Privacy Policy

PRIVACY POLICY ADEKI LTD 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, including when you use our services or visit our website (regardless of where you visit our website from). It will tell you about your privacy rights and how the law protects you. This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: [link]. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

In this Privacy Policy a reference to "you" is a reference to our customers and any person who provides personal data in relation to the services we supply to our customers (such as an employee or director of a customer) and to any visitor to our website.

  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
  10. GLOSSARY  

Important information and who we are Purpose of this Privacy Policy This Privacy Policy aims to give you information on how ADEKI LTD collects and processes any personal data you provide to us, including through your use of our website.

Our website is not intended for children and we do not knowingly collect data relating to children on our website or our other services.

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 ADEKI LIMITED is the controller and is responsible for your personal data (referred to as "ADEKI", "we", "us" or "our" in this Privacy Policy). If you are not a customer of ours but have consented to provide personal data in relation to the services we supply to one of our customers, ADEKI and our customer may be joint controllers in respect of personal data which we provide to them and / or which they provide to us (for example, if such customer is your employer). We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details If you have any questions about this Privacy Policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Adeki Ltd

Name of DPO: Adrian Webb

Email address: info@adeki.me

Postal address: 57 Deerings Road, Reigate, Surrey, RH2 0PW, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes We keep our Privacy Policy under regular review. This version was last updated on 21st August 2019.

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 Our 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 certain 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.

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). 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 and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• 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.

AS PART OF THE PROVISION OF OUR SERVICES WE MAY ALSO COLLECT SPECIAL CATEGORIES OF PERSONAL DATA FROM YOU. THIS MAY INCLUDE HEALTH DATA (PARTICULARLY HEART RATE AND HEART RATE VARIABILITY INFORMATION) AND BIOMETRIC DATA.

IN ORDER TO DO THIS WE WILL ASK (OR OTHERWISE OBTAIN) EXPLICIT CONSENT FROM YOU.

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.

If you fail to provide personal data Where we need to collect your personal data by law, or under the terms of a contract we have, or are trying to enter into, with you (or in relation to a customer in respect of whom you have agreed to provide personal data), and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a service in relation to such contract or be unable to enter into such contract. We will provide notice to our customer (or prospective customer) if this is the case. How is your personal data collected? We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, meeting with us or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• complete an online registration form;

• apply for our services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

• Technical Data from parties such as analytics providers, advertising networks and search information providers.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• Identity and Contact Data from data brokers or aggregators or from publicly available sources.

If you are providing personal data on behalf of one of our customers, we may also collect data from our customer (e.g. your employer). 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 you give us consent to do so.

• Where we need to perform the contract we are about to enter into or have entered into with: (i) you; or (ii) a customer in relation to whom you have agreed to provide your personal data.

• 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.

Scroll down to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, other than in relation to explicit consent for special categories of personal data (such as health or biometric information), we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.

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 or the provider of personal data in relation to a new customer
Identity and Contact
Performance of a contract with our customer To process and deliver our services including: (i) managing payments, fees and charges; and (ii) collecting and recover money owed to us Identity, Contact, Financial, Transaction and Marketing and Communications Performance of a contract with our customer AND necessary for our legitimate interests (to recover debts due to us) To provide our services to our customer Identity, Contact, Profile, health data and biometric data Performance of a contract with our customer and explicit consent

To manage our relationship with you which will include: (i) notifying you about changes to our terms or Privacy Policy; and asking you to leave a review or take a survey Identity; Contact; Profile and Marketing and Communications Performance of a contract with our customer AND necessary to comply with a legal obligation AND necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity, Contact, Technical 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) AND 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 Identity, Contact, Profile, Usage, Marketing and Communications and Technical Necessary for our legitimate interests (to study how you and/or our 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 Technical and 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 or our customer about goods or services that may be of interest to you Identity, Contact, Technical, Usage, Profile and Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

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. For more information about the cookies we use, please see our Cookie Policy.

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.

Disclosures of your personal data We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Firstbeat Technologies Oy, a company registered in Finland, as a data processor for the purposes of providing our services.

• 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. 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.

International transfers We may transfer your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

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 Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

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. 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.

Data retention How long will you use my personal data for?

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.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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.

Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data

• Request correction of your personal data

• Request erasure of your personal data

• Object to processing of your personal data

• Request restriction of processing your personal data

• Request transfer of your personal data

• Right to withdraw 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.

Glossary

LAWFUL BASIS

Consent means, in relation to any special category of personal data you have given us clear consent for us to process your personal data for a specific purpose.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties means other companies in the ADEKI group acting as joint controllers or processors.

External Third Parties means service providers acting as processors, professional advisers including lawyers, bankers, auditors and insurers and HM Revenue & Customs, regulators and other authorities.

YOUR LEGAL RIGHTS You have the right to:

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.

This data protection statement applies to Adeki's customer and marketing activity. It describes how Adeki Ltd processes the personal data of current and potential customers as well as other users of its services within the customer relations and marketing activities of the Adeki.

Adeki Ltd commits to comply with the existing UK data protection and personal data legislation, including EU General Data Protection Regulation (GDPR) and other applicable acts and laws regarding personal data processing. Adeki Ltd is also committed to process personal data in line with best practises on data management and data processing. The personnel of Adeki Ltd are committed to handle all and any personal data with strictest confidence.

Who is the Controller?

Adeki Ltd headquarters at 57 Deerings Road, Reigate, Surrey, RH2 0PW, United Kingdom(“Adeki”)

Who is the contact person in data protection matters?

Our controller can be contacted by e-mail at info@adeki.me. The contact person for all data protection related matters is the data protection officer Adrian Webb.

Name of the data file

The customer and marketing file of Adeki Ltd.

Content of the data file

Adeki Ltd’s customer and marketing activity aims at providing the best possible service as well as offering interesting content for each data subject. The following data may be stored and protected in this data file. Not all the below-mentioned data are necessarily stored for all the data subjects.

E-mail address, name, phone number, organisation, position

Data about updates and modifications of above-mentioned information Data collected using cookies related to the data subject’s visits and actions in Adeki Ltd web site In addition to what has been said above the register may contain notes and other data regarding the data subject needed for good customer relationship management. This may include e.g. data on the data subject’s newsletter subscriptions, past or forthcoming event participations, contact requests or data on services ordered by the data subject, deliveries and invoicing of them. Furthermore, the data file may contain data derived from the use of services such as segmentation to a given user group on the basis of the use of services or interests of the user.

The purpose and the legal basis for processing the personal data

The personal data are used in Adeki Ltd for

  • Targeting customer communication and marketing activity
  • Producing, offering, personalising and developing of services
  • Informing and marketing services and events
  • Managing, maintaining and enhancing current and potential customer relationship
  • Planning and developing business activities within Adeki Ltd
  • Market research and other statistical purposes
  • Personal data is processed based on a consent given by the data subject, the legitimate interests of the controller or to prepare or execute an agreement where the data subject is a party.

The storing of personal data has partly been outsourced to external service providers. The controller guarantees that this kind of outsourcing takes place in accordance with existing UK data protection and personal data legislation and that the external service providers will not use the data in this personal data file for their own purposes.

Data sources The data included in this data file are collected

  • Directly from the data subject,
  • or from public sources.

Data storage period The data are stored in the data file only as long as and to the extent necessary and allowed according to legislation in relation with the original or compatible purposes of collecting the personal data. The personal data will mainly be stored no longer than three years from the last active transaction between the data subject and the controller. The data will be erased when the storage time defined above expires. The personal data may be used after the termination of the customer relationship if the legislation in effect so require.

Additionally, the controller will carry out all reasonable activities to ensure that all personal data which are inaccurate, erroneous or outdated with regard to the original purposes of processing will be rectified or erased without delay.

Principles of data file protection Adeki Ltd sets very high importance on the confidentiality of its customers and the users of its services. Adeki Ltd carries out appropriate technical and organisational actions to protect personal data from accidental or illegal loss, disclosure, misuse, modification, deletion or unauthorised access.

Instructions related to the use of this data file are introduced within the organisation and the access rights have been restricted so that only the authorised personnel, who need the data in their work, have access to the data stored in the data file.

Adeki Ltd ensures that all its data systems and computer equipment are sufficiently protected with appropriate technical methods, including passwords and personal user IDs. Both the backups and deletion of the data files including personal data are carried out securely.

Transfer of personal data Personal data may not be transferred outside Adeki Ltd or its subcontractors, who store the data, in a manner enabling the data to be identified, except in the following exceptional circumstances: if required by any ruling of a governmental or regulatory authority, court, or by mandatory law; or if it is otherwise necessary for the purposes of preventing, or investigating, any breach of law, user terms or good practices or to protect the rights of Adeki Ltd or a third party.

Transfer of the personal data outside the EU or the EAA The controller may transfer personal data outside the EU and the ETA due to technical implementation when the controller uses external service providers to store data on the basis of a mutual partnership agreement. These transfers will always be carried out securely in accordance with data protection legislation and within the limits set by this legislation.

Rights of the data subject The data subject has the right to inspect his/her personal data and request to change possible inaccurate, incomplete or outdated data. Such an inspection is granted free-of-charge once a year. Any requests to inspect or to modify this data shall be indicated in person, or by a signed letter or similarly verified document to the controller’s person in charge of the data file, so that Adeki Ltd can confirm that the requestor has the right to make such a request. The requests are handled within one month from the date they were made.

The data subject has at any time the right to withdraw previously given consent for processing his/her data. The data subject can at any time make a complaint to authorities regarding the processing of his/her personal data. The data subject also has the right to request the erasure of his/her personal data from the data file providing that they are no more needed for the purpose they were collected for or that there are no legal obligations in effect concerning the controller regarding the processing or storing them. The data subject can request to restrict the use of his/her personal data or oppose the use of his/her personal data for e.g. direct marketing and relating profiling, too.

Data protection statement updates This data protection statement has been updated 15th February 2019.

Adeki Ltd is constantly following the updates on existing data protection and personal data legislation and aspires to continuously develop its business. Thus, Adeki Ltd reserves the right to update this data protection statement.