Privacy Policy

WHO WE ARE
We are Adsum Technologies Ltd (referred to as Adsum, we, our and us in this document). We’re serious about protecting and respecting your privacy and your business’ privacy. We’re registered with the Information Commissioner’s Office (ICO) under the number ZB071038 and registered with the Financial Conduct Authority under the number 921976.

This document explains how we use your personal information when you use our website or access our services. If you want further information or want to speak to someone about how we use your personal information, please use the live chat (bottom right) and someone will be in touch.

YOU AND YOUR DATA
The business and people authorised to access our services on behalf of the business are referred to as “you” in this document. Where you share personal data which is not about yourself, for example, about an employee, business partner, director, owner, you must have the permission of the other person/people and confirm they understand how we will use their data.

WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT
Direct interactions
Information we hold about you and people connected to your business will often come from you directly. That information will include our own records of your shareholders (including beneficial owners), suppliers and companies you use or may have agreements with, other directors, partners, beneficial owners, signatories or employees in your business, people appointed to act on your behalf.

Shared through our website

• Details you give when you see if you qualify for our services or make an application, such as your name, home address, date of birth, email, phone number, geographic location, ID, photograph.
• Details about your business including industry, business size, financial information to determine your eligibility for our services.
• The login details and settings you choose for the website and client portal so you can use these securely.
• Your IP address

Shared when you contact us
We collect the following so we can answer your questions and take the appropriate action:

• The phone number you’re calling from and information you give us during the call (we record all calls).
• The email address and contents of your email (including any attachments).

Shared when you use our services
We collect this information to provide you with our services in a safe and lawful way, and to help us constantly improve our services. This includes:

• Details about how you use our website and our portal.
• Details about the services you express interest in.
• Details about any feedback you give us explicitly in feedback forms and via the live support chat.

When you apply to use our services

• We’ll need you to verify your identity and search your record with fraud prevention agencies, Anti Money Laundering (AML), and Know Your Customer (KYC) service providers.
• We may request access to the platforms you use to run your business such as banking and accounting platforms. We will use the data shared to determine your eligibility for our products and monitor performance. All data will be accessed in read-only mode (so no data can be edited or added). Stored data is encrypted and visible only to those who need to access it and will never be shared externally.
• Once you accept an offer of funding from Adsum, we will collect your Business Tax Account (Government Gateway) credentials. We switch access to our registered office details (phone number and email) for the duration of your agreement with us. The duration of this access is the same as the term period of your agreement with Adsum. We use these credentials to validate your tax dues (VAT, Corporation Tax, PAYE), liaise with HMRC on your behalf, track your reclaim and nominate our bank for repayment via the Making Tax Digital (MTD). If you require access during the term of the agreement for any operational reasons, please reach out to portal@adsum-works.com and we’d be happy to help.

COOKIES
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

THE REASONS WE USE YOUR INFORMATION
European and UK data laws say we need to have a lawful basis for using your personal data. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent. In this section, we explain which one we rely on to use your data in a certain way.

We need to use your data for a contract we have with you, or to enter into a contract with you. We use details about you to:

• Consider your application.
• Give you the services we agreed to in line with our terms and conditions.
• Send you messages about your account and other services you use if you get in touch, or we need to tell you about something.
• Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us.
• Investigate and resolve complaints and other issues.

We need to use your data to comply with the law, including:

• Confirming your identity when you sign up or get in touch.
• Check your record at fraud prevention agencies.
• Prevent illegal activities like money laundering, tax evasion and fraud.
• Keep records of information we hold about you in line with legal requirements.
• Adhere to banking laws and regulations (these mean we sometimes need to share customer data with regulators, law enforcement or third parties).

When it’s in our “legitimate interest”:

We need to use your data for legitimate interests. This means using your data in a way that you might expect us to, for a reason which is in your interest and which doesn’t involve overriding your privacy rights. We:

• Tell you about products and services through the website or other channels, like social media companies, based on how you use our services and products and other information we hold about you. We do this so we can make sure our marketing is of interest to you.
• Track, analyse and improve the services we offer to you and other customers and how you respond to the ads we display. We may ask for feedback if you’ve shown interest in a service. We do this so we can make our products better and understand how to market them.
• Protect the rights, property, or safety of us, our customers or others.
• Carry out security and maintenance checks to make sure our website and other services run smoothly for you.
• Manage Adsum’s business and financial affairs and protect our customers and staff.
• Share information with credit bureaus so we can benefit from up-to-date information when we make lending decisions, and other companies so they can help us provide our services.

CONSTENT
We’ll ask for your consent to:

• Send you information about our products and services, and those of our partners if we think they’re of interest to you. Each email will have an option to unsubscribe from similar future emails should you want to.
• Share information about you with companies we work with when we need your permission (see “Who we share your data with” below).

You don’t have to share information about yourself if you don’t want to. But if you don’t, you may not be able to use some (or any) of our services.

WHO WE SHARE YOUR DATA WITH
Companies that give services to us. Here we mean companies that help us provide services you use, and need to process details about you for this reason. We share as little information as we can and encrypt and/or make it impossible for you to be identified by the recipient where possible (for example using a USER ID rather than your name).

• Know Your Customer (KYC) and Anti-Money Laundering (AML) service providers that help us with identity verification or fraud checks such as Veriff.
• Cloud computing power and storage providers like Amazon Web Services and Google Cloud.
• Software companies that help us with marketing, such as email platforms and customer relationship management platforms.
• Our business intelligence and analytics platform provider.
• Companies that help us with customer support.
• Companies that manage our security and office maintenance if you visit our offices.

Anyone you give us permission to share it with

• Companies that introduce their own services through the Adsum website.
• Your own banking, accounting, tax or other business platforms to determine eligibility and monitor performance such as Xero.
• People you’ve asked to represent you, such as solicitors.

Law enforcement and other external parties

We may share your details with:

• Authorities that identify and stop financial crimes, money laundering and tax evasion if the law says we are obligated to, or if it’s necessary to for other reasons.
• The police, courts or dispute resolution bodies if we have to.
• Other banks to help trace money if you’re a victim of fraud or other crimes or there’s a dispute about a payment.
• Any other third parties where necessary to meet our legal requirements.

We may also share your details with people or companies if there is a corporate restructure, merger, acquisition or takeover.

WHEN WE MAKE AUTOMATED DECISIONS
We sometimes use computers to make decisions. We do this for things like deciding if we can make you a funding offer based on information we hold about you. You can ask a member of the team to review a decision by emailing portal@adsum-works.com or contacting us via the live support chat.

HOW LONG WE KEEP YOUR INFORMATION
We keep most of your data for as long as you’re using Adsum’s services, and for 5 years after that to comply with the law and if we face a legal challenge. In other circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (in our legitimate interest) and/or the law says we have to.

To work out how long we keep different categories of your data, we consider why we hold it, how sensitive it is, how long the law says we need to hold it, and what the risks are.

YOUR RIGHTS
You have a right to:

• Access the personal data we hold about you, or to get a copy of it.
• Ask for a copy of your personal data in a portable (machine-readable) format or make us send it to someone else.
• Make us correct inaccurate data.
• Ask us to delete, block or suppress your data, though for legal reasons we may not always be able to fulfil your request.
• Say no to us using your data for direct marketing and in certain other “legitimate interest” circumstances.
• Companies that help us with marketing (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt-out at any time).
• Withdraw any consent you’ve given us.
• Ask a member of the team to review a computer-made decision.

To exercise any of these rights, please contact us through the website or by emailing portal@adsum-works.com. EU data protection laws, like the GDPR, give us one month to respond.

WHERE WE STORE OR SEND YOUR DATA
We may transfer and store the data we collect from you to organisations outside of the European Economic Area (EEA). When we do this, we make sure that your data is protected and that:

• The European Commission says the country or organisations has adequate data protection, or we have agreed to the standard data protection clauses approved by the European Commission with the organisation.
• If you’d like a copy of the relevant data protection clauses, please send an email to portal@adsum-works.com.

HOW TO MAKE A COMPLAINT
If you have a complaint about how we use your personal information, please send an email to portal@adsum-works.com and we’ll do our best to fix the problem. You can also reach our Data Protection Officer in this way.

If you’re still not happy, you can refer your complaint with a data protection supervisory authority in the EU country you live or work, or where you think a breach has happened. The UK’s supervisory authority is the Information Commissioner’s Office (ICO). For more details, you can visit their website at ico.org.uk.

CHANGES TO THIS POLICY
We’ll post any changes we make to our privacy notice on this page and if they’re significant changes we’ll let you know by email.