Last Updated: 01/06/2021

Adaire is committed to upholding the privacy rights of individuals. Adaire provides this Privacy Policy to let you know our policies and procedures regarding the collection, use and disclosure of information through www.adaire.com.na (the “Site”), and any other websites, features, applications, widgets or online services that are owned or controlled by Adaire and that post a link to or incorporate the terms of this Privacy Policy (together with the Site, the “Site Services”), as well as any information Adaire collects offline in connection with the Site Services and through other means such as our events, sales and marketing activities. This Privacy Policy also explains the collection, use, purpose, and sharing of personally identifiable information related to Adaire’s employees and Adaire’s providing of services to our customers.

Adaire does not require you to register or provide PII to visit our Site. By accessing our Site or using our Site Services, you agree to this Privacy Policy in addition to any other agreements we might have with you.

Definitions
“ Adaire” means the company. We may also refer to Adaire as “we”, “us”, or “our”.

“Adaire Client” means any customer that has entered into an agreement with Adaire to use Adaire ’s services.

“ Adaire Engineer” means any authorized member of the Adaire Talent Network who has agreed to the Talent Network Terms & Conditions.

“PII” or “Personally Identifiable Information” means any information which may identify an individual, directly or indirectly. Examples of PII include, but are not limited to, first and last name, home address, billing address or other physical address, email address, telephone number, etc. PII does not include information which is anonymized or aggregated, and other information which is excluded from the scope of applicable privacy laws.

“Visitor” refers to anyone accessing the Adaire site, www.adaire.com.na.

Information Collection

A. Information Collected Automatically

Like other companies with online services, we receive technical information when you use our Site or access certain Site Services. We use these technologies to analyze how people use the Site Services and to improve how our Site and Site Services function.

We and our third party service providers, including analytics and third party content providers, may automatically collect the following information from you whenever you access or interact with the Site or Site Services: pages visited, links clicked, text entered into contact forms or chat widgets, and mouse movements. We may also collect the referring URL, browser, operating system, and Internet Protocol (“IP”) address you used to access the Site Services. We (and/or our service providers) may use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We collect this information to improve the services we offer you, and to improve marketing, analytics, and the functionality of our Site Services.

B. Information You Voluntarily Provide to Adaire

Site Visitors may choose to interact with the Site in a way that results in your providing PII to Adaire, such as giving us your name, email address, phone number, and country location when signing up to learn more about Adaire’s Client services or when signing up to apply to be an Adaire Engineer in the Adaire Talent Network. If you make use of our Site to register for certain services, download e-books, attend virtual events or webinars, complete online registration forms, apply for roles via our Site, or to create or update any of your marketing preferences, you will be asked to provide personal information. If you choose to provide us with any PII, we will use the information provided to respond to your request.

If you provide us with your consent to be contacted for marketing purposes, we may send you information about our products and services, including marketing communications, as follows:

  • To market events, promotions, competitions, webinars, reports, our services, news or relevant industry updates.
  • Depending on which jurisdiction you are in, we may be required to give you an option to “opt-in” and we will always provide you with an option to “opt-out” with each marketing communication.

While Visitors do not have a statutory obligation to provide us with any information, Adaire Engineers may have a contractual obligation (pursuant to the Talent Network Terms & Conditions) to do so, and if we do not receive certain information from you, then we will not be able to provide certain Site Services to you. If you have any questions regarding whether the provision of information is mandatory and the consequences for withholding such information, please contact our Privacy Officer using the contact information below.

General Information on Our Use of PII

Use of or access to our Site does not require you to provide any PII to us. Adaire does not buy or sell PII for its business practices or for commercial purposes.

Adaire stores, maintains, processes, and/or handles PII data of Adaire employees as necessary to perform its business functions for our employees.

We also may receive PII from Adaire Clients to perform services for them. Any PII used for such purposes will be limited to access by only those who require it given their job function at Adaire, and except as otherwise provided herein, we only share the PII back with our respective Clients. Adaire does not retain, use or disclose any personal information collected on behalf of our Clients for any purpose (including any commercial purpose) other than the specific purpose of performing the services as specified in the applicable Master Services Agreement with the Client.

Adaire may provide PII of our users to only those of its personnel and third-party vendors that (1) need to know such information in order to process it on Adaire’s behalf or to provide services as described above, and (2) have agreed in writing not to disclose it to any other parties without Adaire’s consent. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Site and/or Site Services, you consent to the transfer of information to such individuals and organizations in order to accomplish these purposes.

In some instances, we may be required by law to disclose information you submit or email to us electronically by law, court order, law enforcement request or other purposes to protect our sites or other sites due to security threats. We may, as necessary, disclose this information or any other information that may identify you to state and local authorities or law enforcement as required under law or by court order.

Use of Third-Party Resources, Applications and Websites

Adaire actively engages third-party resources, applications, and websites. These services provided by third-parties are established to enhance user experience, provide ease of navigation through Adaire’s sites, and to promote access to information. Adaire does not buy or sell PII for its business practices or for commercial purposes.

Please note that Adaire does not control, moderate, or endorse any comments or opinions provided by visitors on third-party websites. The use and creation of official Adaire accounts may cause PII to become available or accessible to Adaire. Such information may become available to Adaire when a user provides, submits, communicates, links, posts, or associates information with designated Adaire accounts on social media (e.g., by using “hashtags”, “liking”, “friending”, “tweeting”, commenting on any content or media on our designated accounts). At times, Adaire, through its personnel, employees, officers, directors, agents and assignees, may respond publicly to content or media made available though “share,” “retweet,” “friend,” “follow,” or similar activities, or respond publicly on content made on designated and official Adaire accounts. Adaire may disseminate any of such information or PII to law enforcement officials, as required by law or court order.

From time to time, Adaire may engage in joint marketing events with select business partners. If you register for a joint webinar or specifically express an interest in a jointly-offered product, promotion or service, we may share relevant PII with those partner(s). Where you have given your consent to do so, these business partners may send you marketing communications about their own products and services.

In addition to the automatic and voluntary provided information collected by Adaire, third-parties may host embedded content, applications on the webpage, and/or cookies that collect information from your machine while you are on our website. These services provide Adaire with website analytics, enhance the user experience, provide ease of navigation through Adaire’s sites, send tailored marketing communications or ads, and promote your access to information.

Please be aware that Adaire does not control our business partners’ use of PII and this Privacy Policy does not apply to third party websites or services. Such entities are responsible for managing their own use of the PII collected in these circumstances. You may wish to review their privacy policies for details about how each third party collects, uses, and shares information. You can control the use of cookies at the individual browser level.

In relation to third-party advertising on our website or through any advertising entities, you may opt-out of being served personalized advertisements by clicking on these two links (US and EU).

Other Onward Transfers

Adaire may transfer data to third-party vendors acting as our agents, due to an acquisition of business assets by another entity, in the ordinary course of business due to expansions or fund-raising, or as otherwise prescribed by this policy. In the course of any change of ownership, Adaire shall notify any impacted parties in writing of any transfer of PII.

All transfers of PII will be: (1) limited for specific purposes; (2) based on a proper determination that the recipient shall: (i) adhere to Privacy Shield principles; (ii) notify Adaire if they determine at any subsequent time they will not be able to adhere to Privacy Shield principles; and (iii) stop and remediate any unauthorized processing; and (3) based on contractually established privacy terms with the recipient of such information that can be either: (i) shared with you; or (ii) reasonably summarized for you. Any transfer of Adaire employee PII will be consistent with our internal privacy practices and as disclosed in our employee handbook.

Adaire is responsible and liable for the processing of PII it receives and transfers to a third party acting on Adaire’s behalf. Adaire complies with the Privacy Shield Principles for all onward transfers of PII from the EU including liability provisions of such onward transfer.

Your Choice & Rights

You can use our Site without providing any personal identifiable information. However, if you choose not to provide any PII, you may not be able to use certain Site Services.

Individuals also have the opportunity to choose whether their PII is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. In accordance with applicable law, you may have the right to:

  • Access Personal Information. You may request confirmation of whether we are processing your personal information and obtain a copy of the categories of information we may have collected on your behalf.
  • Request Correction. You may request correction of your personal information where it is inaccurate, incomplete or outdated. For Adaire Engineers, you may update your personal information within your Adaire accounts by logging in and updating your profile.
  • Request Deletion (“Opt Out”) or Withdraw Consent. You may request to remove your PII from our records. Note that if your personal information is deleted, you may no longer access or be able to use certain Site Services, and any account you have with us may become deactivated.
  • Direct Marketing Opt Out. You have the right to object if we are processing your PII for direct marketing purposes. You can unsubscribe from Adaire’s own marketing emails at any time by clicking the “unsubscribe” link they contain or by accessing the Email Preferences Center.

If you wish to access, correct, amend, or delete PII you have provided directly to us, please contact our Privacy Officer at privacy@adaire.com.na. For deletion/opt out requests, please include the subject line “OPT OUT”. We will respond to requests within forty-five (45) days. If we require more time, we will inform you of the reason and extension period for a response in writing.

If you wish to access, correct, amend, or delete PII you have provided to our Clients, please contact those Adaire Clients directly. Alternatively, you may contact our Privacy Officer at privacy@adaire.com.na and we will pass your request along to the applicable Adaire Client.

When any Client requests Adaire to remove any Client data that Adaire may have on its systems, Adaire will respond as soon as practicably as possible, and no more than forty-five (45) days after such receipt from our Client. If you wish to no longer have your PII used or disclosed by our Clients, or by us in connection with our work for our Clients, please contact the Client that you interact with directly. Alternatively, you may contact our Privacy Officer at privacy@adaire.com.na and we will pass your request along to our Clients.

Security

Adaire uses industry-standard technologies, administrative, technical, and physical measures to protect the security, confidentiality and integrity of any information or data collected by us.

However, no website, service, mobile application, database or system is completely secure or “hacker proof.” You are responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

Privacy Shield Statement

Adaire complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of all personal information transferred from the European Union to the United States. Adaire has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, and is subject to the investigatory and enforcement powers of the Federal Trade Commission. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the list of companies that have self-certified to the Privacy Shield, please visit https://www.privacyshield.gov/ and https://www.privacyshield.gov/list.

Links To External Sites

Our Site and Site Services may contain links to websites created and maintained by other public or private organizations. We provide these links as a service to our users. Please note that when you follow a link to an external site, you will be leaving Adaire’s Site Services and are subject to the privacy and security policies of the site to which you are visiting. Adaire is not responsible for the security practices or the content of such external sites.

Children’s Privacy

Adaire is committed to the protection of children’s online privacy. Because of the nature of our business, our services are not designed to appeal to, and our Site and Site Services are not directed to children under the age of 13. Adaire does not intend to solicit or collect information and we do not knowingly collect personal information from children under the age of 13.
The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing personal information about a child under the age of 13. If an Adaire Site or Site Services intends to collect information about children under 13 years old, instructions and information pertaining to COPPA will be provided by the specific Site Service that collects information about the child. The Site Service will specify exactly what such information will be used for, who will see it, and how long it may be kept.

Contact Us

We welcome feedback from all our users and if you have any question regarding our privacy policy or the use of your information please contact us. You can email our privacy officer at privacy@adaire.com.na or you can send mail to us at:

Adaire
Attn: Privacy Officer
47 Church Street
Windhoek, Namibia

Enforcement and Arbitration

Adaire is committed to responding to requests in a timely manner as provided above. However, if you have not received a timely or satisfactory response from Adaire to your question, complaint, or request, please contact our privacy officer.
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You may invoke binding arbitration if your complaint remains unremedied following our dispute resolution process described above. More information is available on the Privacy Shield website: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

Changes To Our Privacy Policy

Adaire may amend this Privacy Policy at any time by posting a new version to our Site. It is your responsibility to review this Privacy Policy periodically as your continued use of the Site and the Site Services represents your agreement with the then-current Privacy Policy.