Aduna Privacy Notice

Last updated: February 11, 2025

This Privacy Notice describes how Aduna Global LLC and any other Aduna group companies you are contracting or dealing with (“Aduna”, “us”, “our”, “we”) handle personal data in connection with your use of our website and in connection with the services we provide (together, our “Services”), what your rights are and how you can contact us. This Privacy Notice applies to situations where Aduna group companies act as data controllers or equivalent local law concept. When we refer to “personal data” we mean any information relating to an identified or identifiable individual.

This Privacy Notice applies to the extent required by applicable laws. This Privacy Notice does not apply to Aduna’s processing activities as processor, for example when we process personal data on behalf of our customers when we provide services to them. The contracts we have with our customers control how we process personal data in such context. If you are a customer, end-user, or employee, or contractor of one of Aduna’s customers and have questions about the processing of your personal data, we recommend that you contact our respective customer.

1. How do we process your personal data?

We only use your personal data where it is necessary for specific purposes. We receive your personal data directly from you, from your employer (e.g., our customer or business partners) or through automated means. Where applicable, we indicate to you in connection with the collection of personal data whether the provision of such data is mandatory.

We may aggregate your personal data to a non-identifiable format and use such data to improve and develop the Services. Please see also sections 2 and 4 for more general information on how we share and retain your personal data.

In Canada, the only legal basis that we rely upon to process your personal data is your implied or express consent, except where permitted or required by law.

1.1 Providing services to our customers

Purposes of processing: Why do we process your personal data?	Personal data categories we may process in this context	Legal basis for our processing (where required under applicable laws)
To deliver our Services and carry out core activities relating to our Services Aduna processes personal data and other information as necessary to perform our obligations in delivering our Services to our customers. This includes processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, preventing fraud, violations of our acceptable use policies, and unlawful activities, and operating and maintaining our Services. We also need your information to communicate with you about the Services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the Services.	First name, last name ID numbers that we or third parties assign to you to identify you Contact details (email address, phone number) Information about your job role (company, business unit, role, office location) Contents of our communications with you such as email correspondence, screenshots or any other information relevant to solving the issue with you	The processing is necessary to comply with our contractual obligations under the Service’s relevant terms and conditions that you may have agreed to; or We have a legitimate interest in using your personal data to maintain our business relationships and comply with laws and regulations.

Purposes of processing: Why do we process your personal data?

Personal data categories we may process in this context

Legal basis for our processing (where required under applicable laws)

To deliver our Services and carry out core activities relating to our Services

Aduna processes personal data and other information as necessary to perform our obligations in delivering our Services to our customers. This includes processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, preventing fraud, violations of our acceptable use policies, and unlawful activities, and operating and maintaining our Services.

We also need your information to communicate with you about the Services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the Services.

First name, last name
ID numbers that we or third parties assign to you to identify you
Contact details (email address, phone number)
Information about your job role (company, business unit, role, office location)
Contents of our communications with you such as email correspondence, screenshots or any other information relevant to solving the issue with you

The processing is necessary to comply with our contractual obligations under the Service’s relevant terms and conditions that you may have agreed to; or
We have a legitimate interest in using your personal data to maintain our business relationships and comply with laws and regulations.

1.2 Customer, supplier and partner relationships

Purposes of processing: Why do we process your personal data?	Personal data categories we may process in this context	Legal basis for our processing (where required under applicable laws)
Customer, supplier and partner relationship management and business administration Aduna processes personal data about customer, supplier and partner representatives for administrative purposes, contract management and contract performance, sales and sourcing related activities, delivery of products and services, invoicing and management of the services and the business relationship with our customers, suppliers and partners. We use the relevant personal data to develop our Services and to improve the quality of Aduna’s solutions and Services as well as for business planning and customer engagement planning. We also use supplier and partner personal data to perform supplier due diligence and necessary background checks where such checks are required under our policies.	First name, last name Contact details (business email, business phone) Information about your job role (company, business unit, role, office location) Communications with you such as email correspondence Language preferences (e.g., “prefers to use English”) Date of birth where needed Nationality where needed Signatures Other information you may provide, or we may need for the business administration and relationship management purposes Information about supplier representatives collected in connection with potential background checks and supplier due diligence reviews	We have a legitimate interest in using your personal data to maintain our business relationships and comply with laws and regulations.
Customer support Aduna may process customer representatives’ personal data about how you use our customer support services to provide you with a personalized experience on the customer support platform and to continuously improve the user experience of our Services. We may also process your personal data for troubleshooting and to protect the Services, products, and solutions against security and cyber threats and prevent such threats. Aduna mainly processes personal data to respond to customer support requests and to provide customer support services as processor on behalf of our customers. Please check the relevant Aduna business customer’s privacy notice for more information about their processing activities.	First name, last name Contact details (business email, business phone) Information on communications with you (call history, chat transcripts, questions, and answers on our Aduna customer support platforms) Security logs	We have a legitimate interest in using your personal data to run our business effectively and efficiently. In certain instances, we may also obtain your consent for certain processing activities.
Customer experience surveys Aduna performs customer experience surveys on a regular basis to validate our customers’ needs and to improve and develop our Services.	First name, last name Contact details (business email) Information about your job role (company, role, country) Your responses to the survey questions	We have a legitimate interest in developing and improving our Services.

Purposes of processing: Why do we process your personal data?

Personal data categories we may process in this context

Legal basis for our processing (where required under applicable laws)

Customer, supplier and partner relationship management and business administration

Aduna processes personal data about customer, supplier and partner representatives for administrative purposes, contract management and contract performance, sales and sourcing related activities, delivery of products and services, invoicing and management of the services and the business relationship with our customers, suppliers and partners.

We use the relevant personal data to develop our Services and to improve the quality of Aduna’s solutions and Services as well as for business planning and customer engagement planning. We also use supplier and partner personal data to perform supplier due diligence and necessary background checks where such checks are required under our policies.

First name, last name
Contact details (business email, business phone)
Information about your job role (company, business unit, role, office location)
Communications with you such as email correspondence
Language preferences (e.g., “prefers to use English”)
Date of birth where needed
Nationality where needed
Signatures
Other information you may provide, or we may need for the business administration and relationship management purposes
Information about supplier representatives collected in connection with potential background checks and supplier due diligence reviews

We have a legitimate interest in using your personal data to maintain our business relationships and comply with laws and regulations.

Customer support

Aduna may process customer representatives’ personal data about how you use our customer support services to provide you with a personalized experience on the customer support platform and to continuously improve the user experience of our Services.

We may also process your personal data for troubleshooting and to protect the Services, products, and solutions against security and cyber threats and prevent such threats.

Aduna mainly processes personal data to respond to customer support requests and to provide customer support services as processor on behalf of our customers. Please check the relevant Aduna business customer’s privacy notice for more information about their processing activities.

First name, last name
Contact details (business email, business phone)
Information on communications with you (call history, chat transcripts, questions, and answers on our Aduna customer support platforms)
Security logs

We have a legitimate interest in using your personal data to run our business effectively and efficiently. In certain instances, we may also obtain your consent for certain processing activities.

Customer experience surveys

Aduna performs customer experience surveys on a regular basis to validate our customers’ needs and to improve and develop our Services.

First name, last name
Contact details (business email)
Information about your job role (company, role, country)
Your responses to the survey questions

We have a legitimate interest in developing and improving our Services.

1.3 Marketing, advertising, website and analytics

Purposes of processing: Why do we process your personal data?	Personal data categories we may process in this context	Legal basis for our processing (where required under applicable laws)
Marketing and communications If you contact Aduna with an inquiry, an order, or a request for information or support, we will use this personal data to respond to the inquiry, order, or request and to manage further correspondence. Aduna processes personal data for communications on sales and marketing purposes, including email marketing. We may combine this information with data obtained from other sources (such as cookies) to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you. We also use your data for analytics and service development and service improvement. We may use your personal data for lead generation, contact segmentation, lead nurturing and lead scoring, relationship marketing, cross-selling, and marketing return on investment (ROI) measurement. Aduna is also an administrator for certain business pages on social media sites such as Facebook. Aduna may act as a joint controller with the social media platform provider when processing personal data about the visitors on such page for Aduna’s advertising purposes, even if Aduna does not access any personal data. The terms setting forth the data protection obligations and the implementation of data subject rights between Aduna and Facebook regarding Facebook Insights can be accessed here.	First name, last name Contact details (email, business phone) Information about role (company, role, office location) Details about your inquiry, order, or request, (if applicable) Information about contact person at Aduna Information about marketing opt-in / opt-out Information received via cookies if you have given your consent for marketing cookies, such as IP address, device type, and information about your browsing time, browsing history, and interactions with our websites and Services Information about your interactions with our marketing communications such as whether you have opened the email or clicked links in our emails	Where required under applicable law, you have consented to the processing by giving your consent for email marketing or marketing cookies; or We have a legitimate interest in using your personal data to maintain our business relationship and effectively communicate with our customers. You may choose not to receive email marketing or communications from us by following the “unsubscribe” instructions included in each email. You can withdraw your cookie consent any time on our website.
Third-Party Advertising We use third-party advertising companies to place advertisements on third-party platforms and websites that may be of interest to you based on your behavior on our Services, as well as based on information received from third parties. These third-party companies might place a cookie in your browser or on your device, used for determining interest categories, performance measurement (tracking pixel), and cross-device identification. You can find more information on this in our Cookie Notice. No advertising/marketing cookies are placed on your device when you visit Aduna’s websites if you have not given your consent for using such cookies.	IP address Information collected via cookies, such as Client ID, device type and information about your browsing time, browsing history, and interactions with our Services, if you have given your consent for analytics and marketing cookies E-mail address	Where required under applicable law, you have consented to the processing by giving your consent for using advertising/marketing and analytics cookies. You can withdraw your consent any time on our website.
Website analytics, service improvement and service development We analyze how our Services are being used to make them more intuitive, improve functionality and deliver better content. We place a cookie in your browser to determine you as returning visitor to our website (random cookie identifier). You can find more information on this in our Cookie Notice. No analytics cookies are placed on your device if you have not given your consent for using such cookies.	We may process your IP address for geographic information without storing the IP address. Information collected via cookies such as Client ID, device type and information about your browsing time, browsing history and device type.	Where required under applicable law, you have consented to the processing by giving your consent for analytics cookies. You can withdraw your consent any time on our website.

Purposes of processing: Why do we process your personal data?

Personal data categories we may process in this context

Legal basis for our processing (where required under applicable laws)

Marketing and communications

If you contact Aduna with an inquiry, an order, or a request for information or support, we will use this personal data to respond to the inquiry, order, or request and to manage further correspondence.

Aduna processes personal data for communications on sales and marketing purposes, including email marketing. We may combine this information with data obtained from other sources (such as cookies) to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you. We also use your data for analytics and service development and service improvement.

We may use your personal data for lead generation, contact segmentation, lead nurturing and lead scoring, relationship marketing, cross-selling, and marketing return on investment (ROI) measurement.

Aduna is also an administrator for certain business pages on social media sites such as Facebook. Aduna may act as a joint controller with the social media platform provider when processing personal data about the visitors on such page for Aduna’s advertising purposes, even if Aduna does not access any personal data. The terms setting forth the data protection obligations and the implementation of data subject rights between Aduna and Facebook regarding Facebook Insights can be accessed here.

First name, last name
Contact details (email, business phone)
Information about role (company, role, office location)
Details about your inquiry, order, or request, (if applicable)
Information about contact person at Aduna
Information about marketing opt-in / opt-out
Information received via cookies if you have given your consent for marketing cookies, such as IP address, device type, and information about your browsing time, browsing history, and interactions with our websites and Services
Information about your interactions with our marketing communications such as whether you have opened the email or clicked links in our emails

Where required under applicable law, you have consented to the processing by giving your consent for email marketing or marketing cookies; or
We have a legitimate interest in using your personal data to maintain our business relationship and effectively communicate with our customers.

You may choose not to receive email marketing or communications from us by following the “unsubscribe” instructions included in each email.

You can withdraw your cookie consent any time on our website.

Third-Party Advertising

We use third-party advertising companies to place advertisements on third-party platforms and websites that may be of interest to you based on your behavior on our Services, as well as based on information received from third parties. These third-party companies might place a cookie in your browser or on your device, used for determining interest categories, performance measurement (tracking pixel), and cross-device identification.

You can find more information on this in our Cookie Notice. No advertising/marketing cookies are placed on your device when you visit Aduna’s websites if you have not given your consent for using such cookies.

IP address
Information collected via cookies, such as Client ID, device type and information about your browsing time, browsing history, and interactions with our Services, if you have given your consent for analytics and marketing cookies
E-mail address

Where required under applicable law, you have consented to the processing by giving your consent for using advertising/marketing and analytics cookies.

You can withdraw your consent any time on our website.

Website analytics, service improvement and service development

We analyze how our Services are being used to make them more intuitive, improve functionality and deliver better content.

We place a cookie in your browser to determine you as returning visitor to our website (random cookie identifier). You can find more information on this in our Cookie Notice. No analytics cookies are placed on your device if you have not given your consent for using such cookies.

We may process your IP address for geographic information without storing the IP address.
Information collected via cookies such as Client ID, device type and information about your browsing time, browsing history and device type.

Where required under applicable law, you have consented to the processing by giving your consent for analytics cookies.

You can withdraw your consent any time on our website.

1.4 Aduna events, sites, and locations

Purposes of processing: Why do we process your personal data?	Personal data categories we may process in this context	Legal basis for our processing (where required under applicable laws)
Aduna events We process your personal data when you register or attend our or our partners’ online or offline events. We may use the data collected in connection with our events to send you marketing if we have received your consent for marketing. To learn more about how we process your personal data for marketing purposes, please see section 1.2.	First name, last name Contact details (email, business phone) Information about role (company, title, office location) Participation and comments in event sessions and surveys Information about dietary requirements Personal data in the photos and videos taken during the events Information you may provide in feedback or online event chats	Where required under applicable law, you have consented to the processing; The processing is necessary to comply with our contractual obligations under the event’s relevant terms and conditions that you may have agreed to; or We have a legitimate interest in using your personal data to develop and maintain our business relationship.
Visitors at Aduna locations and sites We register personal data about you if you are visiting our sites or locations for reasons of security and safety of persons and property, as well as for regulatory purposes.	First name, last name Contact details (email, business phone) Information about role (company, title, office location) Visiting times (entrance and exit times)	We have a legitimate interest in using your personal data to keep track of the visitors and to ensure safety and security in our locations and sites; or The processing is necessary for compliance with a legal obligation.
Camera surveillance Aduna uses camera surveillance at Aduna location and sites where Aduna conducts business with the purpose to protect our staff, visitors, and company resources and to prevent and discover crime and incidents in the buildings and at sites.	CCTV recordings where your images can be identified	We have a legitimate interest in using your personal data to enhance safety and security and to protect our resources in our locations and sites.

Purposes of processing: Why do we process your personal data?

Personal data categories we may process in this context

Legal basis for our processing (where required under applicable laws)

Aduna events

We process your personal data when you register or attend our or our partners’ online or offline events.

We may use the data collected in connection with our events to send you marketing if we have received your consent for marketing. To learn more about how we process your personal data for marketing purposes, please see section 1.2.

First name, last name
Contact details (email, business phone)
Information about role (company, title, office location)
Participation and comments in event sessions and surveys
Information about dietary requirements
Personal data in the photos and videos taken during the events
Information you may provide in feedback or online event chats

Where required under applicable law, you have consented to the processing;
The processing is necessary to comply with our contractual obligations under the event’s relevant terms and conditions that you may have agreed to; or
We have a legitimate interest in using your personal data to develop and maintain our business relationship.

Visitors at Aduna locations and sites

We register personal data about you if you are visiting our sites or locations for reasons of security and safety of persons and property, as well as for regulatory purposes.

First name, last name
Contact details (email, business phone)
Information about role (company, title, office location)
Visiting times (entrance and exit times)

We have a legitimate interest in using your personal data to keep track of the visitors and to ensure safety and security in our locations and sites; or
The processing is necessary for compliance with a legal obligation.

Camera surveillance

Aduna uses camera surveillance at Aduna location and sites where Aduna conducts business with the purpose to protect our staff, visitors, and company resources and to prevent and discover crime and incidents in the buildings and at sites.

CCTV recordings where your images can be identified

We have a legitimate interest in using your personal data to enhance safety and security and to protect our resources in our locations and sites.

2. Sharing your personal data with third parties

Your personal data will be accessed by Aduna personnel on a need-to-know basis. Aduna shares personal data to other Aduna Group companies when reasonably necessary for the specific purposes of processing described in this Privacy Notice.

We work with third-party service providers. Such third-party service providers include data management platform providers, data analytics vendors, advertising vendors, customer relationship management software vendors and facility management service providers. These third parties may process your personal data on our behalf as part of providing services for us or they may process the personal data for their own purposes that we have accepted. We limit the information provided to these service providers to what is reasonably necessary for them to perform their functions, and we require them to agree to comply with applicable laws and maintain the confidentiality of such information.

As the provider of our Services, we share data we collect from you, your representatives or your users with third parties in order to comply with our contractual obligations to you, including:

Communication service providers (as necessary to provide you with the Services).
Partners that you purchase Services offered by Aduna or a partner from pursuant to a marketing or reseller agreement, as necessary to provide you with the Services.

We also share your personal data with professional advisors, in our legitimate interests in maintaining our business or as required by a legal obligation, such as with auditors, law firms or accounting firms.

Exceptionally, we may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, to cooperate with law enforcement or other governmental agencies or to otherwise establish, defend or exercise legal claims. We also reserve the right in exceptional circumstances to disclose your personal data that we believe is necessary to take precautions against liability or to protect ourselves, our property, or others from fraudulent, abusive, or unlawful uses or activity.

We may disclose personal data to a prospective buyer, acquirer, successor, seller, new owner, assignee or other relevant third party as necessary when negotiating or in connection with or anticipation of a change of corporate control such as a restructuring, merger, acquisition, sale of assets, bankruptcy, or similar transaction in our legitimate interests to ensure the continued success of our business.

3. International transfers of personal data

Since Aduna Group is present around the world and Aduna is driving a global business, we may transfer your personal data outside of the country where you are located to Aduna Group companies and to our contracted service providers or, in limited circumstances, to cooperate with law enforcement or other government agencies located anywhere in the world. The countries where your personal data is transferred may not have similar data protection laws as the country where we collected your personal data. However, Aduna will protect your personal data as described in this Privacy Notice.

Transfers outside of the European Economic Area (EEA) and the UK

When transferring your personal data outside of the EEA and the UK, Aduna will comply with applicable EEA and the UK data protection laws:

We may transfer your personal data from the EEA to countries/sectors which the European Commission has found to provide adequate level of data protection in accordance with the General Data Protection Regulation (GDPR);
We may transfer your personal data from the UK to the countries and territories covered by the UK adequacy regulations; or
We may rely on the relevant modules of the EU Commission’s Standard Contractual Clauses or other appropriate safeguards under the GDPR as well as the UK Addendums to the EU Standard Contractual Clauses and other appropriate safeguards under the UK data protection law.

For more information about how we transfer personal data outside of the country where you are located, you may contact us as specified below in section 8.

4. How long will we keep your personal data

Aduna limits the retention of personal data to a proportionate period during which the personal data is needed to accomplish those purposes or processing the data. When determining the length of time to retain your personal data, we consider various criteria, including whether we need the information to continue to provide you with our Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security, and integrity, or protect ourselves, including our rights, property or products.

We will also retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. The retention period may also depend on legal or regulatory requirements to which Aduna is subject.

When personal data is no longer needed, we have processes in place to securely delete the data, for example by erasing electronic files. Where we aggregate and anonymize your personal data, we may use this information indefinitely.

5. Your rights

Subject to the applicable data protection laws, you may have the following rights in relation to your personal data:

Right to access your personal data. You have the right to obtain confirmation on whether Aduna processes personal data about you and receive a copy of such data as well as information on how we process your personal data.
Right to rectification. You have the right to rectify any inaccurate personal data we process about you or have any incomplete personal data about you completed.
Right to erasure. You may have the right in certain circumstances to have your personal data deleted.
Right to data portability. You may have the right in certain circumstances to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and have that data ported directly to another controller.
Right to restriction. You may have the right in certain circumstances to restrict our processing of your personal data.
Right to object. You may have the right in certain circumstances to object to our processing of your personal data.
Right to information. You have the right to receive transparent information about how we process your personal data.
Right to withdraw your consent. You have the right to withdraw any consent for processing you provided at any given time. You can withdraw your consent for cookies any time by visiting the cookie withdrawal toggle on our website. You can withdraw your consent for direct marketing by unsubscribing from receiving our direct marketing. For any other cases, please contact us using the contact details set out in section 8 below. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We will not discriminate against you based on your exercise of any of the rights described above. Please note that a number of these rights only apply in certain circumstances, and all these rights may be limited by law. If you wish to exercise your rights or have any questions regarding the processing of your personal data, please contact us using the contact details set out in section 8 below.

6. Children’s privacy

Our Services are not directed to children under the age of 16 (or 13, in the UK and in certain EU member states), and we do not knowingly collect personal data from children under the age of 16 (or 13, in the UK and in certain EU member states). If you are under 16 years of age (or 13, in the UK and in certain EU member states), then please do not use or access our Services. If we learn that we have collected personal data about persons under 16 years of age and without verifiable parental consent, then we will take appropriate steps to delete this data.

7. Links to other websites or services

Our Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our website. We encourage you to learn about third parties’ privacy and security policies before using their services and providing them with information.

8. How to contact Aduna or competent supervisory authorities

If you have any questions or a complaint pertaining to your personal data you can contact us by mail at Privacy, 6300 Legacy Drive, Plano, Texas 75024, United States of America, or you can send an e-mail to privacy@adunaglobal.com.

You may also contact or submit complaints to your applicable data protection supervisory authority where you live or work in relation to your privacy rights.

9. Changes to this Privacy Notice

Aduna may, from time to time, make changes to this Privacy Notice to reflect any changes in our data processing practices. We recommend that you visit this Privacy Notice on occasion to learn about new privacy practices or changes. If we make material changes to the way in which we use information we collect, we will take any steps required by applicable law.