This website is operated by ADDAPTIVE GROUP. The privacy of our users is extremely important to us and therefore we encourage all users to read this policy very carefully because it contains important information regarding:
who we are;
how and why we collect, store, use and share personal information;
your rights in relation to your personal information; and
how to contact us and supervisory authorities in the event that you have a complaint.
Who we are
ADDAPTIVE GROUP ('we' or 'us') collect, use and are responsible for storing certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation which apply across the European Union (including the United Kingdom) and we are responsible as a 'controller' of that personal information for the purposes of those laws.
The personal information we collect and use
a. Personal information you provide to us
We collect the following personal information that you provide to us:
Some examples of when we collect this information include:
When buying premium content
b. Personal information from other source
We may receive information about you from other sources. This information includes:
We will add this information to the information we hold about you for the following purposes:
The data is processed anonymously
c. Personal information you provide about third parties
If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:
shall consent on their behalf to the processing of their personal data;
shall receive any data protection notices on their behalf; and
shall consent on their behalf to the transfer of their personal data abroad.
d. Monitoring and recording communications
We may monitor communications such as emails and telephone calls for the following purposes:
In App chat
e. Cookies and similar technologies
A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects ('flash cookies') and single-pixel gifs. Such technologies can be used to track users' actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website.
In addition it should be noted that in some cases our cookies or similar technologies may be owned and controlled by third parties who will also collect personal information about you.
Pages and Content viewed
This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
How we use your personal information
We collect information about our users for the following purposes:
For User experience improvements
Viewing data analysis
Who your information may be shared with
We may share your information with:
Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
Credit reference agents in accordance with our credit checking policy below;
We will not share you personal information with any other 3rd parties.
We may do a credit check on you so that we can make credit decisions about you and members of your household, and to prevent and detect fraud and money laundering. Any such search will be recorded on the files of the credit reference agency.
We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.
Other credit businesses may use your information to:
make credit decisions about you and the people with whom you are financially associated;
trace debtors; and
prevent and detect fraud and money laundering.
If you provide false or inaccurate information to us and we suspect fraud, we will record this. If you want to see your credit file, please contact the credit reference agency which we use EQUIFAX.
Required personal information
No personal information has to be provided by you to us at any time.
How long your personal information will be kept
We will hold your personal information for the following periods:
For age verification
In App Subscription
These periods are no longer than necessary in each case.
Reasons we can collect and use your personal information
We rely on the following as the lawful basis on which we collect and use your personal information:
(a). The legitimate interests relied upon are as follows:
To verify age of user to control the distribution of age restricted material
Keeping your information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:
Account Access is controlled and encrypted
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.
Transfers of your information out of the EEA
We will not transfer your personal information outside of the EEA at any time.
Children and the validity of consent
Where we obtain consent from any user we will take reasonable steps to ascertain whether the user is over 13 years of age and whether the child is sufficiently informed to give valid consent. If the user is not, parental consent will be required to provide consent for the processing of any personal information.
What rights do you have?
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
fair processing of information and transparency over how we use your use personal information
access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances
claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
If you would like to exercise any of these rights please:
email, call or write to us
let us have enough information to identify you
let us have proof of your identity (a copy of your driving license, passport or a recent credit card/utility bill)
let us know the information to which your request relates
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Website GDPR page
If you have any questions about this policy or the information we hold about you, please contact us by: