Privacy Policy

CUSTOMER WEBSITE PRIVACY NOTICE

This version was last updated in April 2023.

Welcome to the adm’s Website Privacy Notice (“Privacy Notice”) for the web portal with url (“Website”).

adm respects your privacy and is committed to protecting your Personal Data (as defined hereafter). This Privacy Notice aims to give you information on how adm collects and processes Personal Data of users of this Website, regardless of where you visit it from (hereinafter “User”, “you” or “your”), including any Personal Data you may provide through this Website, when you purchase a product or service, when we receive your registration data to create an account and/or when you use adm’s proprietary software (adm EXCHANGE). This Privacy Notice will also inform you about your rights in relation to your Personal Data.

The use of this Website is subject to our “Terms of Use”. More information on the use of cookies and similar technologies used on this Website can be found in our “Cookie Notice”.

Please read these documents together with this Privacy Notice, as well as with any other privacy notices or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.

Please also use the Glossary at the end of the Privacy Notice to understand the meaning of some of the terms used in this Privacy Notice.

The Personal Data provided will be processed in accordance with applicable data protection and privacy laws and regulations, including the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”) and implementing local laws, as well as the UK GDPR.

This Website is not intended for children and we do not knowingly collect Personal Data relating to children.

1. Who is responsible for the processing of your Personal Data?

adm promotions Spain SL is the controller unless otherwise indicated and is responsible for this Website (hereinafter “adm”, “we”, “us” or “our”).

Full name of legal entity: adm Promotions Spain SL

Registered address: EDIFICI IL.LUMINA, Gaspar Fàbregas, 81 3º, 08950 Esplugues de Llobregat, Barcelona

Company number: B65467748

2. The Personal Data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

  1. Identity Data, including first name, last name, username or similar identifier and/or title, Employing Company and job
    2. title.
  2. Contact Data, including billing address, delivery address, email address and telephone number.
  3. Transaction Data, including payment data, details of products and services you have purchased from us.
  4. Technical Data, including 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 information on the technology on the devices you use to access this Website.
  5. Profile Data, including your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
  6. Usage Data, including information about how you use our Website, products and services, any information disclosed to us when you contact us with a requests or complaint.
  7. Marketing and Communications Data, including your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

Where required under applicable law, we will obtain your consent to the collection, use and/or disclosure of your Personal Data.

The Personal Data that we specifically collect from you depends on the applicable purposes as described below.

If you fail to provide Personal Data

If we obtain Personal Data directly from you, you are in principle free to decide whether or not to provide adm with the Personal Data, except in the event of a legal obligation. Where we collect Personal Data to comply with a legal obligation, or under the terms of a contract we have with you or your Employing Company, and you do not wish to provide that Personal Data when requested, it is possible that you will not be able to use the Website, products or services that adm offers, that your questions cannot be answered and/or that you and/or your Employing Company will not be able to conclude an agreement with adm.

3. How is your Personal Data collected?

We use different methods to collect Personal Data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, through the Website, adm EXCHANGE or otherwise. This includes Personal Data you provide when you: correspond with us about our products or services; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us.

Automated technologies or interactions. As you interact with our Website, we may collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our Cookie Notice for further details.

  • Indirect collection. Contract, Financial and Transactional Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House, and the Electoral Register based inside the EU.

4. Purposes for which we may use your Personal Data

We have set out below, in a table format, a description of the ways we plan to use your Personal Data, and which legal basis under the (UK) GDPR and other applicable data protection legislation is relied on to process the Personal Data. We have also identified what our legitimate interests are where appropriate. Where required under applicable law, we will obtain your consent for the collection, use and/or disclosure of your Personal Data for the purposes described in this section.

Purpose/Activity Type of Personal Data Legal Basis for processing
To register you as a new customer (a) Identity (b) Contact Performance of a contract with you
To register you as an authorised user of your Employing Company’s account. (a) Identity (b) Contact Processing necessary for our legitimate interest to perform the contract with your Employing Company
To process and deliver an order including: (a) Manage payments, fees and charges, (b) Provide customer support, (c) Collect and recover money owed to us. (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications Certain processing may be necessary for a legal obligation incumbent on adm.If no such legal obligation applies, the processing will be necessary for
  • performance of a contract with you if we have a relevant contract with you; or
  • our legitimate interest to perform the contract with your Employing Company
Other processing may be necessary for our legitimate interest to recover debts due to us.
To communicate with you, including regarding: (a) your queries and/or complaints about our Website and products or services, (b) important information about your account and your products, e.g. to inform you that your payment has been accepted or your order has been processed. (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications Certain processing may be necessary to comply with a legal obligation.
If no such legal obligation applies, the processing will be necessary for our legitimate interests (process Personal Data of individuals in the context of sales or to answer questions or requests and to improve and promote out services this way).
To manage our relationship with you/your Employing Company which will include: (a) Notifying you about changes to our terms or Privacy Notice (b) Asking you to leave a review or take a survey. (a) Identity (b) Contact (c) Profile (d) Marketing and Communications Certain processing may be necessary to comply with a legal obligation.
If no such legal obligation applies,
  • if adm has a relevant contract with you, the processing will be necessary for the performance of a contract with you
  • if not, the processing will be necessary for our legitimate interest to perform the contract with your Employing Company

Other processing may be necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey. (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications If adm has a relevant contract with you, the processing will be necessary for the performance of a contract with you. If not, the processing will be necessary for our legitimate interest to perform the contract with your Employing Company.
In other cases, the processing will be necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
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 Certain processing may be necessary to comply with a legal obligation.
If no such legal obligation applies, the processing will be 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).
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 Where we are required by law to obtain your consent before processing such information, we will rely upon your consent as our basis for processing.
In other cases, the processing will be necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences. (a) Technical (b) Usage Where we are required by law to obtain your consent before processing such information, we will rely upon your consent as our basis for processing.
In other cases, the processing will be necessary for our legitimate interests (to define types of customers for our products and 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, by email or mail. (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Where we are required by law to obtain your consent before processing such information, we will rely upon your consent as our basis for processing (e.g. share your Personal Data with a third party for marketing purposes).
In other cases, the processing will be necessary for our legitimate interests (to develop our products/services and grow our business).
For management of disputes and possible legal proceedings, in order to comply with legal obligations or court orders. (a) Identity (b) Contact (c) Transaction (d) Technical (e) Profile (f) Usage (g) Marketing and Communications Certain processing may be necessary to comply with a legal obligation (complying with binding court orders).
If no such legal obligation applies, the processing will be necessary for our legitimate interests (defending our rights in and out of court and to collect Personal Data for use in resolving any disputes).
As part of a corporate transaction, to evaluate or carry out an acquisition, merger, demerger, restructuring, dissolution or other sale or transfer of some or all of our assets, whether by way of transfer of all or part of the business, or as part of a bankruptcy, liquidation or similar proceeding, in which Personal Data in our possession forms part of the transferred assets. (a) Identity (b) Contact (c) Transaction (d) Technical (e) Profile (f) Usage (g) Marketing and Communications Necessary for our legitimate interests (carrying out the said business transactions in order to implement our business strategies or grow our business)

In addition, if we use your information for purposes other than those mentioned above we will notify you of these purposes before using your information and obtain your consent (where necessary).

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.

5. Disclosures of your Personal Data

We require all third parties to respect the security measures applicable to your Personal Data and to treat it in accordance with the law.

In view of achieving one or several of the above-mentioned purposes, we share your Personal Data within the adm Group (on which you can find more information here). In addition, we can transmit your personal data to third parties who reasonably need access to those data. It concerns third parties, such as:

  • external service providers that adm relies on in the framework of granting access to you to the Website and allow you to use the Website, products and/or services: IT service providers, marketing agencies, subcontractors;
  • potential or future buyers of adm;
  • law enforcement and public authorities, in accordance with the applicable legislation;
  • external professional advisors (e.g. auditors, lawyers or consultants of adm).

6. International transfers

Please note that some parties who receive your personal data may be located in a country outside the European Economic Area (EEA) and/or the United Kingdom (UK) of which the legislation does not offer the same degree of data protection. We will ensure that your personal data is only transferred to parties that apply an appropriate level of data protection (e.g. where the European Commission has issued an adequacy decision or by including the so-called EU standard contractual clauses in the agreement with the recipient and subject to an appropriate data transfer impact assessment). You can contact us to receive a copy of the appropriate safeguards that apply to the transfer of your personal data using the contact details in Section 11 (Contact details).

7. Data Security

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 know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

8. Data retention: How long will you use my Personal Data for?

We will only retain your Personal Data 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 Data 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.

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, regulatory, tax, accounting or other requirements and the relevant statutory limitation or retention terms.

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Details of retention periods for different aspects of your Personal Data are available in our Data Retention Policy which is available here.
In some circumstances you can ask us to delete your Personal Data: see Section 9 (Your rights under the GDPR) below for further information.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes.

9. Your rights under the (UK) GDPR

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If the relevant conditions of the (UK) GDPR are met, you have the right to:

  • Request that we provide you with a copy of your Personal Data that we hold, to access those Personal Data and to be informed of, inter alia, (a) the source of your Personal Data (where we have not received the Personal Data directly from you); (b) the purposes, legal basis and methods of processing; (c) the controller's identity; and (d) the entities or categories of entities to whom your Personal Data may be disclosed or transferred;
  • Request that your Personal Data be rectified or deleted. adm will seek to verify the accuracy of the Personal Data before rectifying it. The right to delete your Personal Data can only be exercised in limited circumstances e.g. where it is no longer needed for the purposes for which it was collected; where you have withdrawn your consent (if this was the legal basis). adm is however not required to comply with your request to delete your Personal Data where your Personal Data needs to be processed, for example, for compliance with our legal obligations or for the establishment, exercise or defense of legal claims;
  • Restrict the processing of your Personal Data. This applies where (i) the accuracy of the Personal Data is contested, in which case, we will process it to allow us to verify its accuracy; (ii) where the processing is unlawful, but you do not want it erased; (iii) where it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or (iv) you have exercised the right to object, and verification of overriding grounds is pending;
  • Object to the processing of your Personal Data. This applies to Personal Data which we process based on our legitimate interest, and you believe your fundamental rights and freedoms outweigh our legitimate interests;
  • Request portability of any Personal Data that has been transmitted by you to adm in a machine-readable format or to have it transferred directly to another controller, but in each case, only where: the processing is based on your consent or on the performance of a contract with you; and the processing is carried out by automated means;
  • Obtain a copy of, or reference to, the safeguards under which your Personal Data is transferred outside the European Economic Area and/or the UK. We may redact data transfer agreements to protect commercial terms;
  • Withdraw your consent, and therefore prevent that processing, at any time, where the legal basis of processing is your consent;

If you have questions about your data protection rights, or if you would like to exercise one or more of your rights as a data subject, please contact us through the Website’s ‘Contact us’ function or submit your request by email to global.legal@admgroup.com.

Furthermore, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). You have also the right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time.

Marketing communications

We will obtain your consent to the sending of marketing communications where required to do so under applicable law. You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you withdraw your consent or opt out of receiving these marketing messages, this will not apply to Personal Data provided to us because of a product/service purchase, warranty registration, product/service experience or other transactions.

Cost of a request

In principle, no fee is required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights under the (UK) GDPR). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

Especially if you do not submit your request through the Website’s ‘Contact us’ function (as a logged-in user), we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights under the (UK) GDPR). This is a security measure to ensure that Personal Data 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.

10. Third-party links

This Website may include links to third-party websites and applications. This Privacy Notice only applies to Personal Data processed by adm. When you click on links on this Website, we strongly advise to read the privacy statements on the relevant websites first, before sharing any Personal Data.

11. Contact details

Our legal department is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your rights under the (UK) GDPR, please contact us using the details set out below.

If you have any questions about this Privacy Notice or our privacy practices, please contact us in one the following ways:
Email address: global.legal@admgroup.com
Postal address: EDIFICI IL.LUMINA, Gaspar Fàbregas, 81 3º, 08950 Esplugues de Llobregat, Barcelona/p>

12. Changes to the Privacy Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review. The modified Privacy Notice shall enter into force as of the date on top of this page.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

13. Glossary

Employing Company means any company that you are engaged or employed by, and with which adm is in contract with, for the provision of products and/or services.

Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified.

Addendum for individuals based in Singapore

Please read this addendum if you are based in Singapore. This addendum forms a part of the Privacy Notice and is to be read together with the Privacy Notice. If there is any conflict between the addendum and the Privacy Notice, this addendum shall prevail.

1. DATA SUBJECT RIGHTS

If the relevant conditions of the Personal Data Protection Act 2012 are met, you may have the right to:

  • Request access to the Personal Data we process about you, obtain a copy of such Personal Data, and be informed of how we have used or disclosed your Personal Data in the 12 months prior to your request.
  • Request that your Personal Data be rectified. If your Personal Data is incorrect, you may request that your data be corrected by adm free of charge.
  • Withdraw your consent. Where we have obtained your consent, you have the right to withdraw your consent at any time. However, depending on the nature of the consent that is withdrawn, you may not be able to use the Website, products or services that adm offers. Any withdrawal of your consent will not affect the processing of Personal Data which occurred before you withdrew your consent.
  • Complain to the competent authority. You have the right to file a complaint with the competent data protection authority (https://www.pdpc.gov.sg/).

To exercise the above rights with regard to the processing activities for which we are the controller, please contact us by e-mail or regular mail (see Section 11 for our contact details). Your request should be accompanied by your full contact details and a means of verifying your identity (e.g. a copy of the front of your ID card or driving licence). We may request further information as necessary in order to verify your identity or for security purposes. Where permitted to do so under applicable law, we may charge a reasonable fee for processing your request. We may also reject your requests where permitted to do so by law.