order to allow them to perform the Services for you and us. We require these third-party service providers to provide safeguards for your personal data in similar to the ones that we provide.
We shall be entitled to communicate information that describes the habits or usage patterns and/or demographics of the whole or a part of ADWConnect’s customer base (including you) but which is anonymous and does not describe or reveal the identity of any particular customer to any third party.
We shall be entitled to make your name, address and telephone number available to the emergency services.
Unless you notify us, we may use information provided by you for market research purposes or to supply you with information about other products or services available from ADWConnect or any of its holding companies or subsidiaries and any subsidiary of any such holding company.
We use Google Analytics, a service which transmits website traffic data to Google Inc. servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google Inc. We use reports provided by Google Analytics to help us to understand our Website traffic and its usage.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
AGE OF CONSENT
YOUR LEGAL RIGHTS
- The right to request access to your personal data. This means that you may request us to send you a copy of the personal data we hold about you and to check that we are lawfully processing it.
- The right to request correction of the personal data. This means that you may request any incomplete or inaccurate data we hold about you to be corrected.
- The right to 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, where we may have processed your information unlawfully or where we are required to erase your personal data in order to comply with any relevant applicable laws. Please note that sometimes we may be unable 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.
- The right to object to processing. You may object to processing of your personal data where you know or have grounds to assume that such processing impacts on your fundamental rights and freedoms. Also you have the right to object processing at any time where we are processing your personal data for direct marketing purposes. We may demonstrate that we are processing your data due to legitimate grounds which in certain circumstances override your rights and freedoms.
- The right to request restriction of processing of personal data. You may request us to suspend the processing when you want us to make the processed data accurate; or the processing of data is unlawful but you do not want us to erase it; or if 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.
- The right to request the transfer of your personal data to you or to a third parties. It means that upon your request we will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to data which are processed by automated means and only in cases where you provided us with the relevant explicit consent to such processing or processing is used in course of performance of contract.
- The right to withdraw consent at any time. You may withdraw your consent to processing of your personal data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
We will keep your personal data only as long as it is necessary in order to fulfill the purposes the personal data was collected for, including without limitation the purposes of compliance with any relevant reporting, accounting or legal requirements.
When determining how long your personal data will be kept with us, we consider following factors: nature, sensitivity of the personal data and its amount; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we collected your personal data and process it; applicable legal requirements.
Where we are processing your personal data for marketing purposes, we may contact you at least every month to ensure you are pleased to continue receiving our marketing communications. You may require us not to use your personal data for marketing purposes or object to such processing at any time by sending appropriate request or statement to our email address.
Sometimes we can send you email or push notifications. You always can subscribe or unsubscribe to all such notification except “account” notifications that we use in order to notify when certain account changes takes place.
In cases when you enable push notifications, we save cookies on your device (mobile telephone, tablet or pc).
In some circumstances we may anonymise and/or pseudonymize your personal data for statistical research purposes. In such cases your personal data will not be longer associated with you and we may use this it indefinitely without further notice to you.
REQUEST FOR INFORMATION
Sometimes we may need to request specific information from you in order to 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. We also may suggest you to link your account on this Website with your social network profile in order to enhance your experience of use this Website or our Services.
TIME LIMIT TO RESPOND
We will make our best efforts to respond to all your legitimate requests within 1 (one) month. Sometimes it may take us longer than a 1 (one) 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.
PERSONAL DATA BREACHES
We will report any unlawful data breach of this Website’s database or the database(s) of any of our third party data processors (if any) to any and all relevant persons and authorities within 72 (seventy two) hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
You have the right to lodge a complaint with a data protection authority, in particular in the state or country of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the applicable Data Protection Law.
However, we would appreciate the possibility to deal with your concerns before you send your complaint to supervisory authority so please contact us in the first instance.
QUESTIONS AND CONTACT INFORMATION