Privacy Statement

Adonis is a Norwegian corporation, with legal entities, business processes, management structures and technical systems that cross international borders.  Adonis provides software and services to private and public businesses worldwide.  The company’s head office is located in Kvinnherad,  Vestland Region in Norway.  Adonis is subject to European data protection- and privacy regulations and directives. Our privacy policies and guidelines fully comply with the General Data Protection Regulation (GDPR), as well as privacy legislation in the countries the company operates. All major decisions regarding privacy in Adonis are made at the corporate level.

This Statement is available on our Adonis’ home page Adonis.no and at the bottom of every Adonis web site.

 

Scope and acceptance

This Privacy Statement applies to all Adonis business processes as well as all company websites, domains, mobile solutions, cloud services and communities. It also applies to Adonis- branded websites and third party social networks (e.g., Facebook). Any specific appendices for our cloud services is in the Terms of Service or equivalent for the service in question.

The Statement provides information about data processing carried out by Adonis when Adonis determines the purpose and means of the processing (Adonis as data controller), and data processing we do on behalf of our Customers based on their instructions (the Customer as data controller and Adonis as data processor).

Personal data is information that can identify you as a person (such as an email address, street address or phone number). Processing personal data is necessary for us to serve you and our Customers. In providing your personal data, you implicitly accept the practices and terms described in this Privacy Statement. Please do not use Adonis Sites or provide your personal data if you do not agree.

 

Whose data we process

Adonis process data about jobseekers, contact persons and software users among our Customers, including persons representing potentially new Customers that approach us via Adonis Sites or other channels.  Our statement regarding this is in the data controller section.

We also process data about our Customers’ employees and other persons’ data of which the Customer controls. Our statement regarding this is in the data processor section.

Note: in this Statement, data subjects may also be referred to as persons or you.

 

Adonis as data controller

When an Adonis subsidiary determines the purpose and means of processing your data, this subsidiary acts as data controller. Adonis control personal data that is collected in the context of you being a jobseeker, you are employed by a Customer that has or may have a business relation to Adonis, or you declare that you want to receive information from us based on your own or your employer’s interests. When you represent a Customer of Adonis, your rights are the same as if you were a private person only representing yourself.

 

Why we process your personal data

To manage our Customer relations in general and to meet our Customer commitments, Adonis requires some information about you in your role as Customer contact person or user of a service. Our aims with this are:

·         Provide offers on programs and services that Customers or prospective customers have asked for. Inform about and present program and service offers that are            closely related to the services and programs the Customer already uses

·         Perform deliveries in accordance with a customer agreement

·         Provide support to users of our programs and services

·         Enhance the quality of our programs, services and Adonis Sites

·         Identify and prevent security threats; perform maintenance and debugging

·         Prevent abuse of our programs and services

·         Disseminate information that is relevant for our deliveries in particular and our customer   relations in general

·         Process orders, invoicing, payments and other financial follow-up of Customers

·         Payment of programs and services purchased through Adonis Sites

·         Processing per the above listed purposes is necessary for us to effectively manage our customer relations. Therefore, Adonis does not ask for or require your                consent to process your personal data; the processing does not disadvantage you in any way.

In addition, we will collect information about you as a contact person or user of a service, for the following purposes:

·         To manage your access to our web-based services (cloud services)

·         To promote new products and services

If you are a jobseeker, we gather information in order to:

·         Evaluate your skills and background

·         Assess your potential as an Adonis employee

 

The basis for Adonis’s processing of personal data for these stated purposes is based on your voluntary consent. Your consent may be given on Adonis Sites when applicable. Please note that the collection of individual personal data is required in order to gain user access to many of our programs and services, and also to access the information you’ve requested.

 

How we collect your personal data

In general, Adonis collects data directly from you or other persons linked to the company that employs you. These persons may be a manager or a colleague. If the Customer you work for purchases Adonis programs and services from an Adonis partner company, we may collect information about you from the partner company.

We will also, with your consent, use cookies and other tracking technology when you use Adonis Sites, in order to optimize your experience of these platforms. Please see the paragraph describing automatic data collection tools for more information about these technologies and your rights in this context.

In some instances, we may also collect information about you from other sources if you have given your consent that the party collecting the personal data may share this. These sources may be third party data aggregators, Adonis’s marketing partners, public sources or third party social networks. Adonis will be able to combine personal data about you that is obtained from one source with data obtained from another source. This provides us with a more comprehensive perspective of you as contact person, which also gives us the possibility of serving you in a more timely and appropriate way, with a greater degree of personalization.

 

Automatic data collection tools

Adonis uses a variety of technologies to collect information about your movements on the web as well as the interests and preferences that you have disclosed.

Cookies

Cookies are small text files that contain a string of characters that are sent to a computer by website operators or third parties. Most browsers are initially set up to accept cookies. You may be, however, able to change your browser settings to cause your browser to block third-party cookies or to notify you when a third-party cookie is being sent. If you want to know more about cookies and how they work, visit www.allaboutcookies.org.

Marketing Automation Tools

Adonis is currently not using such tools.

Google

Google Analytics: This cookie allows us to see information on user Website activities including, but not limited to, page views and time spent on a Website. The information is anonymous and is displayed as numbers, meaning it cannot be tracked back to individuals. This helps protect your privacy.

Google Analytics Remarketing:  Places cookies on your computer which lets Google show you advertisements about Adonis that you might be interested in, based on your previous behavior on our website. This information is not personally identifiable.

Google AdWords: By using Google AdWords code, we are able to see which pages lead to  contact form submissions, which allows us to make better use of our paid search budget. This information is not personally identifiable.

Google Adwords Remarketing: Places cookies on your computer which enables Google to show you advertisements about Adonis that you might be interested in, based on your previous behavior on our website. This information is not personally identifiable.

If you want to prevent the information generated by the Google cookie about your use of our Sites from being collected and processed by Google in the future, download and install Google Analytics Opt-out Browser Add-on for your current web browser. This Add-on is available at http://tools.google.com/dlpage/gaoptout.

 

What personal data we process

The type of data that Adonis process about you may include:

Your own and the Customer’s contact details, such as name, address, telephone number and email.

Your date of birth, age and gender

Your employment information, such as job title, position,  including preferences and professional interests

Feedback, comments or questions about Adonis as a supplier, or regarding our programs and services

Photos or video of you recorded on our premises

Content you have uploaded, such as photos and video

Unique user information, such as login ID, username, password and a security question

Financial information, such as credit card information

Information provided by your web browser, such as browser type, language and the address of the website from which you arrived and other traffic information such as IP address

Clickstream behavior, such as which links you click on and when

Other personal data from your profile or what you’ve posted on third party social networks (Facebook, etc.)

 

How we share your personal data

Because Adonis has business locations and partners in several countries, there is a likelihood that Customer data is shared among them. We ensure that your data is secure wherever it is housed and accessed; we also ensure that you can access the relevant information on time and that you are not contacted unless it is necessary   for you or for Adonis.

Adonis does not share your personal data with third parties for marketing purposes.

Adonis may share your personal data with third parties for other purposes, but only in the following contexts:

Business partners

Adonis may share your personal information with our partners if there is a legitimate business purpose. For example, if you purchase a program or service on behalf of your employer that we provide.

Public Authorities

The police or other authorities may demand the handover of personal information from Adonis. In such cases, Adonis will only cooperate if there is a court order requesting the handover.

M&A

In connection with mergers, acquisitions or divestiture of all or parts of Adonis’s business, the acquiring entity as well as its consultants and Adonis’s will obtain access to data managed by the Adonis entity/entities involved. In some cases, this may include personal data. Should external parties enter into a NDA with Adonis, the NDA can also cover potential disclosure of personal data.

 

Your rights

Right to opt-out of marketing communications

You have the right to opt-out of receiving marketing communications from Adonis, and can do so by:

(a) Following the instructions for opt-out in the relevant marketing communication,

(b) Change your op-in/opt-out preferences under the account section if you have an account with Adonis, or

(c) Contacting us via e-mail

Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from Adonis, such as order confirmations and notifications about your account activities (e.g., account confirmations and password changes).

Access and rectification

You have the right to request a copy of your personal data.

You also have the right to request that Adonis correct any inaccuracies in your personal data. If you have an account with Adonis for an Adonis Site, this can usually be done through the appropriate "your account" or "your profile" section(s) on the Adonis Site (if available) or inside your Adonis cloud service. To manage subscription settings for Adonis Newsletters, please click the “UNSUBSCRIBE” link at the bottom of the emails you receive. Alternatively, you can send us a request to change your data.

 

Data security and retention

How we keep your personal data secure

Adonis takes the trust you place in us seriously. We are committed to preventing unauthorized access to or disclosure/processing of your data. Further, Adonis is committed to ensuring the proper use of the information, maintaining data integrity and assuring data availability. As part of this commitment, we use reasonable and appropriate technical and administrative procedures and protocols to safeguard the information we collect and process. Adonis has implemented a number of security measures, including:

Secure operating environments - Adonis stores your data in secure operating environments that are accessible only to Adonis employees and subcontractors on a need-to-know basis. Adonis follows industry standards in this respect.

Encryption of payment information - Adonis uses industry-standard encryption to protect sensitive financial information such as credit card information sent over the Internet (e.g., when you make payments through Adonis’s online stores).

Prior authentication for account access - Adonis requires its registered users to verify their identity (e.g. login ID and password) before they can access or make changes to their account. This prevents unauthorized access.

Please note that these protections do not apply to the personal data that you choose to publicly share on community websites and social media platforms.

How long we store your personal data

Adonis will only retain your personal data for as long as necessary for the stated purpose. We also take into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws.

This means that we may retain your personal data for a reasonable period after your last interaction with us and/or the Adonis system. When the personal data that we collect is no longer required, we destroy or delete it in a secure manner. We may process data for statistical purposes, but in such cases, the data will be anonymized.

 

Adonis as a data processor

Adonis provides many different services to our Customers. These services involve processing of the Customers’ data and may include processing personal data. The purposes of this processing is determined by our Customers, not by Adonis. The Customer is then the data controller for the data subject’s data.  In some cases, Adonis acts as data processor and processes the data on behalf of and according to instructions given by the Customer. When acting as data processor, Adonis enters into a data processing agreement (DPA) with the Customer. The Customer has agreed and guaranteed that:

The Customer is the owner of or otherwise has the right to transfer the data to Adonis for processing. The Customer is responsible for the accuracy, integrity, content, reliability and legality of the personal data

It is the Customer’s duty as data controller to notify, to the extent required by applicable law, the relevant supervisory authorities and/or the data subject in the event of any breach or unauthorized disclosure of personal data

When acting as data processor, Adonis is responsible for providing technical and organizational security measures in order to protect your privacy on behalf of our Customer - the data controller.

As data processor, Adonis will not process personal data in any other manner or for any other purpose than as authorized in the agreement with the data controller.

Data subjects having questions, comments, claims or any other issues regarding their personal data for which Adonis is data processor, must submit these to the data controller. As data processor, Adonis will not give any data subjects access to their personal data unless the data controller explicitly requests it.  If governmental authorities or the police request disclosure of personal data, Adonis will promptly notify the data controller; in such cases, we will disclose only the specific data requested in the  court order.

Upon request, Adonis will provide non-public information about internal systems and routines for data processing to Customers and collaboration partners. This may be contingent upon a non-disclosure agreement.

 

Subcontractors and export of personal data

In some cases, Adonis may use subcontractors to process personal data, and there may be times we export your personal data or our Customers’ data outside the EU. These subcontractors are typically vendors of cloud services or other IT hosting services. When using subcontractors, Adonis enters into a data processing agreement (DPA) in order to safeguard your privacy rights and/or to fulfill our obligations towards our Customers.

If the processing of data is performed outside of the EU, we make sure that the DPA is based on the EU Standard Contractual Clauses or if the data importer is located in the U.S., that they are certified according to the EU/US Privacy Shield framework. In such cases, we will also inform our Customers about the export of data. Adonis is not responsible for providing such information to data subjects whose data is controlled by our Customers.

 

Changes to this Statement

Should we make any modifications to our Privacy Statement, the revised statement will be posted here, with the revision date. We urge you to review the Statement periodically. If we make changes to our Statement that significantly affect our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages before the changes take effect.

 

How to contact us

If you have any comments or questions about our Privacy Statement, any unresolved privacy or data use concerns that we have not satisfactorily addressed, or you are concerned about a possible breach of your privacy, please email privacy@Adonis.no. You can also send your comments or questions it in writing to Adonis AS, Corporate Data Protection Manager, Roeo 91, 5457 Hoylandsbygd, Norway.

We will handle all correspondence in confidence. Our representative will contact you to address your concerns and outline the options in how they may be resolved.  We aim to ensure that all complaints are addressed in a timely and appropriate manner.