Privacy Policy - Adeva Partners

Registered address: 73 Cornhill, London, EC3V 3QQ

This privacy notice was updated on 11th March 2024 and is effective immediately. It tells you everything you need to know about how Adeva Partners Ltd process, control and protect your personal data and the rights that you have in relation to that data. This privacy statement is regularly updated to reflect any changes in the way we handle your personal data or any changes to applicable laws.

Introduction

Adeva Partners is committed to protecting and respecting your privacy.

This privacy notice provides you with details of how we collect and process the personal data of the following categories of individuals:

Clients*
Suppliers
Business contacts to network, develop leads and share best practice
Visitors to our website and social media pages

*We have a separate privacy notice for individuals who are attending or have attended training programmes we deliver as part of a contract with their employer. https://www.adevapartners.com/privacy-policy-for-training-participants/

All personal data is collected, stored and processed in accordance with the UK General Data Protection Regulation (UK GDPR), the EU GDPR, the Data Protection Act 2018 (DPA 2018) and the Privacy and Electronic Communications Regulations (PECR).

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.

We may update this notice at any time, and we may provide you with additional privacy notices from time to time.

Data Protection Principles

We will comply with data protection law including the 7 principles of GDPR which are:

Personal data shall be processed lawfully, fairly and in a transparent manner.
Personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in any manner incompatible with that purpose or those purposes.
Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
Personal data shall be accurate and where necessary kept up to date.
Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Personal data shall be processed in a way that ensures it is appropriately secure.
Adeva has put in place appropriate technical and organisational measures to prevent unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

Personal Data That We Process

We will collect, store, and use the following categories of personal data about you:

Audio and visual data: photos and video recordings that may have been taken, with your consent, during in-person or online events or meetings
Contact data: name, email address and telephone numbers
Communication data: any other information that you directly provide to us whether through our contact form, over the phone, by email, text, social media messaging, social media posting or any other communication that you send to us
Financial data: (relevant to self-employed suppliers only) bank account and invoicing information required to make payments to you
Marketing and Communications Preference Data: includes your preferences in receiving marketing from us and your communication preferences
Public information: information that is publicly available such as social media, online directories and websites
Technical data: includes internet protocol (IP) address, cookie IDs, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Adeva’s website and video conferencing platforms

Cookies

What is a cookie?

Most sites today make use of cookies – these are small files that a website stores on the user’s computer in order to enhance the functionality of the website.

Cookies used on this website

Cookies used on this site are for the following purposes:

Detect device screen size so we can serve smaller images to smaller screens
Remembering your choice of cookie consent (if you have interacted with the Cookie Consent banner)
Facilitate security functionality of the website
Facilitate the use of Google Analytics for improving user experience. Information is collected in an anonymous form

Strictly Necessary Cookies

Cookie name		Cookie description
cookieconsent_status		This cookie name is associated with the Cookie Declaration banner, and detects if you have dismissed the banner or not.
resolution		This cookie helps to identify the size of your device screen so that an appropriately sized image can be served (for example, smaller images for mobile devices). This cookie is classed as a strictly necessary technical cookie and is always set.
PHPSESSID		This is a general purpose identifier cookie used to maintain user session variables. It is normally a random generated number
JCS_INENTIM JCS_INENREF NCS_INENTIM_wpss_p_ _wpss_h__wpss_r__wpss_v_ _wpss_j_ SJECT* ckon* 44bc5a3a4a0688bd366086b1471aaf91		These are first-party cookies (so only written and read by this website), used by the WP-Spamshield anti-spam plugin for security and technical functionality only. These cookies will delete when the browsing session is ended or when the browser is closed.

Cookie name		Cookie description
_ga _gat _gid		These cookies are associated with Google Universal Analytics and are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they visited.
uvc loc lidc __atuvs __atuvc		These cookies are associated with the AddThis social sharing widget to enable visitors to share content with a range of networking and sharing platforms. It stores an updated page share count.

How We Collect Your Personal Data

We use different methods to collect data from and about you, including through:

Direct interactions and email contact with Adeva’s employees
Interaction with our social media pages
Submission of a form on our website or other sites and applications we use
Searches on public data sources such as websites and social media platforms.
Third Parties: we may receive information about you from third parties:
- Contact data from another individual e.g., in your firm or in your business network
- When you interact with our website or applications (e.g., Zoom, Teams), we may automatically collect Technical Data about your equipment, browsing actions and patterns.

How We Use Your Personal Data

We will only process your personal data if we have a lawful ground for processing such data. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract with you or your employer to provide you with training.
Where we need to comply with a legal obligation
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we have your consent.

Purposes For Which We Process Your Personal Data

Purpose	Type of Data	Lawful Basis for Processing
For Clients of Adeva Interact with you about current and future contracts Process and deliver the services we provide to your firm Manage invoices and payments Keep records for audit/accounting reasons Send you relevant educational and marketing content	Contact data; communication data; technical data; audio and visual data	Performance of a contract with you or your firm
For Suppliers of Adeva Order and receive services/goods from you or your firm Manage invoices and payments Keep records for audit/accounting reasons	Contact data; communication data; technical data; financial data	Performance of a contract with you or your firm
For All Categories
To respond to enquiries or requests for information	Contact data; communication data; technical data; marketing and communications preference data	It is necessary for a contract we have with you or your firm or you have provided explicit consent to us
To use data analytics to improve our website, products/services, marketing, client relationships and experiences	Technical data	Necessary for our legitimate interests
To send you relevant educational and marketing content	Contact data; Marketing and Communications Preference Data	It is necessary for a contract we have with you or your employer; necessary for our legitimate interests; you have provided explicit consent to us
To interact with you online e.g. via social media	Public information	Public information; necessary for our legitimate interests

We may from time to time use your personal data without your knowledge or consent where this is required or permitted by law.

Transfers to Third Parties

We may have to share your personal data with third parties, including third-party service providers, because it is necessary for a contract we have with you or where we have another legitimate interest in doing so.

Third party providers include the following services:

Provide electronic storage services for personal data we collect
Provide accounting services and software to manage invoices and payments
Provide IT and system administration support to Adeva
Please contact gdpr@adevapartners.com to request a list of third parties that may process your data

If applicable, we may share your personal information with a regulator or to otherwise comply with the law.

We require third parties to respect the security of your data and to treat it in accordance with the law. They must act only in accordance with our instructions, and they agree to keep your personal data confidential and secure. We have data protection agreements in place with these parties.

Transfers Outside of the EEA

It is Adeva’s policy to, where possible, use UK or EEA based data storage and processing services. We may occasionally need to transfer your personal information outside the EEA, e.g., if a staff member resides outside of the EEA or your firm is based outside of the EEA. If we do, you can expect a similar degree of protection in respect of your personal information.

Where we transfer your personal data to countries where there is no adequacy decision by the ICO in respect of that country, we will put in place certain measures to ensure that your personal data does receive an adequate level of protection, such as contractual clauses that have been approved by the ICO.

Sensitive Data

The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data.

We do not routinely collect or process sensitive data and criminal convictions data. Occasionally we may receive gender data from your employer: it is our policy to remove this data from the records we hold about you. If we provide additional support to meet an individual’s accessibility requirements, we may also collect, store and use the following “special categories” of more sensitive personal information:

Information about any disabilities or learning needs – this information may be provided by you or your employer so that any reasonable adjustments can be made to accommodate participants with disabilities and to ensure that any learning needs are supported. This information is voluntary, but Adeva will not be able to provide you with learning support/reasonable adjustments if you do not provide this information.

Data Security

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.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Rights of Access, Correction, Erasure, and Restriction

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal information changes.

Under certain circumstances, by law you have the right to:

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.
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.
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 exercised your right to object to processing (see below).
Object to processing of your personal information where we are 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.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

In all cases you must provide us with evidence of your identity before we will respond to a subject access request. We would prefer if your request sent to us in an email (see contact information below). We may contact you to confirm the details of your request it in order ensure that we provide the detail that you require.

You will not have to pay a fee to access your personal data or to exercise any of the other rights under data protection laws. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Right to Withdraw Consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email us (see contact information below). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Contact Us

Please contact us at gdpr@adevapartners.com if you have any questions about how we protect your personal data or if you wish to exercise your rights in relation to your personal data.

If you wish to make a complaint about our use of your data you have the right to contact the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Telephone: +44 (0)303 123 1113 or https://ico.org.uk).