Privacy Policy

This privacy policy (“Privacy Policy”) sets out the ways in which Adelye Ltd (“we, us, our”) collect, use and share your personal data (“your information”) in connection with our business. It also explains what rights you have to access or change your personal data.

We are the data controller which means we decide how your information is used and protected. We take your privacy and our responsibility to protect your information seriously.

 

WHO WE ARE

Adelye is a company registered in England under company number 7346747.

You can contact us at:
FAO: Legal Department (GDPR)
Adelye
54 Poland Street, London, W1F 7NJ, United Kingdom

Email: hello@adelye.com

 

WHAT INFORMATION WE COLLECT ABOUT YOU

The information you provide to us might include: your name, first name, postal address, email address, phone number and date of birth, etc. Your information includes anything which identifies you so if you write an email to us under a “Contact” section on our website www.adelye.com or www.roadandload.com (the “Websites”) we will receive personal data information mentioned hereto.

We will not ask you to provide us with any sensitive information such as details about your racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, health, sexual life or orientation.

We collect your information when you:

  • interact or correspond with us by post, phone, SMS, email or via our Websites;

  • attend events we hold or interact with us in person;

  • enter into a contract with us; and

  • apply to join the Adelye colony

Information about how you use our Websites:

We will also collect certain information about how you use our Websites and the devices that you use to access them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers, etc.), browser type, referral source, length of visit to the Websites, number of page views, the search queries you make on the Websites and similar information. This information is collected by Google Analytics on our behalf using cookies.

Our Websites may include links to third party websites and plugins. For instance, our Websites links to various social media platforms currently:

  • Linkedin.com operated by LinkedIn Corp. – 2029 Stierlin Court, Mountain View, CA 94043, USA;

  • Instagram Inc. (Facebook Inc.) – 1601 S. California Ave, Palo Alto, CA 94304, USA;

  • Twitter.com operated by Twitter Inc. – 795 Folsom St., Suite 600, San Francisco CA 94107, USA; and

  • Youtube.com operated by Google Inc. – 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

By clicking on those links or enabling these connections you may allow third parties to collect or share your information. We do not control these websites and therefore decline any responsibility for their content and in particular we are not responsible for their privacy policies. Please ensure that you read the privacy policies on any such external websites.

 

HOW WE USE YOUR INFORMATION

We use your information lawfully. We do not sell your information to third parties. However, we may share your information as set out in the section ‘When we share your information’. The details of how we use your information and the legal bases for our use are set out below:

When we have your consent to contact you, we may use your information to:

  • keep in contact with you and provide you with marketing communications about our news and events;

  • tell you about new Website features or services; and

  • share your information with affiliates so that they can contact you and offer you services that may be of interest to you (for more information, see section ‘When we share your information’).

We will sometimes use your information on the basis of our ‘legitimate business interests’ (our “legitimate interests”). This means, for example, our legitimate interests in conducting and managing our business and our relationship with you.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests do not automatically override yours and we will not use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing you have rights and choices which include the right to object or rectify (please see the section headed ‘Your rights and choices’).

We may use your information for the purposes listed below on the basis of our legitimate interests:

  • to respond to an email that you have sent to us directly or via the “Contact” section

  • to process any application to join the Adelye colony you submit to us;

  • to work with our third-party recruitment agency to process any job applications you submit to us;

  • to carry out aggregated and anonymized research about general engagement with our Websites in providing the right kind of products and services to our Website users;

  • to operate a safe and lawful business or where we have a legal obligation;

  • to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees;

  • to analyse your use of our Websites and your responses to our communications;

  • to personalize, enhance, modify or otherwise improve the services and/or communications that we provide to you;

  • to detect and prevent fraud and unauthorized access or illegal activity; and

  • to improve security and optimization of our network sites and services including trouble shooting, testing and software development and support.

 

WHO CAN SEE YOUR INFORMATION

Your information may be processed by our staff, selected freelancers or by the staff of third parties we work with to deliver our business. Processing can mean any activity that involves the use of information about someone that can identify them. All uses, for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying are types of data processing. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organizational safeguards in place in our company and with third party processors to protect your information. Third party processors of your information include:

  • our Websites hosts and operators, IT support providers, database operators, site analytics providers and software developers;

  • our marketing or publicity services providers;

  • freelancers selected to work on your project

  • our financial services and payment service provider; and

  • our auditors, technical consultants and legal advisors.

 

WHEN WE SHARE YOUR INFORMATION

Where we share your information to a third party outside of delivering our business, you will be asked for your consent, and if you choose to give your permission any interaction you have with a third party is governed by their privacy terms. The third party becomes a joint data controller of your information with us. This means that the third party can make decisions about how to use your information. Before we share your information we require third parties to enter into a data sharing agreement which stipulates that they must maintain appropriate security to protect your information from unauthorised access, processing or use.

We will share your information with the following third parties:

  • selected marketing partners;

  • any prospective seller or buyer of businesses or assets, only in the event that we decide to acquire, transfer or sell any business or assets; and

  • any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so.


HOW WE LOOK AFTER YOUR INFORMATION

We look for opportunities to minimise the amount of personal information we hold about you. Where appropriate we anonymise and pseudonymise your information. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:

  • ensuring the physical security of our offices or other sites;

  • ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;

  • maintaining a data protection policy for, and delivering data protection training to, our employees; and

  • limiting access to your personal information to those in our company who need to use it in the course of their work.


HOW LONG WE KEEP YOUR INFORMATION

We will retain your information for as long as it is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our legitimate interests, such as for the purposes of responding to correspondence, exercising our legal rights, etc.

We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example,

  • we archive our email and paper correspondence regularly and destroy unnecessary information;

  • we operate a best practice email retention policy requiring password-protected folders and departmental shared drives to provide restricted access to information;

  • deleted emails are auto-deleted periodically;

  • we conduct regular access reviews to keep access profiles and policies up to date;

  • we conduct periodic review and purge cycles of documents in accordance with our document retention policy; and

  • we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently.

 

INTERNATIONAL TRANSFERS OF YOUR INFORMATION

Our company is located in the United Kingdom but some of our freelancers and third party suppliers are located elsewhere in the European Union and the World. Whenever we transfer your personal information out of the European Economic Area (“EEA”) we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Policy by using all appropriate cross-border transfer safeguards.

Please contact us if you would like additional information on the specific means used by us when transferring your personal data outside of the EEA.


YOUR RIGHTS AND CHOICES

You have different rights, and in particular a right of access, rectification, erasure, restriction and objection to the processing of your information as well as the right to portability.

Your right to object

You have the right to object to our using your information for direct marketing and on the basis of our legitimate interests (refer to section ‘How we use your information’ above to see when we are relying on our legitimate interests). If you want to do this you can contact us using the details in the section ‘Contact’.

Your right to withdraw consent

The right to withdraw your consent for our use of your information in reliance of your consent (refer to section ‘How we use your information’ to see when we are relying on your consent), which you can do by contacting us using any of the details in the section ‘Contact.

Your other rights and choices

You also have other choices and rights in respect of the information that we hold about you, including:

  • the right to request access to the information that we hold about you to check that we are acting lawfully;

  • the right to receive a copy of any information we hold about you in a structured, commonly used, machine readable format or in another format of your choice;

  • the right to request that we transfer your information to another service provider in a structured, commonly used, machine-readable format;

  • the right to ask us to correct information we hold about you if it is inaccurate or incomplete;

  • the right to ask us, in certain circumstances, to delete information we hold about you; and

  • the right to ask us, in certain circumstances, to restrict processing of your information.

You may exercise your rights and choices by contacting us using the details above in the ‘Contact’ section.

Your right to complain

Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may have.

You also have the right to lodge a complaint about us and our use of your information to the Information Commissioner’s Office in the United Kingdom (https://ico.org.uk/).


CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time to stay abreast of technological developments, industry practices and regulatory requirements, or for any other reason. Any changes will be directly updated on our Websites.

This Privacy Policy was updated on 18 April 2023.