Website Privacy Notice

Adapted Creative Limited (the “Company”) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about visitors to our website, in accordance with applicable data protection law. It applies to all visitors to our website, but does not form part of any contract to provide services. The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about visitors to our website. We are required under data protection legislation to notify you of the information contained in this privacy notice. It is important that you read this notice. We may amend this notice at any time.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

Personal data and sensitive personal data

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). There are “special categories” of more sensitive personal data which require a higher level of protection. These are data about ethnic origin, political opinions, religious or similar beliefs, trade union membership, health, sex life, criminal proceedings or convictions, and genetic or biometric data.

The kind of information we hold about you

We may collect, store, and use the following categories of personal information about you:

Business contact details such as name, title, addresses, telephone numbers, and email addresses.
Gender.
Working location.
Information about your use of our information and communications systems.

We may also collect, store and use the following “special categories” of more sensitive personal information:

Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

How is your personal information collected?

We collect personal information about visitors to our website directly from them from information they have chosen to share with us through the website.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform a contract we have entered into with you.
Where we need to comply with a legal obligation.
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.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.

We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations.
Where it is needed in the public interest.
Where it is necessary to protect you or another person from harm.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform a contract we have entered into with you or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Consent

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at info@adptd.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Information about criminal convictions

We do not envisage that we will hold information about criminal convictions. We may only use information relating to criminal convictions if it is appropriate and provided that we are legally able to do so. This will usually be where such processing is necessary to comply with our legal or regulatory obligations, provided we do so in line with applicable data protection obligations.

Data sharing

We may have to share your data with third parties, including third-party service providers, where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction. We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, disclosures to stock exchange regulators, and disclosures to shareholders such as directors' remuneration reports.

Transferring information outside the UK

The personal data that we collect from you may be stored on a mix of the Company’s and various cloud providers’ platforms and may be transferred to, and stored outside of, the UK. It may also be processed by staff operating outside of the UK who work for us, or for one of our suppliers. Where we do so, we will always ensure it is in compliance with any relevant data protection laws.

Security

We have appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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.

Data retention

We will only retain your personal information for as long as necessary to fulfil 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.

Rights of access, correction, erasure, and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”).
Request correction of the personal information that we hold about you.
Request erasure of your personal information.
Object to processing of your personal information.
Request the restriction of processing of your personal information.
Request the transfer of your personal information to another party.

If you would like to make a Subject Access Request (SAR) or Data Subject Access Request (DSAR), please fill out the online form here. Alternatively you can make the request by email at info@adptd.co.uk by sharing the following information:

Full name of the requester.
Contact details (email, phone number).
Description of the request (e.g., access, update, delete personal data).
Proof of identity (ID card or passport copy).

No fee usually required

You will not have to pay a fee to access your personal information (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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access information you are requesting (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.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time.

Contact

For further information about your rights, or if you have any questions about this privacy notice or how we handle your personal information, please contact us at info@adptd.co.uk. 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.