Website PRIVACY POLICY
Last updated: September 2023
Our commitment to privacy
Your privacy is important to GLP International Data Center Holdings Limited and its affiliates (together, “Ada Infrastructure,” “our,” “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices. This website privacy policy (this “Privacy Policy”) describes how we ather and use personal information and personal data that we collect:
On or through www.adainfrastructure.com and, as applicable, our other websites (together, the “website”);
when you opt to receive communications from us;
about representatives of our vendors, business partners or portfolio companies;
to conduct business with you;
when you apply for a job with us; and
through other data collection points where we refer to this Privacy Policy.
Please read this Privacy Policy carefully. This Privacy Policy constitutes a legally binding agreement between Ada Infrastructure and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, this Privacy Policy, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree with any of the terms and conditions contained in this Privacy Policy, please do not access or otherwise use this website.
Visitors that are residents of California should also refer to our California Website Privacy Policy, which supplements this Privacy Policy, below.
Individuals that are located in the UK, European Union or the European Economic Area should refer to our EU and UK Website Privacy Policy below, which applies to our processing of your personal data if and to the extent that the GDPR (as defined in the EU and UK Website Privacy Policy) applies to such processing.
Individuals that are based in Japan should refer to our Japan Website Privacy Policy below, which supplements this Privacy Policy, below.
Individuals that are based in Vietnam should refer to our Vietnam Website Privacy Policy below, which applies to our processing of your personal data in place of this Privacy Policy.
Individuals that are based in China (excluding the Hong Kong Special Administrative Region (“Hong Kong”)) should refer to our China Website Privacy Policy below, which applies to our processing of your personal data in place of this Privacy Policy.
Individuals that are based in Hong Kong should refer to our Hong Kong Website Privacy Policy below, which supplements this Privacy Policy, and applies to our collection, use, holding and processing of your personal data if and to the extent that the PDPO (as defined in the Hong Kong Website Privacy Policy) applies.
Individuals that are based in Singapore should refer to our Singapore Website Privacy Policy below, which supplements this Privacy Policy.
Categories of Information we Collect and Process and How We Collect It
We collect and process various types of information from users of this website, including, but not limited to:
a) Basic personal details and identifiers: such as name, email address, postal address, title, job title, and telephone number;
b) Internet or other electronic network activity information: such as information regarding your use of our website and geolocation data. We obtain some information about your IP address and web browser that you use to access the website;
c) Images: such as photographs taken at Ada Infrastructure events;
d) Employment information: professional or employment-related information, such as information relating to your job position (e.g., job title, job description and office location), talent management information (e.g., résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information) and emergency contact information;
e) Information received through communications with us: such as information provided through telephone calls and other verbal communications;
f) Marketing and communications information collected about you or that you provide to us: your preferences in receiving marketing information from us and/or our third parties, and/or your communication preferences; and
g) Other information: such as information obtained through publicly available external websites in certain circumstances.
Information You Provide to Us
Ada Infrastructure collects your personal information when you decide to interact with us (e.g., via any contact/communication feature we utilize on the website, when you visit our offices, when you communicate with us over email or the telephone, when you apply for a job with us, etc.).
We may also collect personal information about you, such as your IP address, through automated technology when you access and use our website, such as cookies and similar technology (please see the “Cookies” section below for information about how we use such technologies).
Information Provided by Third Parties or Publicly Available Sources
We collect personal information from third parties, such as a resumé sent to us by a recruiting firm, background information from a background check provider, personal information we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.
If you represent one of our vendors or business partners, we may also collect your personal information (i.e., basic identifying and contact information, including your name, title, work email address, work postal address, job title and/or work telephone number, as appropriate) from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
We process information in relation to companies that we are evaluating in connection with a corporate transaction or potential investment. This information may include your personal information including name, title, email address, postal address, job title, telephone number, passport or other government-issued identification, financial information and/or job and benefits information, as appropriate.
We do not knowingly collect personal information from children under the age of 18. If we are made aware that we have collected personal information from a child under the age of 18, we will delete it as soon as practicable.
Purposes for Collecting Personal Information
We may collect or disclose the personal information we collect about you for one or more of the following purposes:
Purpose | Legal Basis to Process personal data |
To conduct business with you or to provide you with the services or products you have requested, including responding to your enquiries and requests and providing you with support
| Contractual necessity; and/or our legitimate interest in operating our business and providing investment services |
To keep a record of and manage your relationship with us | Our legitimate interest in operating our business and providing investment services; and/or consent
|
To communicate with you, to operate, schedule and facilitate meetings and in relation to your participation in any of our events
| Our legitimate interest in operating our business and providing investment services; and/or consent |
To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) and to conduct conflicts checks
| Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent |
To conduct due diligence and other business activities in connection with an actual or prospective corporate transaction or investment which we are party to
| Our legitimate interest in operating our business and providing investment services; contractual necessity; and/or legal requirement |
To protect against, identify and prevent, fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, assets our business, and other malicious or unlawful activity
| Our legitimate interest in operating our business and providing investment services; and/or legal requirement |
To monitor and manage our portfolio companies
| Our legitimate interest in operating our business; and/or contractual necessity |
Litigation management and conducting internal audits and investigations
| Our legitimate interest in operating our business; and/or legal requirement |
To comply with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you
| Legal requirement; our legitimate interest in operating our business; and/or consent |
To obtain advice from our professional advisors, including lawyers and accountants
| Our legitimate interest in operating our business |
To administer and protect our business and our website
| Our legitimate interest in operating our business; and/or consent |
To make suggestions and recommendations to you about goods or services that may be of interest to you
| Our legitimate interest in operating our business; and/or consent |
For statistical analysis and market research, including to understand how our service may be improved for you (including through our use of cookies), and to improve our services
| Our legitimate interest in operating our business |
For performance of our IT systems | Our legitimate interest in operating our business
|
For any other purpose that has been notified, or has been agreed, in writing
| Consent |
We monitor communications where the law requires us to do so. We also monitor communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect our respective businesses and the security of our respective systems.
Where required by applicable law, we will obtain your consent to send you marketing communications about our products, services, offers and promotions, and to invite you to events and to participate in surveys. You may request that we stop sending you marketing communications by emailing [email protected] at any time.
Disclosure of Personal Information
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
We may disclose any of the categories of personal information we obtain about you as described in the “Categories of Personal Information We Collect and Process and How We Collect It” section above amongst Ada Infrastructure and to service providers and persons employed and/or retained by Ada Infrastructure to fulfil the purposes set out in this Privacy Notice. We use a number of service providers to perform certain services including legal and financial professional advisors, our auditors, recruitment firms, consultants, IT and data security providers, and data hosting providers.
We may also disclose personal information: (1) if we are required or permitted to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government or regulatory agencies, such as law enforcement, tax, and data protection supervisory authorities; (3) to establish, exercise or defend legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.
We do not sell any of the personal information we collect about you to third parties. However, we reserve the right to transfer any personal information we have about you in the event of an actual or proposed sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).
Retention of Personal Information
We retain your personal information for as long as reasonably necessary and proportionate to achieve the purposes and uses set out in this policy, as authorized by law, and to meet legal, taxation, accounting, risk management or business requirements. We may retain personal information for longer where required by our regulatory obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.
How We Protect Your Information
We maintain physical, electronic, and procedural safeguards to prevent unauthorized access to data and to protect the integrity of our systems. We take reasonable steps to protect any personal information that you provide us online by employing appropriate technical and organizational measures. We permit access only by authorized persons who need access to that information to provide services to us and you and who are required to abide by applicable confidentiality and information security practices. Despite the security procedures we employ, you should be aware that it is impossible to guarantee the security of information that you transmit to us via the internet.
Marketing
We may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we have provided to you, on the basis of our legitimate interest in operating our business. You may opt-in to certain kinds of marketing, or all forms of marketing, at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the "opt-out" or "unsubscribe" link provided in all our marketing emails, at any time.
Cookies
Information regarding how you access this website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website.
Subject to your consent (where applicable), the website will place the cookies listed below:
Cookie | Name | Type / Purpose | Duration | More Information |
[DYNSRV Session] | [DYNSRV] | [Essential cookie - This cookie is used for load balancing to manage server traffic demand. Its purpose is to improve the performance of the website.] | [Cookie expires after the session]
|
|
[Cookie Consent] | [cookieconsent_status] | [Preference cookie - A cookie to remember that a user has accepted the cookie disclaimer when the website first loads.] | [Cookie expires after 7 days.] |
|
You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences. You may access any personally identifiable information we have about you by contacting us at [email protected].
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
Further Information
We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post those changes so our users are always aware of what personally identifiable information / personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of this Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy constitutes your acceptance of, and agreement to be bound by, such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you. The examples contained within this Privacy Notice are illustrations only and are not intended to be exhaustive. This Privacy Notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you.
The provisions in our Terms of Use are hereby incorporated by reference.
Contact Us
If you have questions about this Privacy Notice, wish to contact Ada Infrastructure, wish to exercise opt-out rights or submit verified requests, wish to appeal decisions, or wish to make any changes to the personal information you have provided to us, including removing it from a particular subscription list or removing it from our databases, or to access this Privacy Notice in an alternative format, please contact us at [email protected].
Please note that, unless expressly advised otherwise, our website and communication facilities do not provide a means for completely secure and private communications and use. Although we will attempt to keep personal information confidential, from a technical standpoint, there is still a risk. For that reason, use caution when using the website, e-mail and other communication methods to communicate information to Ada Infrastructure that is considered to be confidential.
Our goal is to respond to any verifiable consumer request within the timeframes mandated applicable law, and we will notify you in writing if we cannot meet any such timelines.
No Discrimination: We will not discriminate against you for exercising your rights under the applicable privacy regulations in your jurisdiction.