We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Acts 1988 and 2003 and Directive 95/46/EC, any other applicable law or regulation relating to the Processing of Personal Data and to privacy (including the E-Privacy Directive and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR, and laws amending or supplementing the E-Privacy Regulations).
We fully respect your right to privacy in relation to your interactions with the Service and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual’s information where we are legally entitled to do so. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commissioner (“DPC”).
We may collect Personal Data from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our Service or as a result of your relationship with one or more of our staff. The information that we process includes: (i) basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person; (ii) contact information, such as your postal address, email address and phone number(s) and your areas of interest in relation to Adaptive; (iii) financial information, such as payment-related information; (iv) technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically, including number of visitors and visits, geo-location data, length of time spent on the site, pages clicked on and/or where visitors have come from; (v) navigational information, refers to information about your computer and your visits to the Adaptive website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. (vi) Log Files, when you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Adaptive to provide general statistics regarding use of the Adaptive website. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number; (vii) Information we collect from third parties: from time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites or (viii) any other information relating to you which you may provide to us.
Information About Children. The Adaptive website is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16. If you believe that we have collected personal information about a child under 16, please contact us so that we may delete the information. If you are aged 18 or under, you will need your parent/guardian's permission before you provide Your Data to us.
In the event that you use our online recruitment platform we may collect additional data, including your work and education history, salary expectations, notice periods, information with respect to your eligibility to work in certain jurisdictions and information volunteered (but not required) on the CV you submit to help us process your recruitment application. We will use the collected data to communicate with you about your job application.
Any Personal Data that we collect from you for these purposes is hereinafter referred to together as “Your Data”). Adaptive is a Data Controller (as defined in Data Protection Legislation) in respect of the Your Data.
We endeavour to keep Your Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible. You can change your stated interests in respect of whether or not you wish to receive direct marketing from us by clicking ‘unsubscribe’ on any direct marketing electronic communication which you receive from us.
We collect information from you as necessary in the course of providing our Service, including responding to sales and contact enquiries and with respect to job applications. We may collect your personal information while monitoring our technology tools and services, including our website and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly. We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.
We use that information: (i) to provide and improve our website, including auditing and monitoring its use; (ii) to provide and improve our Service to you; (iii) to provide information requested by you and communicate with you about your requests for product information and any request to be contacted by an Adaptive employee; (iv) to send you updates, publications, details of events and relevant business and marketing news, including but not limited to, sharing threat intelligence reports, blog posts, press releases, job opportunities and newsletters; (v) to manage and administer our relationship with you; (vi) to fulfil our legal, regulatory and risk management obligations; or (vii) or the purposes of recruitment.
We use Navigational Information to operate and improve the Adaptive website and to provide you with a better experience when you interact with Adaptive. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Adaptive. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time by contacting us (see Section 6).
A cookie is a small text file that is placed on your device by a web server which enables a website and/or mobile app to recognise repeat users, facilitate the user's ongoing access to and use of a website and/or mobile app and allows the website and/or mobile app to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. We collate information on in relation to the Service which is represented in aggregate format through cookies. They help us to improve our Service and to deliver many of the functions that make your browser experience more user friendly.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on's settings or visiting the website of its manufacturer.
You can find a list of cookies we use and the purposes for which we use them in the tables below.
You should also be aware that there are cookies which are found in other companies' internet tools which we may use to enhance the website. You may see ‘social buttons’ during your use of the website, including but not limited to Twitter and LinkedIn, which enable you to share or bookmark certain web pages. These websites have their own cookies, which are controlled by them.
We may contact you:
As a data subject, you have the following rights under Data Protection Legislation and we, as Data Controller in respect of Your Data, will comply with such rights in respect of Your Data:
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see ‘How To Contact Us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right of access to Personal Data relating to you
You may ask to see what Personal Data we hold about you and be provided with:
Requests for your Personal Data must be made to us (see 'How To Contact Us' below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Service and our website. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your Personal Data or correct any mistakes in your Personal Data
You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:
If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How To Contact Us’ below).
Right to ask us to stop contacting you with direct marketing
We have a legitimate interest to send you electronic communications/direct marketing in connection with the Service and related matters (which may include but shall not be limited to blog posts, press releases, job opportunities, threat intelligence reports, newsletters, announcement of new features etc.). We may also ask you to consent to the receipt of certain direct marketing from time to time. We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
We will provide you with information on action taken on a request to stop direct marketing - this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of your use of the website or the Service.
Rights in relation to automated decision taking (if applicable)
You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.
Right to restrict or prevent processing of Personal Data
In accordance with Data Processing Legislation, you may request that we stop processing your Personal Data temporarily if:
If you exercise your right to restrict us from processing your Personal Data, we will continue to process the Personal Data if:
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
Right to erasure
In accordance with Data Protection Legislation, you can ask us (please see ‘How To Contact Us’ below) to erase your Personal Data where:
We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where we have a legal justification to continue to hold such Personal Data, such as it being within our legitimate business interest to do so (e.g. retaining evidence of billing information etc.). Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
We restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, provide, develop, or improve our Service/website. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations.
We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our website, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Service.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
We do our utmost to protect user privacy through the appropriate use of security technology. Adaptive has achieved the ISO-27001 security accreditation and applies these standards across its business. We restrict access to Your Data to employees, contractors and agents who need to know Your Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, our website may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of any data transmitted us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Data arising from such risks. WITHOUT LIMITING OUR OBLIGATIONS IN THE 'PROTECTION OF CUSTOMER DATA' SECTION OF THIS AGREEMENT, WE MAKE NO REPRESENTATIONS OR WARRANTIES ABOUT THE SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, SECURITY OR ACCURACY OF THE ADAPTIVE WEBSITE, DATA MADE AVAILABLE FROM THE ADAPTIVE WEBSITE, ADAPTIVE CONTENT, FOR ANY PURPOSE. APPLICATION PROGRAMMING INTERFACES (APIs) MAY NOT BE AVAILABLE AT ALL TIMES. TO THE EXTENT PERMITTED BY LAW, THE ADAPTIVE WEBSITE, AND ADAPTIVE CONTENT ARE PROVIDED "AS IS" WITHOUT WARRANTY OR CONDITION OF ANY KIND. WE DISCLAIM ALL WARRANTIES AND CONDITIONS OF ANY KIND, WHETHER EXPRESS, IMPLIED OR STATUTORY, WITH REGARD TO THE, ADAPTIVE WEBSITE AND ADAPTIVE CONTENT INCLUDING ALL IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT.
IF, NOTWITHSTANDING THE OTHER TERMS OF THIS AGREEMENT, EITHER PARTY IS DETERMINED TO HAVE ANY LIABILITY TO THE OTHER PARTY OR ANY THIRD PARTY, THE PARTIES AGREE THAT THE AGGREGATE LIABILITY OF A PARTY WILL BE LIMITED TO ONE THOUSAND EURO.
WE DISCLAIM ALL LIABILITY WITH RESPECT TO THIRD-PARTY PRODUCTS THAT YOU USE. OUR LICENSORS WILL HAVE NO LIABILITY OF ANY KIND UNDER THIS AGREEMENT.
We will notify serious data breaches in respect of Your Data to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
Your Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Data as necessary to manage our website, comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Service.
Where we retain information for Service/website improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service/website, not to specifically analyse personal characteristics about you.
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to [email protected]. Adaptive has a Data Protection Officer who is responsible for matters relating to data protection and privacy. The Data Protection Officer can be reached at the following address:
Attn: Data Protection Officer
4th Floor, Ferry House
48-52 Lower Mount Street