Adapto Technologies ApS (“Adapto” / “we” / “our” / “us”) are committed to protecting and respecting your privacy.
This policy stipulates how we will process any personal data we collect from you or that you or your employer provides to us through your use of the Adapto online software and the accompanying software App (together the “Adapto Services ”).
We advise you to read this policy carefully to understand our views and practices regarding your personal data.
By visiting www.leaders-companion.com, www.leaders-companion.dk or Adapto.me or using the Adapto Services you are accepting the practices described in this policy.
INFORMATION WE COLLECT ABOUT YOU
We will collect and process the following data about you:
Information you give us.
You may give us information about you when using the Adapto Services, including by filling in forms or similar. This information may include your name, age, company email address, company telephone number, date of birth, job title, level of seniority, department, work start date and primary office location, as well as any data you provide to us about your performance in your role, or information regarding your employer, your colleagues or other third parties while using the Adapto Services.
If you choose to contact or correspond with us (for example, using any support function made available by us like email, chat or phone) we may keep a record of that correspondence (either directly or through our service providers).
Information your employer gives us.
Your employer may give us information about you when creating a user profile for you in order to enable you to access the Adapto Services (whether on a trial or full basis) or to enable us to send communication to you. This information may include your name, age, company email address, company telephone number, date of birth, job title, level of seniority, department, work start date, time zone and primary office location.
Information we collect about you.
Each time you use the Adapto Services we may collect the following information:
- We will keep a record of the details of your usage of the Adapto Services, including the date, time, location, frequency and duration of the usage.
- Any comments, opinions and/or feedback you provide to us regarding the Adapto Services.
- Technical information about your computer or mobile device for system administration and analysis, including your IP address, URL clicks, unique device identifiers, operating system, and network and browser type.
- Other information about your use of the Adapto Services, including the pages you have viewed, the duration spent on the Adapto Services and data files you have uploaded to the Adapto Services. This information may be linked to your user profile if deemed relevant.
HOW WE USE YOUR INFORMATION
Please be aware that, we are permitted to collect, use, disclose and/or otherwise process any data or information other than personal data, including data sets you upload to the Adapto Services or otherwise provide to us.
We may use the personal information we hold about you in the following ways:
- Ensure specific and personalised learning materials and user experiences for you as part of the Adapto Services process.
- Produce reports and dashboards as part of the Adapto Services process. This also includes to aggregate and anonymise your data for statistical and benchmarking purposes.
- Contact you for your feedback on our services and to help us evaluate and improve our services.
- Deal with any enquiries, correspondence, concerns or complaints you may have.
- Notify you about changes and improvements to Adapto Services including informing you about new versions and about new features, functionality and service offerings.
- For internal operations, including troubleshooting, analysis, testing, research, statistical and survey purposes.
Rest assured we will not contact you for promotional or marketing purposes unless you specifically agree to this or you expressly request (or provide explicit consent for) us to do so at a later date.
DISCLOSURE OF YOUR INFORMATION
We may also share your personal information with selected third parties in accordance with this policy, including:
Service providers, for example of IT services, business partners, suppliers and/or sub-contractors, for the performance of the Adapto Services including(but not limited to):
- Microsoft Azure
We may disclose your personal information to other third parties:
- if we sell or buy any business assets or receive investment in our business, we may disclose your personal data to the prospective or actual buyer, seller or investee of such business or assets;
- if Adapto Technologies ApS or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your data and data about our customers, suppliers, and correspondents will be one of the transferred assets; and
Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.
We require our service providers to comply with data protection laws whenever they process your personal information and not to disclose your data to third parties without our express consent. Please see our Security Terms at www.adapto.me/security
RETAINING YOUR INFORMATION
We will retain the personal information we receive and collect from you for a period of 5 years or until six months after our relationship has ended (whichever is sooner). Your personal data will then be anonymised. We will not store your personal data for longer than is reasonably necessary to use it in accordance with this policy or with our legal rights and obligations. To avoid any doubt, aggregated and anonymised data and any information other than personal data can be stored indefinitely.
You have the following rights in regards to your personal information:
Access. You have the right to access information about the personal data we hold about you. We reserve the right to charge a reasonable fee in response to unreasonable or repetitive requests, or requests for further copies of the same information.
Rectification or erasure. You have the right to request that we rectify or delete any personal information that we hold about you. Please note, if you request that we erase any personal information that we require in order to provide the Adapto Services to you, you may no longer be able to use the Adapto Services.
We also reserve the right to retain your personal data in an anonymised form for statistical and benchmarking purposes.
Portability. You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies.
Change of preferences. You can change your data processing preferences at any time. For example, if you have given your consent to direct marketing, but have changed your mind, you have the ability to opt out of receiving marketing communications by emailing us at email@example.com or clicking the relevant link in any communication you receive.
Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to facilitate your use of the Adapto Services, you will no longer be able to use the Adapto Services following your request to stop the relevant processing. This does not include your right to object to direct marketing which can be exercised at any time without restriction. Please allow at least 5 working days for your request to be actioned.
OBJECTIONS AND COMPLAINTS
In certain circumstances, you have the right to object to our processing of your personal data. If for any reason you are not happy with the way that we have handled your personal information, you also have the right to make a complaint to the Danish Data Protection Agency.
Date of last update:
30. August 2018