Privacy policy

Last update: 23rd of May, 2018

This Privacy Policy covers how Adagio collects, holds, uses and discloses your personal information. This Policy applies to all information collected by Adagio, through the Adagio website, accessible at the following address: adagio.io.

Please note this Privacy Policy is subject to change at any time and at our discretion, mainly in order to comply with legal and regulatory changes as well as taking into account changes in technology or legislation. If we make changes to this Privacy Policy, we will update the effective date at the top of this page. These modifications apply to the User as soon as they are published online. Consequently, we highly recommend that you review the Privacy and Cookie Policies from time to time to be informed of any changes.

I. PERSONAL DATA

Globally, you can visit the Adagio website without communicating any personal data. You do not have any obligation to provide Adagio with your personal data.

However, in some cases, Adagio may ask you for certain personal information such as your name, surname, email address and company. By providing this information, you expressly agree that Adagio will process such information, for the purposes indicated in “2. Purpose of processing” below, as well as for the purpose specified on each form.

In accordance with the General Data Protection Regulation adopted by the European Parliament on April 14th, 2016, and the Data Protection Act of January 6th, 1978, amended, Adagio informs you of the following points:

1. Identity of the data controller

The controller will be represented by the company Adagio, registered at Rond Point Benjamin Franklin, 34000 Montpellier, France.

2. Purpose of processing

Adagio may process your personal data:

(a) for the purpose of providing you with the information or services you have requested, particularly, in the case of test request; and/or
(b) for the purpose of incident investigation, particularly in the event of an attack or attempted cyber attack; and/or
(c) to be able to identify you when using our services, accessible after login in.

3. Recipients

Adagio is the sole recipient of your Personal Information. These, whether in individual or aggregated form, are never transmitted to a third party, notwithstanding any subcontractor with whom Adagio works (you will find more information about them in point 7 below). Neither Adagio, nor any of its subcontractors, sells the personal data of the visitors and Users of the Adagio website.

4. Retention period

Adagio will retain your Personal Information for the period necessary to fulfill the purposes outlined above in point 2. However, this period cannot exceed 24 months.

5. Data Protection Act

Under applicable data protection laws, you have the following rights that you can exercise by contacting us at the following address: dpo@adagio.io or by writing us at the postal address mentioned in point 1.

Rights of access and communication of data

In conformity with the law, you have a right to access your Personal Information.However, because of its obligation of security and confidentiality in the processing of personal data, Adagio will consider such a request, provided that you can confirm your identity.
Adagio is entitled, if necessary, to oppose manifestly abusive requests (by their number, their repetitive or systematic nature).If you want to exercise your rights, you can address your request at the mailing address mentioned in point 1.

Right of rectification of data

You have the right to directly require from Adagio the correction of the data (if they are wrong), completion or clarification (if they are incomplete or equivocal) or erasement (if the information could not legally be collected).Moreover, you can set general and specific guidelines regarding the fate of your personal data after your death. In this case, the heirs of a deceased person may demand to consider the death of their loved one and / or to make the necessary updates.If you want to exercise your rights, you can address your request at the mailing address mentioned in point 1.

Right of opposition

The exercise of this right is only possible in one of the two following situations:

  1. When the exercise of this right is based on legitimate reasons; or
  2. When the exercise of this right aims at preventing the collected data from being used for commercial prospecting purposes.

If you want to exercise your rights, you can address your request at the mailing address mentioned in point 1.

6. Response time

Adagio undertakes to respond to your requests for access, rectification, opposition or any other request for additional information within a reasonable period of time, which may not exceed one month from receipt of your request.

7. Authorised providers and transfer to a third country within the EU

Adagio has previously ensured the implementation by its providers of adequate guarantees and compliance with strict conditions regarding confidentiality, usage and data protection. In particular, the attention was focused on the existence of a legal basis for any transfer of data to a third country. As such, one of our service providers is subject to internal corporate rules (or “Binding Corporate Rules”) that were approved by the CNIL in 2016 when others obey not only to Standard Contractual Clauses but also to the Privacy Shield.

8. Complaint to the competent authority

If you consider that Adagio does not comply with its obligations regarding your Personal Information, you may address a complaint or request to the competent authority. In France, the competent authority is the CNIL to which you can send an electronic request by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

II COOKIE POLICY

When you first login to the Adagio website, you will be warned by a banner at the bottom of your screen that information about your browsing may be stored in files called “cookies”. Our cookie policy allows you to better understand the provisions that we implement in terms of navigation on our website. It informs you in particular about all the cookies on our website, their purpose (part I.) and gives you the procedure to follow to set them up (part II.).

1. General information about cookies on the Adagio website

Adagio, as the publisher of this website, may implement a cookie on the hard drive of your device (computer, tablet, mobile etc.) to ensure a smooth and optimal navigation on our website.”Cookies” are small text files that allow us to recognize your computer, tablet or mobile device in order to personalize the services we offer.The information collected through cookies does not in any way identify you by name. They are used exclusively for our own needs in order to improve the interactivity and the performance of our website and to send you contents adapted to your centers of interests. None of this information is subject of a communication to third parties except when Adagio has obtained your prior consent or when the disclosure of this information is required by law, by order of a court or any administrative or judicial authorities.

2. Setting your cookie preferences

You can accept or refuse the deposit of cookies at any time.When you first login to the Adagio website, a banner briefly outlining information about cookies and similar technologies will appear at the bottom of your screen. This banner warns you that by continuing your navigation on the Adagio website (by loading a new page or by clicking on various elements of the site for instance), you accept the deposit of cookies on your device. You are also deemed to have consented to the deposit of cookies by clicking on the “X” icon to the right of the banner at the bottom of your screen.

Depending on the type of cookie, collecting your consent to deposit and read cookies on your device may be imperative.

Cookies exempted from consent

In accordance with the CNIL recommendations, some cookies are exempted from the prior collection of your consent to the extent that they are strictly necessary for a good functioning of the website or have the exclusive purpose of allowing or facilitating electronic communication. These include session ID, authentication, load balancing session cookies, as well as cookies used for customizing your interface.

These cookies are fully subject to this policy insofar as they are issued and managed by Adagio.

Cookies requiring the prior collection of your consent

This requirement applies to third-party cookies that are referred to as “persistent” as long as they remain in your device until they are deleted or expired.Their use and deposit are subject to their own privacy policies (see link below) because these cookies are issued by third parties. This kind of cookies are: audience measurement cookies (including Google Analytics), advertising cookies (which Adagio does not use), and social networking cookies (including Facebook, YouTube, Twitter and LinkedIn, which Adagio does not use)Cookies used for audience measurement provide statistics about the frequency and use of various elements of the website (such as the content/pages that you visited). These data are contributing and improving the ergonomics of the Adagio website. The tool used for audience measurement on this website is:

Google Analytics. Find out the terms of Service and confidentiality and privacy policies with the following link: https://www.google.com/analytics/terms/us.html

You can actively manage your cookie preferences.

Most internet browsers are initially set up to automatically accept cookies. You can change your standard browser settings to reject systematically all or only certain cookies according to the website.IMPORTANT: Note that disabling cookies may impact your experience on the Adagio website and prevent some Web services from working correctly. If done so, Adagio can not be held responsible for a degradation of your navigation because you choose to refuse, delete or block cookies that are necessary for the operation of the website and cannot be claimed or compensated.Your browser also allows you to delete existing cookies on your device or notify you when new cookies may be placed on your device. These settings do not affect your navigation but you lose all the benefits of the cookie.Please take notice of the multiple tools provided below to exercise your cookie preferences on your device.

Settings of your internet browser

Each internet browser has its own cookie management. You can exercise your cookie preferences by clicking on the appropriate links provided below:

Chrome: https://support.google.com/chrome/answer/95647?hl=fr
Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies
Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
Opera: http://help.opera.com/Windows/10.20/fr/cookies.html
Safari: https://support.apple.com/kb/PH21411?viewlocale=fr_FR&locale=fr_FR

For more information about cookies management, you can visit the CNIL website: https://www.cnil.fr/en/search/cookies.

“tarteaucitron” settings

The deactivation of cookies can also be done directly via the tool tarteaucitron set on the Adagio website. You can manage your cookies by clicking on the banner displayed at the bottom right of the page (button “Terms and conditions”) and uncheck the cookies that are still ticked. To disable a cookie, click on the cross next to the description of the service. If all cookies are disabled, the banner dedicated to collect the User’s consent will appear when the page is refreshed.

For any additional information or requests about this cookie policy, please email us at dpo@adagio.io.