1. PURPOSE OF THIS NOTICE
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.
2. ABOUT US
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 an 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.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you or your employer or our clients engages us to provide our services and also during the provision of
those services; you contact us by email, telephone or post (for example when you have a query about our
services); or
- from third parties and/or publicly available resources (for example, from your employer or from
Companies House).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (such as your name and/or address);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our
services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research, surveys, and marketing activities;
Information we receive from other sources, such as publicly available information, information provided by
your employer or our clients or information from our member network firms.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
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.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you or your employer or our
clients and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which
will most usually be for the provision of our services) where you may be a subcontractor, supplier or
customer of our client;
- provide you with information related to our services and our events and activities that you request from
us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide;and
- notify you about any changes to our services
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.
Data retention
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:
- the requirements of our business and the services provided;
- any statutory or legal obligations; the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data;and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
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.
6. DATA SHARING
Why might you share my personal data with third parties?
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.
Which third-party service providers process my personal data?
“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.
What about other third parties?
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.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
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.
8. DATA SECURITY
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.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
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.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold
about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- 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 exercised your right to object to processing (see below).
- 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 basis. You also have the right to object where we are processing your personal
information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the
processing of personal data about you, for example if you want us to establish its accuracy or the reason
for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based
on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact
dpo@adappt.ai
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.
10. RIGHT TO WITHDRAW CONSENT
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
dpo@adappt.ai
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.
11. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at:
https://www.adappt.ai
This privacy notice was last updated on 23rd February 2025.
12. CONTACT US
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 +44 (0) 20 70 60 5304 or
dpo@adappt.ai
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
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