Please read this policy alongside the End User Licence Agreement for Adapt HR (the “EULA”). By accessing or using Adapt HR (the “Service”), you agree to this Privacy Policy and consent to our collection, storage, use, and disclosure of your Personal Data in accordance with this policy.

Any capitalized terms not defined here shall have the meaning given to them in the EULA.

COMPLIANCE WITH DATA PROTECTION LAWS

We collect, store, use, and disclose Personal Data in compliance with applicable laws, including but not limited to:

• United Kingdom: Data Protection Act 2018, UK General Data Protection Regulation (UK GDPR), Privacy and Electronic Communications Regulations (PECR).

• European Union: EU General Data Protection Regulation 2016/679 (EU GDPR), ePrivacy Directive 2002/58/EC.

• United States: Relevant federal laws (e.g., COPPA), and applicable state laws such as the California Consumer Privacy Act (CCPA) as amended by the CPRA, Virginia Consumer Data Protection Act (VCDPA), and others.

• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws.

For legal purposes, you are the Data Controller of any Personal Data you or your Users submit, and we act as the Data Processor.

PERSONAL DATA WE COLLECT

“Personal Data” means any information relating to an identified or identifiable natural person. We may collect the following categories of Personal Data from you and your Users:

• Client Data: May include names, contact details, National Insurance or Social Security numbers, bank details, payroll information, health data, and other employment-related records. May also include “Sensitive Personal Data” such as racial or ethnic origin, trade union membership, health information, etc.

• Correspondence: Includes communications with you or your Users.

• Forms: Information provided during registration or via forms on our website.

• Service-Related Data: Employee records, support requests, documents uploaded, and other usage data.

• Survey Responses: Information provided in optional surveys.

• Website Data: IP addresses, browser types, visit duration, and usage behavior.

Your Responsibility:
You confirm that you have obtained all necessary rights and consents to provide us with any Personal Data (including Sensitive Personal Data). You indemnify us (as outlined in Clause 14 of the EULA) for any claims resulting from unlawful access, use, or disclosure of Client Data.

COOKIES AND IP ADDRESSES

We use cookies and similar technologies to enhance functionality, analyze usage, and personalize content.

Types of Cookies We Use:

• Strictly necessary cookies: Essential for core functionality.

• Analytical/performance cookies: Help us understand usage patterns.

• Functionality cookies: Enable personalized features.

In regions where required (e.g., UK, EU, California, Canada), we request explicit consent for non-essential cookies. You or your Users may manage cookie preferences via browser settings or our cookie banner.

WHERE WE STORE PERSONAL DATA

Personal Data may be stored or processed in:

• The UK, European Economic Area (EEA),

• The United States, Canada, or

• Other jurisdictions where we or our service providers operate.

When transferring Personal Data internationally, we ensure appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs),

• Binding Corporate Rules (BCRs),

• Participation in frameworks like the EU–U.S. Data Privacy Framework, UK–U.S. Extension, or Swiss–U.S. Framework,

To learn more, email: privacy@adapthr.io

HOW WE PROTECT YOUR PERSONAL DATA

We maintain appropriate technical and organizational measures to safeguard your data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

While we use secure transmission methods, no internet-based system is 100% secure. We recommend keeping passwords confidential and using secure networks.

HOW WE USE YOUR PERSONAL DATA

We use Personal Data for the following purposes:

• To provide and manage the Service.

• To allow data uploads, storage, and access.

• To provide support and account moderation.

• For research, analytics, and Service improvements.

• To comply with applicable laws, court orders, and law enforcement requests.

• To ensure the safety of users, staff, and systems.

• To communicate service updates or marketing (with consent).

• To fulfill contractual obligations.

We may also aggregate and anonymize Personal Data for statistical analysis and share such anonymized data with third parties.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your or your Users’ Personal Data:

• To service providers involved in supporting the Service (e.g., hosting, security, analytics).

• To fraud prevention and law enforcement agencies.

• In connection with a merger, sale, or acquisition of assets.

All third parties must follow our instructions, implement appropriate safeguards, and must not use your data for unrelated commercial purposes.

YOUR RIGHTS

Depending on your jurisdiction, you and your Users may have the following rights:

United Kingdom / EU / EEA / Canada

• Right to access, rectify, or erase Personal Data.

• Right to restrict or object to processing.

• Right to data portability.

• Right to withdraw consent.

• Right to lodge complaints with supervisory authorities.

United States (State-Specific Rights)

• Right to know what Personal Data we collect and use.

• Right to request deletion or correction of Personal Data.

• Right to opt out of sale or sharing of Personal Data.

• Right to limit use of Sensitive Personal Data.

• Right to non-discrimination for exercising privacy rights.

Marketing Communications
We only send direct marketing

• In the US: with opt-in under CAN-SPAM.

• In Canada: with express consent under CASL.

• In the UK/EU: where legally permitted.

You can opt out anytime by contacting: privacy@adapthr.io

CONTACT US

For questions, complaints, or to exercise your rights under this Privacy Policy, contact:

Adapt HR Privacy Team
Email: privacy@adapthr.io