Privacy Policy

Last updated: Aug 01, 2024

Adapt2web, trading as Adapt2web, (‘we’/’us’/’our’) may be in a position to receive and process personal information relating to you. As the controller of this information, we’re providing this Privacy Notice (‘Notice’) to explain our approach to personal information.

We intend only to process personal information fairly and transparently as required by data protection law including the UK General Data Protection Regulation (UK GDPR). Before obtaining information from you, we intend to alert you to this Notice and let you know how we intend to process the information. We’ll only process the information as permitted by law. The UK GDPR also defines certain special categories of personal information that’s considered more sensitive. These categories require a higher level of protection, as explained below.

We’ll start this Notice by setting out the conditions we must satisfy before processing your personal information. However, you may wish to skip to clause 4, which summarises what we intend to collect. The Notice also explains some of the security measures we take to protect your personal information, and tells you certain things we will or won’t do.

1. Identity and contact details

1.1 Registered number: SC813499

1.2 Registered office: 231 Langside Road, Glasgow, G42 8XY

1.3 Phone: +447831541861

1.4 Email: Nimlesh.john@adapt2web.com

1.5 Website: https://adapt2web.com/

1.6 Our Data Protection Officer (DPO) would welcome communication from you regarding any matter relating to data protection, and can be contacted by email at nimlesh.john@adapt2web.com or by phone on +447831541861.

2. When we're allowed to collect information from you

We will only collect personal information relating to you if one of the following conditions has been satisfied:

2.1 You have clearly told us that you are content for us to collect that information for the particular purpose or purposes that we will have specified.

2.2 The processing is necessary for the performance of a contract that we have with you.

2.3 The processing is necessary so that we can comply with the law.

2.4 The processing is necessary to protect someone’s life.

2.5 The processing is necessary for the performance of a task that’s in the public interest.

2.6 The processing is necessary for our or another’s legitimate interests – but in this case, we’ll
balance those interests against your interests.

3. How to consent

3.1 If we need your consent to collect and use certain information, we’ll endeavour to explain how we intend to use it and which of the above purposes apply, and provide you with the opportunity to tell us that you’re happy to provide that information at the point of collecting it.

3.2 If at any point in time you change your mind and decide that you want to withdraw your consent, please let us know and we’ll endeavour to stop processing your information in the specified manner, or we’ll delete your information if there is no continuing reason for possessing it.

3.3 If you don’t consent to a particular bit of processing, it may affect a service that we provide or the performance of any contract we have with you, but we’ll endeavour to continue to operate without the need for that information.

4. Information we expect to collect from you

4.1 We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal justifications we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4.2 Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Information type	Purpose and related details	Justification
For creating their website	We collect this to Create website	We'll ask for your consent

4.3 We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.

a. Before doing that, if practical we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case, we’ll only record the call if our interest outweighs yours. This will depend on all the circumstances, in particular the importance of the information and whether we can obtain the information another way that’s less intrusive.

b. If we think the recording would be useful for us but that it’s not necessary, we’ll ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you don’t consent, the call will either automatically end or will not be recorded.

4.4 We may collect personal information about you from a number of sources, including the following:

a. From you when you make a payment to us.

b. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.

c. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about your interests or preferences or how you use our products or services.

d. From documents that are available to the public, such as the electoral register.

e. From third parties. If we receive information about you from a third party, then as soon as reasonably practicable afterwards we’ll let you know; that’s required by the UK GDPR.

4.5 If you refuse to provide information requested, and if that information is necessary for a service we provide to you or to perform a contract we have with you, we may need to stop providing or performing it.

4.6 If at any point you think we’ve invited you to provide information without explaining why, feel free to object and ask for our reasons.

5. Using your personal information

5.1 Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which UK GDPR justification applies; however it will depend on the circumstances of each case.

a. To help us to identify you when you contact us. This will normally be necessary for the performance of our contract.

b. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information you’ve provided and/or any
information we hold about you and personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it.

c. To help us to administer and to contact you about improved administration of any accounts, subscriptions, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether you agree.

d. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.

e. To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it.

f. To allow us to contact you by written electronic means (such as email, text or multimedia messages) about products and services offered by us where:

i. these products are similar to those you have already purchased from us,

ii. you were given the opportunity to opt out of being contacted by us at the time your personal information was originally collected by us and at the
time of our subsequent communications with you, and

iii. you have not opted out of us contacting you.

g. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.

5.2 We will not share your personal information with any third party except in accordance with this Notice, or in the following circumstances:

a. We may engage companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, processing payments and providing customer service. Those parties must comply with this Notice and will be bound by strict contractual provisions with us in accordance with the UK GDPR and will only have access to personal information needed to perform their functions, and they may not use it for any other purpose. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Notice and the UK GDPR.

b. We may also share your personal information with:

i. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting
services.

ii. HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances, including where disclosure is required to a law enforcement agency, e.g. where we know or suspect that a transaction may involve such illegal activities as money laundering or terrorist financing.

iii. 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 information in the same way as set out in this Notice.

c. It may also be necessary to use your information to help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it.

d. Third parties if we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

5.3 Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Notice and that they have not objected to such use of their personal information.

5.4 In connection with any transaction which we enter into with you:

a. We may carry out one or more credit checks.

b. We may carry out one or more fraud prevention checks with licensed fraud prevention agencies.

c. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records may also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.

d. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.

e. If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please contact our Data Protection Officer as detailed in clause 1.6.

f. We may need to transmit the payment and delivery information provided by you during the payment process for the purpose of obtaining authorisation from your bank, card issuer or from PayPal.

6. Protecting information

6.1 We have put in place 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.

6.2 We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we’re legally required to do so.

6.3 We reveal only the last five digits of your debit or credit card number when confirming a payment. Of course, we transmit the entire card number to the card issuer during payment processing.

6.4 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

6.5 It’s also important for you to protect your personal information. For example, electronic communications are not secure unless they have been encrypted. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

7. Retaining information

7.1 We will only retain your personal information 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 information 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.

7.2 To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal
information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

7.3 Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us.

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

7.5 In some circumstances we may anonymise your personal information (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.

8. Your legal rights

8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal information.

8.2 You have the right to:

a. Request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

b. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

c. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we’re required to erase your personal information to comply with the law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

d. Object to processing of your personal information where we’re 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’re processing your personal information 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.

e. Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following situations:

i. if you want us to establish the information’s accuracy;

ii. where our use of the information is unlawful but you do not want us to erase it;

iii. where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or

iv. you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

f. Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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.

g. Withdraw consent at any time where we’re relying on consent to process your personal information. 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 or perform a contract we have with you. We will advise you if this is the case at the time you withdraw your consent.

8.3 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

8.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

8.5 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.

9. Further information

9.1 If you would like any more information or you have any comments about this Notice, or if your wish to exercise any of your legal rights, please write to our Data Protection Officer as detailed in clause 1.6.

9.2 Please note that we may have to amend this Notice on occasion. If we do that, we will endeavour to alert you to the change, but it’s also your responsibility to check regularly to determine whether this Notice has changed.

9.3 You can ask us for a copy of this Notice by writing to the above address or by emailing us at Nimlesh.john@adapt2web.com. This Notice applies to personal information we hold about individuals. It does not apply to information we hold about companies and other organisations.