AdaptiveComms understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Adaptive Communication Solutions Limited.
Limited Company registered in England under company number 4677602.
Registered address: 11b Hoghton St, Southport. PR9 0NS
VAT number: 811948718.
Data Protection Officer: Ms L Pritchard.
Email address: email@example.com
Telephone number: 01704540547.
Postal Address: 11b Hoghton St, Southport. PR9 0NS.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the GDPR) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Information about your preferences and interests;
Your personal data is obtained from the following third party:
- Credit safe for the purpose of credit checking when we enter a business relationship;
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and/or services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and /or post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing or calling the data controller).
- For conducting credit checks prior to starting a business relationship and at various times throughout it.
- For the purposes of creating a bill for our products and services.
- For managing delivery of project work and/or other installation and/or jobs at your site
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will, therefore, be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
7a. Prospects, customers and suppliers, until they are post-implementation
There may be many pieces of information used for draft in this phase.
As the appointment is booked the file is to be ticked as no contact and removed at the next database clean-up.
Once the sale is complete the salesperson will reduce files (both e and paper) to only necessary information for implementation, proof of theory and proof of deal.
Implementations will pass the quote and contract to accounts who will retain master copies. Post-implementation customer service will pass the files to Account Management who will create 2 files
- Account management file with basic AM and service details in
- Proof of theory file which will be stored until 24 months after service ends, or in the event of a dispute until 24 months after that dispute ends.
7b. Human Resources Data
Data can be held for varying time lengths, in the case of employees (Human Resource Records) we will keep relevant personal data in their paper personnel file and electronically. We have the following data retention policies.
- We will keep information fully for the entire period of their employment
- We will destroy all information not required for compliance within 6 months of the end of their employment if there has been no further involvement (tribunals etc).
- Where there has been further involvement we will retain the files for 6 months after the end of any further involvement such as tribunal etc.
- Compliance information, such as proof we are paying the minimum wage will be retained until up to 90 days after our statutory requirement to keep it has been fulfilled.
7c. Customer & Supplier Data
For Suppliers and Customers, data can also be held for varying time lengths. We have the following data retention policies.
- we will retain orders, contracts, quotes and the like (which may feature personal information) for 5 years after the services termination date in order to protect our business from spurious claims.
- If the customer/supplier has agreed to be re-contacted about future business opportunities at a future date, relevant information will be kept.
- We will destroy all other information not required for compliance (such as emails) within 24 months of the termination of contract/services if there is no dispute. If there is any dispute the entire file(s) will be retained until the dispute is resolved.
- Where information is stored on workflow management systems etc, the data will be deleted following the same policies as above.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the EEA). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group for contractual, legal and account management purposes. This includes 21st Century Network Solutions Limited.
We may sometimes contract with the following third parties to supply products AND/OR services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- First Capital for Direct Debit Collection
- Various telecom and IT suppliers for billing and product delivery.
- Credit Safe for credit checking.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 4 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Ms L Pritchard):
Email address: firstname.lastname@example.org
Telephone number: 01704540547.
Postal Address: 11b Hoghton St, Southport, PR9 0NS.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available in the privacy section of our website.