Background
ADM Club operated by Alesya de Monaco Ltd. is committed to protecting your privacy. We understand the importance you place on how your personal information is collected, used, and shared. This Privacy Policy outlines how we manage your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We respect and value the privacy of everyone who visits this website, https://adm.club (“Our Site” or “ADM Club”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
This privacy policy gives you information about how we collect and use your personal data through your use of our ADM Club, including:
• any data a Member provides when joining ADM Club or using ADM Club to purchase products from a Dealer/Maker
• any data Dealer/Makers provide when they join ADM Club as or use ADM Club to supply products to our Members
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
This Privacy Policy incorporates the terms and conditions between Us and our Members (Member Terms) and Dealer and/or Makers (Dealer and/or Maker Terms) as found on Our Site to the extent that such terms and conditions are applicable to UK GDPR and the use of the data belonging to Members and Dealer and/or Makers.
Defined terms used in the Member Terms and the Dealer and/or Maker Terms shall have the same meaning when used in this Privacy Policy.
1. Definitions and interpretation
In this Policy, the following terms shall have the following meanings:
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition aligns with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR).
“We/Us/Our” Refers to Alesya de Monaco Ltd., a limited company registered in England under company number 15370330, whose registered address is at The Engine Room, 2nd & 3rd Floor, Battersea Power Station, 18 Circus Road Street, London, Greater London, United Kingdom, SW11 8BZ.
2. Information about us
2.1 Our Site is owned and operated by Alesya de Monaco Ltd., a limited company registered in England under company number 15370330, whose registered address is at The Engine Room, 2nd & 3rd Floor, Battersea Power Station, 18 Circus Road Street, London, Greater London, United Kingdom, SW11 8BZ.
2.2 Our VAT number is 469 0469 56
2.3 Our Data Protection Officer can be contacted by email at [email protected], by telephone on +44 7777625582, or by post at The Engine Room, 2nd & 3rd Floor, Battersea Power Station, 18 Circus Road Street, London, Greater London, United Kingdom, SW11 8BZ.
3. What does this policy cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. Your rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What data do we collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.1 name;
5.2 date of birth;
5.3 gender;
5.4 business/company name
5.5 job title;
5.6 profession;
5.7 contact information such as email addresses and telephone numbers;
5.8 demographic information such as post code, preferences, and interests;
5.9 financial information such as credit / debit card numbers;
5.10 IP address;
5.11 web browser type and version;
5.12 operating system;
5.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How do we use your data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and always safeguard your rights under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR). For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 The supply of products and/or services by Dealer and/or Makers to you (please note that Dealer and/or Makers will require your personal data in order to enter into a contract with you for the supply of products);
6.2.2 Personalising and tailoring Dealer and/or Makers products and/or services for you;
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into. You may unsubscribe at any time by clicking the unsubscribe link in our emails or by contacting [email protected];
6.2.5 Market research;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Personal data will be retained for a specific time frame, such as a maximum of two years after the termination of membership, or until it is no longer needed for legal, contractual, or business purposes;
6.5.2 Additional retention periods may apply to specific categories of data as outlined in our internal policies or as required by applicable laws.
7. How and where do we store your data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where such transfers occur, We will take all reasonable and necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy, the UK General Data Protection Regulation (UK GDPR), and, where applicable, the EU General Data Protection Regulation (EU GDPR). These safeguards may include:
7.2.1 Ensuring that the country to which the data is transferred has been deemed to provide an adequate level of protection by the UK Government or the European Commission;
7.2.2 Implementing Standard Contractual Clauses or other approved data transfer mechanisms;
7.2.3 Ensuring that third-party processors adhere to legally binding and enforceable obligations to protect personal data.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Encryption of sensitive data during transmission and storage.
7.4.2 Regular security audits and monitoring of our systems to detect and prevent unauthorised access.
7.4.3 Implementation of access controls to limit who can access your personal data.
7.4.4 Training our staff on data protection principles to ensure compliance with applicable laws.
7.4.5 Incremental backups are performed every three hours to ensure data integrity and recovery in case of any incidents.
7.4.6 Full backups are carried out once a day to provide comprehensive data protection and recovery.
7.4.7 Backups are not directly accessible and can only be retrieved through encrypted SSH connections, restricted to our authorised IP addresses.
7.4.8 Member access passwords are encrypted using a self-destructing key mechanism, ensuring that even we cannot retrieve or know the access passwords of our members.
8. Do we share your data?
8.1 We will not share any of your data with any third parties for any purposes other than:
a) Dealer and/or Makers who require Member’s personal data in order to supply products and services to Members, in which case we will share Member’s personal data with Dealer/Makers to the extent necessary to facilitate the transaction; and
b) Members may require Dealer and/or Makers personal data in order to buy products and services from Dealer and/or Makers, in which case we may share Dealer/Makers personal data with Member’s to the extent necessary to facilitate the transaction,
in the case of (a) or (b) above, We will take all reasonable steps to ensure that the relevant data will be handled safely, securely, and in accordance with the rights and obligations of the parties and Our obligations under the law.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.3 We may sometimes contract with third parties to facilitate the supply by Maker/Dealers of products and/or services to you. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.5 Some of the third-party service providers We use may be located outside the United Kingdom or the European Economic Area (EEA). In such cases, We ensure that appropriate safeguards are in place to protect your personal data, in line with this Privacy Policy and the applicable provisions of the UK GDPR and, where relevant, the EU GDPR. These safeguards may include:
8.5.1 Ensuring third-party compliance with GDPR through binding agreements, certifications, or other legal frameworks;
8.5.2 Utilising secure data transfer protocols and encryption to protect personal data during transit and processing;
8.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What happens If our business changes hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance unless required by applicable data protection laws.
10. How can you control your data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to manage or restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
11. Your right to withhold information
To use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How can you access your data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at [email protected], or using the contact details below in section 13.
13. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [email protected], by telephone on +44 7777625582, or by post at The Engine Room 2nd & 3rd Floor Battersea Power Station 18 Circus Road Street, London, Greater London, United Kingdom, SW11 8BZ. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
14. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.