1.THE DATA WE COLLECT ABOUT YOU:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

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

1. Identity data – first and last name, user name
2. Contact data – address, email address and phone numbers
3. Technical data – Last login, internet protocol addresses, location
4. Usage data – Information on how you use the website
5. Marketing and Communications Data includes your preferences in receiving marketing from us.

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.
 

IF YOU FAIL TO PROVIDE PERSONAL DATA:

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
 

2. HOW IS YOUR PERSONAL DATA COLLECTED: 

We use different methods to collect data from and about you including through:
Direct interactions:  You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Download products, Whitepapers, On Demand webcasts and register for a webcast
• Request a quote or more information or give feedback
• Create an account on the site
• Subscribe to services or publications 

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies.
Third parties or publicly available sources: We may receive personal data about you from various third parties with whom we have partnerships.
Technical Data from analytics providers based outside the EU.
 

3. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the agreement we are about to enter into or have entered into with you.
• Where we have your consent.
• 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.

4.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity	Type of Data	Lawful basis for processing
To register as a new customer	(a ) Identity (b ) Contact	Consent – Consent requested at the time of registering.  Granular opt-in provided
Process and deliver your request for information e.g. Download products, whitepapers, On Demand webcasts, register for a webcast	(a ) identity (b ) Contact	Legitimate interest – To provide the information requested by the user
To administer and protect our business and our site (inc troubleshooting, data analysis, testing, maintenance, reporting and hosting of data	(a ) Identity (b ) Contact (c ) Technical	Necessary for the legitimate interest of running our business, provision of administration and IT services and network security.
To deliver relevant content and advertisements to users and measure and understand the effectiveness of our marketing	(a ) Identity (b ) Contact (c ) Technical (d ) Usage (e ) Marketing and communications	Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(c ) Technical (d ) Usage	Necessary for our legitimate interests to define types of customers for our products and services, to keep our site 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	(a ) Identity (b ) Contact (c ) Technical (d ) Usage (e ) Marketing and communications	Necessary for our legitimate interests to develop our products/services and grow our business.

5. MARKETING

 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

We may use your Identity and Contact Data to deliver our newsletter, product updates and details on new products to you if you have provided your consent.

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you registered on the ADLINK website and you consented to receiving that marketing.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting our Data Compliance Officer (See Section 12 below) at any time.
 

6. 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 our Data Compliance Officer.

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.   Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

7. DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties and other organisations that processes data on our behalf.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS 

ADLINK is an international company, with affiliates and divisions based outside the European Economic Area (EEA).  As part of our business processes, we may process your personal data by undertaking a transfer of data outside the EEA.  We may also use service providers who are outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield https://www.privacyshield.gov/welcome, which requires them to provide similar protection to personal data shared between the Europe and the US.
   

9. 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.

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

10. DATA RETENTION

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.

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 as well as applicable legal requirements.

11. YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the following rights in relation to your personal information:

• Right of access – you have the right to request a copy of the information that we hold about you. 
• Right of rectification – you have a right to correct information that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the information we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the information we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to legal protections in respect of automated processing or profiling.
• Right to judicial review: in the event that the Company refuses your request for access. We will provide you with a reason why and you have the right to complain as outlined below.

If you wish to exercise any of the rights set out above, please contact our Data Compliance Officer for further details.
 

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 individuals’ rights under GDPR.

If you would like to exercise any of those rights, please:

• Email, call or write to us. All requests should be addressed to our Data Compliance Officer (details below)
• Let us have enough information to identify you
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• Let us know the information to which your request relates.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
 

12. CONTROLLER AND CONTACT 

The above Privacy Policy is relevant for ADLINK Technology Inc., ADLINK Technology GmbH and ADLINK Technology Ltd. These entities are the controller and responsible for your personal data (collectively referred to as “ADLINK”, “we”, “us” or “our” in this privacy notice.  Our full details are:

Full name of legal entity:           ADLINK Technology Inc.
Data Compliance Officer:          Jeff Chou
Email address:                               jeff.chou@adlinktech.com
Postal Address:                             9F, No.166 Jian Yi Road, Zhonghe District, New Taipei City 235, Taiwan

Full name of legal entity:          ADLINK Technology GmbH
Data Compliance Officer:         Roy Wan
Email address:                              roy.wan@adlinktech.com
Postal Address:                            Hans-Thoma-Straße 11, D-68163 Mannheim, Germany

Full name of legal entity:         ADLINK Technology Ltd
Data Compliance Officer:        Lawrence Ross
Email address:                             lawrence.ross@adlinktech.com
Postal Address:                           The Edge, 5^th Avenue, Team Valley Trading Estate, Gateshead, NE11 0XA United Kingdom
 
Any change in the Data Compliance Officer or other amendments to the above contact details shall be notified by way of updated revisions to this Privacy Policy. We hope that we can resolve any query or concern you raise about our use of your information so please contact us in the first instance.

In the event that you wish to make a complaint about how your personal information is being processed by the Company, or how any query or concern has been handled, you have the right to lodge a complaint directly with the Information Commissioner’s Office (‘ICO’), the supervisory authority in the United Kingdom (available at www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO.