Privacy Policy

Your privacy is important to us. It's our policy to respect your privacy regarding any data we may collect from you across this website, and throughout your engagement with us.

About Your Personal Information

Absolute Digital Technology Management LLC (“ADT”) is committed to processing personal information (“PI”), including sensitive personal information (“SPI”) in line with applicable privacy and data protection laws(please note that not all privacy laws define SPI such as Hong Kong, Canada and Singapore). Our offices are located in countries with laws governing the processing of PI. “ADT”, “we”, “us” or “our” means ADT, and each of the director indirect subsidiaries or affiliates of ADT (the “ADT Group”).ADT’s entity you contract with are the controllers of your PI. However, if you are unsure as to the nature of the relationship, ADT will be the controller. References to “you” or “your” refers to individuals whose PI is processed by ADT Group, including clients with direct or indirect relationships; employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

the provision of services to potential and actual clients;
transactions to which we are party (including those which we effect on behalf of clients); or
services provided to us by a third-party vendor.

It also sets outs individuals’ rights in relation to the processing of their PI. There may be additional terms, conditions and commitments that also govern how we collect, process, use, transfer and disclose your PI, which should be read in conjunction with this Privacy Notice.

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Personal Information We Collect About You

PI we collect about you is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data or tax and financial information. Then ature of the information that we collect will depend on the our relationship with you. We categorize PI we process as follows (the PI listed for each category are non-exhaustive examples:

Identification data: Name, title, gender, marital status, date of birth, passport number/national identification number, signature.
Contact data: Address, telephone number, email address.
Electronic Monitoring data: To the extent permitted by law, we may record and monitor your electronic communications and interactions with us.
Financial data: Bank account information, tax, investment, income, net worth, revenue and similar information.
Marketing and Communications data: Marketing and communication preferences; tracking data relating to whether you have read marketing communications from us.
Professional Information data: Employer or company, position/job title, work address, telephone number, email address.
Profile data: Username and password for our online services that you have access to, investments made by you and marketing services.
Services data: Payment details to and from you; details of services you have provided to us or we have provided to you.
ADT security data: Records of visits to our premises and CCTV recordings.
Technical data: Your use of and interaction with our online services; your IP address; browser/operating system type and version;
SPI: In limited circumstances, and where allowed or even required by law, to collect information about criminal convictions and offences; tax, income and financial information; dietary requirements if we are arranging catering; disability so that we can make reasonable accommodations for you in our buildings; sexual orientation if you provide details of your spouse or partner; political affiliations for us to determine whether you are a politically exposed person.

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How We Collect Personal Information About You

We collect PI in relation to you in a number of ways, including:

When you provide it to us in connection with a ADT Group product or service, such as a completed investment application form.
If you are Representative of an organization or entity that is a client or vendor of ADT Group and that organization or entity provides us with your PI.
Throughout the course of our relationship with you, including where you change your details, provide additional PI, or where the services we are providing to you changes.
From public sources where you have manifestly chosen to make your PI public, including via public profiles on social media or public records.
From third parties such as credit reference or government agencies or background check suppliers.
From visits to our websites or through logging into any of our online services
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We may also create or derive PI such as creating records of your interactions with us, subject to applicable law. Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and service.

Purpose and Legal Basisfor Processing Your PI

The below table sets out the purposes and basis for which weprocess PI.

Category of PI

Basis of Processing

To consider opening anaccount, or entering into a relationship at your request, including performinganti-money laundering, anti-terrorism, sanction screening, fraud and other duediligence checks

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring we do not accept the proceeds of criminalactivities or assist in fraudulent or any unlawful activities, such asterrorism

Identification data
Contact data
Financial data
Services data
PI

To deliver the services you have requested, including liaising with third parties and to provide access to our technology solutions services

Identification data
Contact data
Financial data
Profile data
Services data
Technical data
Marketing and Communications data
Professional Information data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring that you are provided with the best client services and visitor services we can offer, and securing a prompt payment of any fees, costs and debts in respect of our services

Identification data
Contact data
Financial data
Professional Information data
Services data

Performance of a contract
Legitimate interests: ensuring we can manage payments, fees and charges and to collect and recover money owed to u

Processing Purpose

To manage payments, feesand charges and to collect and recover money owed to us

To manage our relationship with you which will include notifying you about changes to our terms of business or this privacy notice

Identification data
Contact data
Profile data
Marketing and Communications data
Professional Information data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring we can notify you about changes to our terms of business or this notice

Legal or regulatory obligation
Public interest

Identification data
Contact data
Financial data
Services data
Professional Information data

Legal or regulatory obligation
Public interest

To detect or prevent fraud and/or other criminal activity and to protect our employees and assets

Identification data ADT Building and Assets Security data
Contact data
Electronic Monitoring data
Financial data
Professional Information data
Profile data
Services data
Technical data
SPI

Legal or regulatory obligation
Public interest
Legitimate interests: protecting ADT and client assets; detecting, and protecting against breaches of our policies and applicable laws; protecting ADT employees

To manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities

Identification data
Contact data
Profile data
Technical data Marketing and Communications data
Professional Information data
SPI

Legal or regulatory obligation
Legitimate interests: ensuring the efficient and secure running of our business, including through office and facilities administration, maintaining information technology services, network and data security and fraud prevention

To invite you to take part in market insight or other events, or client seminars or similar events, and to manage your participation in them

Identification data
Contact data
Profile data
Technical data
Marketing and Communications data
Professional Information data

Legitimate interests: ensuring our client records are up-to-date; promoting our client services receiving feedback; improving our services; identifying ways to expand our business

To send you marketing (including by paper and electronic channels) communications and service updates

Identification data Contact data
Profile data
Technical data
Marketing and Communications data
Professional Information data

Legitimate interests: reviewing how clients use, and what they think of, our services; identifying ways to improve and expand our business

Inrelation to vendor services:

Type of data

Legal basis for processing

To engage you or the organization or entity you work for as a new supplier, including performing anti-money laundering, anti-terrorism, sanctions, fraud and other background checks

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring we do not accept the proceeds of criminal activities or assist in fraudulent or any unlawful activities, such as terrorism
Public interest

Identification data
Contact data
Financial data
Services data
Professional Information data
SPI

To manage payments, fees and charges and to collect and recover money owed to us

Identification data
Contact data
Financial data
Professional Information data
Services data

Performance of a contract Legitimate interests: ensuring we can manage payments, fees and charges and to collect and recover money owed to us

Where we provide you access to our systems we need to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, and data hosting

Identification data
Contact data
Profile data
Technical data

Purpose and/or activity

Legal or regulatory obligation
Legitimate interests: ensuring the efficient and secure running of our business, including maintaining information technology services, network and data security

To Whom We Disclose Your PI

In connection with one or more of the purposes outlined in the section ‘Purpose and Legal Basis for Processing Your PI’ above, we may disclose PI in any jurisdiction to:

Other members of the ADT Group.
Professional advisors, third parties, agents or independent contractors that provide services to any member of the ADT Group (such as IT systems providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants).
Goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); intermediaries, brokers, and other individuals and entities that partner with us.
Competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where ADT is required or allowed to do so under applicable law or regulation.
A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of ADT’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
Credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity; or
Any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument.

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Transfers of Pl

To provide global services and in the course of running our business, we may transfer PI to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, including ADT processing centers in Taiwan, Australia, United States, Hong Kong and Singapore. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of PI wherever it is processed.

We require by contract that our third party service providers processing PI on our behalf to comply withADT’s criteria for PI processing. If we transfer PI out of the EEA, we ensure a similar level of protection for your PI by ensuring the country to which the PI is transferred is considered by the EU Commission to provide an adequate level of protection, putting in place contractual clauses the EU Commission consider to provide the same level of protection. For third party service providers in the US, we may rely on the EU-US PrivacyShield certification.

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Marketing And Opt-Out

We will not process your PI for marketing purposes if you have informed us you do not wish to receive marketing materials. You can request that we stop processing your PI for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making are quest to your usual ADT contact or by using the contact details set out in the “Contact Us” section of this notice.

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Sale of Pl

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

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Pl Retention

We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.

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PI Security

We use a range of physical, electronic and managerial measures to ensure a level of security appropriate to the risk of PI processing. These measures include:

Education and training of relevant staff to ensure they are aware of our privacy obligations when processing PI as well as training around social engineering, phishing, spear phishing, and password risks;

The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
The ability to restore the availability and access to PI in a timely manner in the event of a physical or technical incident;
Administrative and technical controls to restrict access to PI;
Technological security measures, including fire walls, encryption (industry standard SSL encryption with 128-bit key lengths), and anti-virus software;
Physical security measures, such building access controls;
External technical assessments, security audits and vendor due diligence;
Perimeter security;
Segregation of networks;
Application security;
Endpoint security;
Real-time monitoring of data leakage controls;
Layered and comprehensive cybersecurity defenses; and
Security incident reporting and management.
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The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavor to protect personal information but cannot guarantee the security of data transmitted to us or by us.

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Your Rights

In certain circumstances you may have the following rights in relation to the processing of your PI:

Access to request a copy of the PI we process in relation to you and to be informed about how we use and share your PI.
Object to the processing of your PI if (i) we are processing your PI on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your PI for direct marketing purposes.
Request that we update the PI we process in relation to you, or to correct PI that you think is incorrect or incomplete.
Ask that we delete PI that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
Request that we restrict the way in which we process your PI, for example, if you dispute the accuracy of your PI or have raised an objection which is under consideration.
Request a copy of your PI that you have provided to us in a commonly used electronic format such as through the completion of an application form.
Request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you.
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You may exercise your rights at any time by using the details set out in the “Contact Us” section in this notice. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights. We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the PI processed in relation to you, including, for example, the nature and location of your relationship with us. We aim to respond to all legitimate requests within one calendar month. If we think it may take us longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), we will notify you and keep you updated. You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.

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Contact Us

ADT’s director’s office oversees compliance with privacy and data protection at ADT. If you wish to exercise any of your rights, or have questions concerning this notice, please contact:

The Directors
Privacy and Data Protection
Absolute Digital Technology Management LLC
3-212 Governors Square, 23 Lime Tree Bay Avenue,
Seven Mile Beach,
Grand Cayman, KY1-1203, Cayman Islands
Email: privacy@absolutedigitech.com

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Complaints

If you have any concerns or complaints about the way your PI is processed, please contact the directors at privacy@absolutedigitech.com

You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen.

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Linked Websites

This notice is not applicable to third party websites that we do not own or control, or to any third-party website where ADT may be displayed.

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Changes to this Privacy Notice

We may modify or amend this notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

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Cookie Notice

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website.When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on ourWebsite to tell us, in general terms, how and when pages on our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfill their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

If you are using one of our password-protected sites, then the Website may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation of the website and customize its content so that the information made available is likely to be of more interest to you.

In broad terms, we use cookies on our Website for the following purposes:

1. Analytical purposes Analytical cookies allow us to recognize, measure and track visitors to our Website and compile a record of this usage information. This helps us to improve and develop the way our Website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.

2. Usage preferences Some of the cookies on our Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.

3. Terms and conditions We use cookies on our Website in order to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user’s experience of the site – for example, it aids in avoiding a situation where a user is asked repeatedly to consent to the same terms. We also track whether a user has seen other similar documents (such as an online survey)before – again, to ensure that a user’s experience of our Website is a smooth one.

4. Session management The software that runs our Website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, to authenticate users, and to determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.

5. Functional purposes Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

6. Advertising Advertising cookies allow us (or third parties) to monitor the behavior of users of our Website. This information is used to ensure that products and services highlighted to those individuals are targeted in a focused and relevant manner – e.g. through advertisements on ADT websites or through advertisements on third party websites (e.g., Bloomberg, Agefi.com, Handlesblatt.de, etc) which are based on your experience with our Website; or to monitor the effectiveness of those digital marketing campaigns. We also monitor whether the adverts displayed on our Website are of interest to users and retain this information to ensure that adverts seen by users of our Website over a period of time are appropriate.

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policies. Please see below for more information about third party cookies. Your cookie preferences Cookies are necessary in order for you to be able to make full use of ADT’s Website. In addition, cookies help us provide you with personalized features on our Website. If you chose to disable cookies, some of ADT’s Website’s functionality might be impaired.

Local Flash Storage

On certain pages of our Website, we include content designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage(often referred to as “Flash cookies”) can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies but is managed directly by your Flash software. If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com.

Please note that, if you disable Flash cookies, some site functionality may not work.

Third party cookies

When you visit our Website, you may receive cookies that are set by third parties. These may include cookies set by Google, LinkedIn, and/or Rocket fuel. These cookies are used for the purposes described in the “Why Do We Use Cookies?” section of this policy.

We do not control the setting of these third-party cookies, so we suggest you might wish to check the third party websites for more information about the use of cookies and how to manage them: Google's privacy policy.

Amending cookie preferences If you wish to remove cookies set by our Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our sites will impair the functionality of the sites.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browses, or you may consult the vendor documentation for your specific software. Further information about cookies If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org