Effective date: July 12, 2018

Adkomo Ltd (“us”, “we”, or “our”) operates the websites www.adkomo.com and portal.adkomo.com (the “Services”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.adkomo.com

Who is Adkomo Ltd

This is Adkomo Ltd registered address, company number and contact information:

Adkomo Limited
25TH FLOOR, WORKINGTON TOWER,
78 BONHAM STRAND, SHEUNG WAN
HONG KONG

Company Registration Number: 2676735

Email: Privacy@adkomo.com

Adkomo Website: https://www.adkomo.com

Definitions

  • Service: Service is the www.adkomo.com website operated by Adkomo Ltd
  • Personal Data : Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data : Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Cookies : Cookies are small pieces of data stored on your device (computer or mobile device).
  • Data Controller : Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
  • Data Processors (or Service Providers) : Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User) : Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

When you register for an Account on portal.adkomo.com, we use a password-protected third-party Service Providers to store your personal information, and we may share your personal information with such third party (“Service Providers”) as is necessary for the performance of your Account and the Affiliate Network.

Non Personal Data

We may collect certain non-personally identifiable information about you when you visit certain pages of www.adkomo.com and/or register for an Account on portal.adkomo.com, such as the type of browser you are using (e.g., Chrome, Internet Explorer), the type of operating system you are using, (e.g., Windows or Mac OS) and the domain name of your Internet service provider (ISP). We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage.

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

We use a cookie to remember your cookie preferences this has a couple of consequence

  • If you delete all your cookies you will have to update your preferences with us again.
  • If you use a different device, computer profile or browser you will have to tell us your preferences again.

The cookies used on www.adkomo.com are based on the International Chamber of Commerce guide for cookie categories:

  • Strictly necessary : ‘Strictly Necessary’ cookies let you move around the website and login to your secure account. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet.We use these Strictly Necessary cookies to…
    • Identify you as being logged in to portal.adkomo.com
    • Remember things like information you’ve entered on forms when you navigate to different pages in a single web browser session
    • Help you use specific features like testing tracking links
    • Make sure you connect to the right service on our website when we make any changes to the way the website works

    ‘Strictly Necessary’ cookies will NOT be used to…

    • Gather information that could be used to advertise products or services to you
    • Remember your preferences or username beyond your current visit
  • Performance : ‘Performance’ cookies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies don’t collect any information that could identify you – all the information collected is anonymous and is only used to help us improve how our website works, understand what interests our users and measure how effective our advertising is.We use performance cookies to…
    • Provide statistics on how our website is used
    • See how effective our adverts are (we don’t use this information to target adverts to you when you visit other websites
    • Provide feedback to partners that one of our visitors also visited their website. This can include details of any products bought. This lets our partners improve their website, but we don’t allow our partners to reuse this information for further advertising
    • Help us improve the website by measuring any errors that occur
    • Test different designs of our website

    Cookies we have defined as ‘Performance’ cookies will NOT be used to…

    • Remember your preferences or username beyond your current visit In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above.
  • Functionality : ‘Functionality’ cookies are used to provide services or to remember settings to improve your visit.We use ‘Functionality’ cookies to…
    • Remember settings you’ve applied such as layout, text size, preferences and colours
    • Remember if we’ve already asked you if you want to fill in a survey
    • Provide proactive live chat sessions to offer you support or submit a trouble ticket
    • Show you when you’re logged in to the website
    • Share information with partners to provide a service on our website. The information shared is only to be used to provide the service, product or function and not for any other purpose

    Cookies defined as ‘Functionality’ will not be used to…

    • Target you with adverts on other websites. Some of these cookies are managed for us by third parties – where this is the case we don’t allow the third party to use the cookies for any purpose other than those listed above.

Use of Data

Adkomo Ltd uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Adkomo Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Adkomo Ltd may process your Personal Data because:

  • We need to perform a contract, provide our services and any related technical support  and fulfill our contractual obligations
  • You have given us permission to do so. You can withdraw at any time by contacting us privacy@adkomo.com
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • To comply with the law or competent authorities

Retention of Data

Adkomo Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Adkomo Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the European Union and choose to provide information to us, please note that we transfer the data, including Personal Data, to the European Union and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Adkomo Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If Adkomo Ltd is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Adkomo Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Adkomo Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Adkomo Ltd
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Your Employees

Your acceptance of the terms of this Privacy Policy, in their entirety, shall extend to your employees. You agree that any of your employees that access your Account or visit the Site under the scope of their employment with you agree to the terms of this Privacy Policy.

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Adkomo Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data by  contacting us.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Adkomo Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Server hosting and outsourcing

Adkomo Ltd uses third-party Service Providers to for server hosting and outsourcing.

Octopuce : Octopuce is a server hosting and outsourcing company. For more information on the privacy practice of Octopuce, please visit Octopuce Personal Data Terms : https://www.adkomo.com/wp-content/uploads/20180402_RGPD_Octopuce.pdf

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics : Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

  • Google AdSense & DoubleClick CookieGoogle, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Behavioral Remarketing

Adkomo Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Recruitment policy

As part of any recruitment process, Adkomo Ltd collects and processes personal data relating to job
applicants. The organisation is committed to being transparent about how it collects and uses that data and to
meeting its data protection obligations.

What information do we collect?

Adkomo Ltd collects a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
  • and information about your entitlement to work in the UK.

Adkomo Ltd may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment. We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so. Data will be stored in a range of different places, including on your application record, in HR management
systems and on other IT systems (including email).

Why does Adkomo Ltd process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with its legal obligations. For example, it is mandatory to check a successful applicant’s eligibility to work in the country before employment starts.

Adkomo Ltd has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Adkomo Ltd may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, Adkomo Ltd may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks.

How does Adkomo Ltd  protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does Adkomo Ltd keep data?

If your application for employment is unsuccessful, the organisation will hold your data on file for 6 (six) months after the end of the relevant recruitment process. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. You will be asked when you submit your CV whether you give us consent to hold your details for the full 6 months in order to be considered for other positions or not.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the organisation to change incorrect or incomplete data;
  • require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where Adkomo Ltd is relying on its legitimate interests as the legal ground for

If you would like to exercise any of these rights, please contact privacy@adkomo.com

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Adkomo Ltd during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: privacy@adkomo.com