This website is operated by AdES Consulting & Services srl, a company registered in Italy at 82 Via Empedocle Restivo, Palermo, 90144, (“AdES”, “we”, “us”, or “our”).
AdES Consulting & Services is a branch of AdES Group. Our business has been built over the years with excellent relationships, service and knowledge of products that we supply to our customers.
What type of information is collected from you?
Depending on the nature of your interaction with us, we may collect, use, store and transfer the following kinds of personal data about you:
- Identity Data includes first name, last name, company name, VAT number, referees and proof of an association.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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 our website.
- Profile Data includes your preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. We own all right, title and interest in Aggregated Data. 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 notice.
Other than specific information that you might provide to us that are relevant to the provision of services to you (such as in relation to you or a member of your organisation’s physical or health requirements) 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. In this case, we may have to cancel a service or order you have with us, but we will notify you if this is the case at the time.
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 making an enquiry with us, when we process your order, or when you register or apply for a web, credit or cash account with us, in each case whether online, by post, phone, email or otherwise.
- Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties: analytics providers
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services in relation to your use of our website.
- Identity and Contact Data from data brokers or aggregators.
We also use CCTV surveillance in order to prevent our services and facilities from being used for illegal purposes and to protect our employees and customers. Personal data in this context may be processed by us or law enforcement authorities for these purposes.
Use of personal data under applicable data protection laws must be justified under one of a number of legal ‘grounds’. We are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds which justify our use of your information:
Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent in relation to any such use, and may withdraw your consent by notifying us).
Legitimate Interest: 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).
Performance of Contract: 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: processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you or a third party.
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. We have also identified (where appropriate) what our legitimate interests are.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To process and deliver your order or requested services, including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us||(a) Identity(b) Contact(c) Financial(d) Transaction||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) 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)(b) Necessary to comply with a legal obligation (to prevent fraud)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of customers for our 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 about goods or services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications||Necessary for our legitimate interests (to develop our services and grow our business)
Consent, where we are sending you third party marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Marketing from us
You will receive marketing communications from us including newsletters and marketing emails relating to our similar services, if you have requested information from us, used our services, or provided us with your details and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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 have to share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties such as:
- Service providers acting as processors who provide IT, system administration, analytics, marketing, finance, HR services and other business services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Legal basis: legitimate interests (to operate the business and provide related 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 notice.
Legal basis: legitimate interests
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 (except as may be permitted by law for compliance purposes) and only permit them to process your personal data for specified purposes and in accordance with our instructions.
HOW DO WE PROTECT YOUR DATA?
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 access it. 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.
Transferring your information outside of Europe
Since we operate internationally, it may be necessary to transfer personal data to another recipient (such as partners and third-party service providers) in a country outside of the country where it was originally collected or outside of your country of residence or nationality. For many of our business purposes, we use cloud-based services. Therefore, for technical and organizational reasons, it may be necessary that your personal data is transferred to servers located countries outside of 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.
- With your express consent or as otherwise lawfully permitted by the applicable data protection laws.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
How long will you use my personal data for?
We will only retain your personal data 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.
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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
- Right to complain. You have the right to lodge a complaint to a supervisory authority. Although we encourage our customers to engage with us first in the event they have any concerns or complaints.
Procedure and Timing to Exercise Rights
You may contact us at email@example.com to exercise these rights. We will ask you for information in order that you can identify yourself.
Requests will be responded to within one month. We are entitled to extend this term by another two months if the complexity of the situation requires it and we shall notify you if the period is extended. If your request is manifestly unfounded or excessive we may either charge you a fee or refuse to process your request. With respect to access requests, we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.
Last reviewed: May 2018