Privacy Policy

1. WHO WE ARE AND OUR APPROACH

We are 26Minutes Limited (we/us/our), and we are committed to respect your privacy and protecting your personal data.

This privacy policy sets out:

a) what personal data we collect about you;

b) how we use your personal data;

c) on what basis we use your personal data;

d) how long we keep your personal data;

e) the cookies we use and the purposes for using them;

f) who we share your personal data with;

g) your rights regarding your personal data.

Personal data is information by reference to which you can be identified or that we can link to you (personal data).

We collect data about:

a) the users of our website adon.shop and adon26.com (website);

b) individuals that subscribe to our newsletters, briefings, updates, marketing materials or other publications and invitations; and

c) our clients or their employees, agents, and representatives, and we may also collect data about the persons who transact or otherwise have legal relationships with our clients (you).

Before sharing your personal data with us please make sure that you have familiarised yourself with this privacy policy and contact us if any parts of it are unclear.

2. TYPES OF PERSONAL DATA. PURPOSE OF PROCESSING. LAWFUL BASES AND INDICATIVE RETENTION PERIODS

In collecting and processing your personal data we rely on one or several lawful bases. Please refer to Table 1 below for the summary of types of personal data, what it is used for, and on which lawful basis.

How long we store your personal data for depends on a number of factors, but we never retain it longer than necessary for the purposes for which it was collected. Please refer to the indicative retention periods in Table 1 below.

Personal data provided by you

We may process and use personal data you provided to us to send you newsletters, briefings, updates, marketing materials or other publications and invitations (communications) that we think may be of an interest (Public Services) or engage us to provide services to you (Services). Should you not wish to receive communications please contact us at info@adon26.com .

We always work to minimise the amount of your personal data in our possession, and only request the personal data indispensable for providing of Public Services and/or Services:

a) to provide Public Services to you, we need to tailor our communications to your needs and interests. To do this, we may need to collect your name, contact information such as e-mail address and telephone number, and information about your location and employment, such as company name and job title; and

b) to provide Services to you, we need to comply with regulations applicable to us, andhave enough information to enable us to enter in a contract with you and carry out our obligations before you. To this end:

i. we collect your identification and payment information including your address and bank details; as well as information about your other circumstances relevant to our engagement, determinable on a case-by-case basis; and

ii. you may need to provide other people’s personal data to us (e.g. your family members, customers, employees, officers, shareholders or beneficial owners). You must ensure that you have given those individuals an appropriate notice that you are providing their information to us and that they consent to that disclosure.

We have robust data protection policies in place. In the unlikely event of a data breach affecting or capable of having affected your data, we will notify you as soon as possible, but in any event within 48 hours of becoming aware of the breach.

Personal data provided by a third party or collected by us independently

If you are our client, we may need to obtain additional information relating to the subject matter of our engagement, and we may obtain it independently from public registers and other third-party sources.

If you are not our client but have a legally significant relationship with our client (for example, you are their family member or if you and our client have entered or are about to enter into a contract), we may collect your personal data within the framework of our client engagement. We will notify you if this happens, unless we are legally exempt from this notification requirement.

Table 1

PERSONAL DATA	PURPOSE (HOW WE USE IT)	LAWFUL BASIS	INDICATIVE RETENTION PERIOD
Contact information. Your name, phone number, address, email address.	Public Services: we use this information to send you our newsletters, invitations, updates,and briefings.	Legitimate Interests: a)providing services; b)ensuring our client records are up-to-date; c)management and improvement of relationship between us and our clients; d)development and promotion of our business and services; e)undertaking the marketing and business development activities in relation to our services such as sending to ourclients newsletters, briefings, updates and invitations to events and seminars organised by us; f)receiving our client’s feedback; g)improving our services and offerings; h)identifying ways to grow ourbusiness.	Until you unsubscribe from our Public Services.
	Services: we use this information to provide Services in accordance with the terms of our engagement and communicate with you in connection with the engagement.	Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract. Legitimate interests: a)providing services; b)ensuring that you are provided with the best services we can offer; c)securing a prompt payment of any fees, costs and debts in respect of our services.	Six years after our last engagement ended or after the last transaction between us, whichever is later.
	Services: we use this information to prevent fraud, ensure compliance with our professional obligations, and assist us in case of a dispute.	Legitimate Interests: a)ensuring we understand any conflict of interest which may arise for us in a matter; b)ensuring that we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities.
	Services: we include this information in our promotional materials in the course ofpromoting our Services to third parties.	Legitimate Interests: a)providing services; b)development and promotion of our business and services; c)improvingour services and offerings; d)identifying ways to grow our business.	Until the promotional material is made unavailable.
Identification information. Proof of identity, e.g. copy of official government identification or your utility bill.	Services: we use this information to verify your identity.	Compliance: the processing is necessary for us to comply with the law.	Six years after our last engagement with you ended or after the last transaction between us, whichever is later.
	Services: we use this information to prevent fraud, ensure compliance with our professional obligations, and assist us in case of a dispute.	Legitimate Interests: a)ensuring we understand any conflict of interest which may arise for us in a matter; b)ensuring that we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities.
Employment information. Information about your job title, employer and its location.	Public Services:we use this information to tailor the communications to your interests.	Legitimate Interests: a)providing services; b)ensuring our client records are up-to-date; c)management and improvement of relationship between us and our clients; d)development and promotion of our business and services; e)undertaking the marketing and business development activities in relation to our services such as sending to ourclients newsletters, briefings, updates and invitations to the events and seminars organised by us; f)receiving our client’s feedback; g)improving our services and offerings; h)identifying ways to grow our business.	Until you unsubscribe from our Public Services.
	Services: we may use this information to provide Services in accordance with the terms of our engagement.	Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.	Six years after our last engagement with you ended or after the last transaction between us, whichever is later.
	Services: we use this information to prevent fraud, ensure compliance with our professional obligations, and assist us in case of a dispute.	Legitimate Interests: a)ensuring we understand any conflict of interest which may arise for us in a matter; b)ensuring that we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities.
Information about your matter. Details of the matter you engage us to assist with, when they contain personal data.	Services: we use this information to provide Services in accordance with the terms of our engagement.	Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.	Six years after our last engagement with you ended or after the last transaction between us, whichever is later.
	Services: we use this information to ensure compliance with our professional obligations, andassist us in case of a dispute.	Legitimate Interests: a)ensuring we understand any conflict of interest which may arise for us in a matter; b)ensuring that we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities.
Payment and transaction information. Payment information, such as your credit card or bank account details, and other information such as date and time of your transaction.	Services: we use this information to invoice you for the Services under the terms of our engagement and facilitate the relevant transactions.	Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.	Six years after our last engagement with you ended or after the last transaction between us, whichever is later.
	Services: we use this information to prevent fraud and assist us in case of a dispute.	LegitimateInterests: ensuring we can manage payments, fees and charges and to collect and recover money owed to us.
Location information. Your current location, place of residence or business address.	Services: we use this information to prevent fraud, andensure compliance with our professional obligations.	Legitimate Interests: a)ensuring we understand any conflict of interest which may arise for us in a matter; b)ensuring that we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities.	Six years after our last engagement with you ended or after the last transaction between us, whichever is later.
Information supplied by third parties. Any personal data relating to you obtained from third parties or publicly available.	Services: we may combine this information with the information we collect from you directly to provide Services under the terms of our engagement. We may also use this information to prevent fraud, ensure compliance with our professional obligations, and assist us in case of a dispute.	Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.	Six years after our last engagement with the client ended or after the last transaction between us and the client, whichever is later.
		Legitimate Interests: if we had a contract with you and after our contract is over the processing may still be necessary for our legitimate interests or the legitimate interests of a third party in the absence of overriding considerations. If we obtained your data from a client for the purposes of our contract with them, we use this data relying on the legitimate interests pursued by our client in the absence of overriding considerations.

Consent

We do not generally process your personal data based on your consent (as we can usually rely on another lawful basis). Where we do process your personal information based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at info@adon26.com.

3. THE COOKIES WE USE:

A cookie is a small file of letters and numbers that we put on your computer which are essential for our website to function properly and which help to provide you with a better online experience.

We use strictly necessary cookies that are required for the operation of our website. These essential cookies are always enabled because our website will not work properly without them. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.

4. CCTV

CCTV has a legitimate role to play in helping to maintain a safe and secure environment for all our personnel and visitors. We currently use a CCTV camera to view and record individuals on our premises, relying on legitimate Interests as the legal basis for processing, namely crime prevention.

CCTV monitors the entrance to our offices in London 24 hours a day and this data is continuously recorded.

In order to ensure the balance of our legitimate interests and your rights as data subject, we will ensure that:

a) data gathered from CCTV is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so;

b) camera location is chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring;

c) live feeds from the camera and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. Recorded images will only be viewed in designated, secure premises; and

d) data recorded by CCTV is retained for no longer than 30 days.

5. SECURELY STORING AND SHARING YOUR DATA WITH THIRD PARTIES

We never share your personal data obtained in connection with the provision of Public Services, unless such disclosure is required by law or we reasonably believe it is necessary to:

a) comply with applicable law or respond to the reasonable and lawful requests of law enforcement and other official authorities, wherever originating; or

b) enforce the terms of our engagement, and pursue or mitigate the amount of damages arising from any breach of those terms.

We share your personal data obtained in connection with the provision of Services in the above cases too. When the terms or essence of our engagement call for such disclosure, we share your personal data with:

a) third party service providers that perform services for us or on our behalf, including accounting, payment, legal and translation services;

b) our agents and consultants based outside the UK, the EU/EEA;

c) third parties if you instruct us to do so, or when the terms of our engagement so demand; and

d) directories and referees and/or the public, when it is necessary for our legitimate interests namely for promotion of our services with reference to your feedback.

We have sufficient and reliable technical and organisational measures in place that protect your personal data against accidental or unlawful loss, destruction, alteration or damage.

We are an international practice with service providers located in various countries of the world. As a result, your personal data may be transferred to locations outside of the locations in which our office is located, including locations outside the UK, theEU/EEA. Where we transfer your personal data outside the UK or the EU/EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to data.

6. YOUR RIGHTS

If you are resident in the UK, you have the rights mentioned below in respect of your personal data in our possession. If you are resident elsewhere, please contact us atinfo@adon26.com if you would like to know if these rights are available to you, and we will help the extent required under applicable law.

Your data is not subject to automated decision-making.

Your legal rights:

• Right to be informed, i.e. to have up-to-date information regarding the purposes for the processing of your personal data, applicable retention periods, and who it will be shared with. All of this information has been included in this privacy policy. You can access the current version of this privacy policy at any time at [website page] and should do so periodically as we may revise this privacy policy from time to time, andwe will not ordinarily notify you of any changes.

• Right of access, i.e. to obtain:

a) confirmation of whether we are processing your personal data, the purposes for such processing, whether we share it with third parties, and applicable retention periods; and

b) a copy of the personal data we hold about you.

• Right to data portability, i.e. to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format, and/or to request the transfer of your personal data to another person. This right is only available to you in respect of the personal data that we collect and process on the basis of consent or contract.

• Right to rectification, i.e. a limited right to have inaccurate personal data in our possession rectified, and incomplete personal data completed.

• Right to erasure, also known as the right to be forgotten, i.e. to require us to erase your personal data if:

a) the personal data is no longer necessary for the purpose which we originally collected or processed it for;

b) we are relying on consent for holding the data, and you withdraw your consent;

c) we are relying on legitimate interests as our basis for processing, and you object to the processing of the data, and there is no overriding legitimate interest to continue this processing;

d) we are processing the personal data for direct marketing purposes and you object to that processing;

e) we have processed the personal data unlawfully;

f) we have to do it to comply with a legal obligation; or

g) we have processed the personal data to offer information society services to a child.

• Right to restrict processing, i.e. to require us to limit the purposes for which we process your personal data if:

a) you contest the accuracy of your personal data and we are verifying the accuracy of the data;

b) the data has been unlawfully processed and you oppose erasure and request restriction instead;

c) we no longer need the personal data but you need us to keep it in order toestablish, exercise or defend a legal claim; or

d) you have exercised your right to object (see below), and we are considering whether our legitimate interests override yours.

• Right to object, i.e. to ask us to stop processing your data. If we process your data relying on legitimate Interests, this right is also available to you subject to us being able to demonstrate compelling legitimate interests for the processing which do not override your interests, rights and freedoms. This right is also not available if the processing is for establishment, exercise or defence of legal claims.

If you wish to exercise one of these rights, please contact us at info@adon26.com

Right to complain, i.e. to lodge a complaint with the relevant data protection authority about the manner in which we process your personal data.

7. CONTACTING US

Any questions with respect to this privacy policy should be sent to info@adon26.com or to our office at

26Minutes Limited
Floor 2, 10 Frith Street

London, W1D 3JF

United Kingdom