Introduction
Welcome to the Privacy Policy of Adnitor Limited (referred to as “Adnitor limited”, “we” or “us”).
Adnitor limited has developed this privacy policy (the “Privacy Policy”) to ensure your personal data as a user of the website at adnitor.com (the “Website”) or our services, is secure, private and in compliance with relevant data protection and privacy laws.
This Privacy Policy should be read in conjunction with our Terms and Conditions and Cookie Policy.
This Privacy Policy specifies how we handle your personal data when you visit the Website and informs you of your legal privacy rights.
1.Important information and who we are
Purpose of the Privacy Policy
This Privacy Policy aims to inform you about how we collect and process your personal data when you use the Website or our services, including any data you may provide when you sign up to our marketing communications.
The Website is not intended for children and we do not knowingly collect data relating to children.
In order to ensure how and why we process your data it is important that you read this Privacy Policy together with our Cookie Policy and any other privacy policy or fair processing notice which we may provide on specific occasions when we are collecting or processing your personal data for a specific purpose. This Privacy Policy supplements the other notices and is not intended to override them.
Controller
For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Adnitor Limited is the controller and responsible for your personal data.
We have appointed a Data Protection Manager 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 data protection manager using the details set out below.
Registration with the Information Commissioner’s Office (“ICO”)
Adnitor Limited is registered as a fee payer at the Information Commissioner’s Office with registration number is: ZA921750
Data protection manager
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Manager in the following ways:
Jason Fry, Managing Director
Adnitor Limited
9-13 St. Andrew Street
London EC4A 3AF
info@adnitor.com
+44 (0) 204 534 3455
Complaints
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). Should you have any concerns about the handling of your data or privacy we would welcome the opportunity to address such concerns and give due consideration to any complaints submitted directly to us before any contact is made to the ICO.
Changes to this Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review. This Privacy Policy was last updated on 4th Feb 2022.
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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this Website, we encourage you to read the privacy policy of every website you visit.
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).
Depending on the nature of our relationship with you or your use of the Website or our services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 IT services). In this case, we may have to cancel your engagement with us but we will notify you in advance.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
You may give us your personal data by completing forms (physical or digital) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you subscribe to our services or to our marketing communications, request information to be sent to you, provide us feedback, or enter into a contract with us.
As you interact with this Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
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:
Generally we do not rely on consent as a legal basis for processing your personal data other than to send you our marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below 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. Where applicable we have identified what our legitimate interests are in relation to the processing of your data.
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 client | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver IT services to you, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) taking instructions, preparing and delivering advice |
(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 notifying you about changes to our terms or this Privacy Policy | (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 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) |
Marketing
We strive to give you control over the processing of your data and provide you with choices regarding its use, particularly around marketing.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which marketing communications we will send to you.
You will receive marketing communications from us if you have requested information from us, or if you provided us with your details at promotional event or similar networking occasion. In each case, you will only receive marketing communications if 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 company outside the company for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing communications at any time.
Where you opt out of receiving marketing communications, this will not apply to personal data provided to us as a result of your working relationship with us.
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 visit 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 would like 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 be required to process your personal data without your knowledge or consent, in compliance with the above rules, where it is a legal obligation to do so.
5. Disclosures of your personal data
We may have to share your personal data with External Third Parties (defined in the Glossary below) for the purposes set out in the table in paragraph 4 above.
We may also share your personal data with 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.
6. International transfers
We do not transfer your personal data outside the European Economic Area (“EEA”) except where required on individual matters and with your prior consent. We will update this Privacy Policy if this changes.
7. 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 will be required to use or access your personal data in order to perform their functions. They will only process your personal data on our instructions and they are subject to a strict 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 will you store my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we are required to keep certain information about our clients (including Contact, Identity, Financial and Transaction Data, but also in relation to your business matters) for minimum periods of time. In most cases, files held in our storage will normally be deleted after 7 years. For more information on our legal obligations to retain and store client data, please contact our Data Protection Manager as described above.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
In some circumstances we may 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.
Please contact our Data Protection Manager if you would like more information on the retention periods for different categories of personal data.
9. 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:
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 in such circumstances we may refuse to comply with your request.
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 may 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.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 is the Cookie Policy of our website at adnitor.com (our “website”).
adnitor.com is a website owned and operated by adnitor limited, of 9-13 St Andrew Street, London EC4A 3AF (“We”).
Like many websites, when you visit our website, in order to deliver a full browsing experience a small amount of information, known as a “cookie” will be downloaded to your device, (e.g. your computer, laptop, tablet or mobile phone). These cookies cannot be used to identify you personally.
These cookies are used to improve your browsing experience by, for example:
If you would like to learn how to manage and remove cookies from your device please visit the following website: http://www.aboutcookies.org
1. Cookies we use on this website
A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.
We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website but the information does not usually identify you directly. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
These also include social media plug-ins which enable you to share our website content via your social media account(s) or easily share information with others. We have a presence on YouTube, LinkedIn and Twitter, and if you click on any of these icons on our website, you will be taken to our pages or profiles on those platforms. The platforms may then start tracking your behaviour using cookies for their own purposes; for example, to better understand your interests so that they can present relevant content or advertising to you. Data about you may also be transmitted to the social media channel even if you do not click on the plug-in. The social media platforms will provide us with statistical information, which we use to help understand how you and our other users interact with our social medial presence. All these platforms provide you with some control over their use of non-essential tracking technology and you can find details of how to exercise this control by reviewing their privacy and cookie notices. We have contractual arrangements in place with the social media channels we use. Please contact us for more information.
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 generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
You can change your cookie preferences at any time by clicking on the icon at the bottom left of this webpage. You can then adjust the available sliders to “On” or “Off” and then click “Save and close”. You may need to refresh your page for your settings to take effect.
Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:
If you use a smart phone, you can usually prevent cross-site tracking and block cookies in the settings section on your device. You may also be able to visit websites without leaving a history by turning private browsing on. You should visit the support section of the website of your device for more information on how to do this.
Strictly necessary cookies
These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.
You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Performance cookies
These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site. All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
These cookies are set by the Google Analytics service, but hosted by Adnitor Limited.
| HOST | COOKIE NAME | DURATION |
|---|---|---|
| adnitor.com | _ga | 1 year |
| adnitor.com | _gat | 1 minute |
| adnitor.com | _gid | 24 hours |
Targeting cookies
We do not currently use targeting cookies.
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 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.
2. How to Refuse the Use of Cookies
Most web browsers allow some control of most cookies through the browser settings. You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality such as personalisation and ‘keep me signed in’ and ‘remember me’ features.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
3. How to Disable Cookies in Your Browser
Here’s how to prevent new cookies from being installed and how to delete existing cookies. The exact procedure depends on which browser you are using.
Internet Explorer
To prevent new cookies from being installed and delete existing cookies: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Firefox
To prevent new cookies from being installed: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
To delete existing cookies: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Google Chrome
To prevent new cookies from being installed and delete existing cookies:
https://support.google.com/chrome/answer/95647?hl=en
Safari
To prevent new cookies from being installed and delete existing cookies:
http://help.apple.com/safari/mac/8.0/#/sfri11471
If you have any questions about our cookie policy, please contact us at info@adnitor.com
Discover how the Adnitor Co-Managed IT Service can work for you.
9-13 St. Andrew Street
London
England
EC4A 3AF
at-one@adnitor.com
Phone: (+44) 204 534 3455