PRIVACY POLICY

Hadrian AG and its divisions (hereinafter “Hadrian”) understands that your privacy is important to you and that you care about how your Personal Data is used. Hadrian respects and values the privacy of everyone who visits its website (hereinafter “Site”), and will only collect and use Personal Data in ways that are described here, and in a way that is consistent with Hadrian’s obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of the Site. If you do not accept and agree with this Privacy Policy, you must stop using the Site immediately.

Definitions and interpretation

In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by the Site when you visit certain parts of the Site and/or when you use certain features of the Site.
“Personal Data” is defined by the “GDPR” (General Data Protection Regulation – EU Regulation 2016/679) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Information about the owner

The Site is owned and operated by Hadrian AG, a Swiss based company.
Registered address: Baarerstrasse, 10, Zug.

What does this policy cover?

This Privacy Policy applies only to your use of the Site. The Site may contain links to other websites. Please note that Hadrian has no control over how your data is collected, stored, or used by other websites and Hadrian advises you to check the privacy policies of any such websites before providing any data to them.

 What is Personal Data?

Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What are my rights?

Under the GDPR, you have the following rights, which Hadrian will always work to uphold:

  • The right to be informed about the collection and use of your Personal Data. This Privacy Policy should tell you everything you need to know, but you can always contact Hadrian to find out more or to ask any questions.
  • The right to access the Personal Data Hadrian holds about you.
  • The right to have your Personal Data rectified if any of your Personal Data held by Hadrian is inaccurate or incomplete.
  • The right to be forgotten, i.e. the right to ask Hadrian to delete or otherwise dispose of any of your Personal Data that Hadrian has. Please contact Hadrian using the details in Part 15 to find out more.
  • The right to restrict (i.e. prevent) the processing of your Personal Data.
  • The right to object to Hadrian using your Personal Data for a particular purpose or purposes.
  • The right to data portability. This means that, if you have provided Personal Data to Hadrian directly, Hadrian is using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Hadrian for a copy of that Personal Data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about Hadrian’s use of your Personal Data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What data does Hadrian collect?

Depending upon your use of the Site, Hadrian may collect some or all of the following personal and non-personal data:

  • IP address
  • Web browser type and version;
  • Operating system;
  • A list of URLs starting with a referring site, your activity on the Site, and the site you exit to.
How does Hadrian use my Personal Data?

Under the GDPR, Hadrian must always have a lawful basis for using Personal Data. This may be because the data is necessary for the performance of a contract with you, because you have consented to the use of your Personal Data, or because it is in Hadrian legitimate business interests to use it. Your Personal Data may be used for one or more of the following purposes: providing and managing your access to the Site; personalising and tailoring your experience on the Site; improving the user experience and the Site in general.

Third Parties whose content appears on the Site may use third-party Cookies. Please note that Hadrian does not control the activities of such third parties, nor the data that they collect and use themselves, and Hadrian advises you to check the privacy policies of any such third parties.

Hadrian uses the following automated systems for carrying out certain kinds of automated decision-making and profiling. If at any point you wish to query any action that Hadrian takes on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact Hadrian to find out more. The following automated decision-making method(s) may be used: Language selection based on browser language. The following automated profiling may take place: Analytics.

How long will you keep my Personal Data?

Hadrian will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Personal Data will therefore be kept for a maximum of 5 years.

How and where do you store or transfer my Personal Data?

Hadrian may store or transfer some or all of your Personal Data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that Hadrian will take additional steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the EEA and under the GDPR as follows.

Hadrian shares your data within the group of companies and divisions of which Hadrian is a part. Where this involves the transfer of Personal Data outside the EEA, Hadrian group ensures that Personal Data is protected by requiring all companies within the group to follow the same rules with respect to Personal Data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

The security of your Personal Data is essential to Hadrian, and to protect your data, Hadrian takes a number of important measures, including the following: Encryption, DLP, Firewall, Network Segmentation, Intrusion detection systems, …

Do you share my Personal Data?

Hadrian may share your Personal Data with other companies in Hadrian group for special projects. This includes subsidiaries and sister companies.

Hadrian may sometimes contract with the following third parties to supply certain services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your Personal Data that Hadrian holds: Google Analytics, located in the US.

If any of your Personal Data is required by a third party, as described above, Hadrian will take steps to ensure that your Personal Data is handled safely, securely, and in accordance with your rights, Hadrian obligations, and the third party’s obligations under the law.

If any Personal Data is transferred outside of the EEA, Hadrian will take suitable steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the Switzerland and under the GDPR.

In some limited circumstances, Hadrian may be legally required to share certain Personal Data, which might include yours, if Hadrian is involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

Can I withhold information?

Yes, you may restrict the use of Cookies from your browser.

How can I access my Personal Data?

If you want to know what Personal Data Hadrian has about you, you can ask Hadrian for details of that Personal Data and for a copy of it (where any such Personal Data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Hadrian’s administrative costs in responding.

Hadrian will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, Hadrian aims to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date Hadrian receives your request. You will be kept fully informed of the progress.

How do you use Cookies?

The Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Hadrian to better understand how the Site is used. This, in turn, enables Hadrian to improve the Site.

The analytics services used by the Site uses Cookies to gather the required information. You do not have to allow Hadrian to use these Cookies, however whilst Hadrian use of them does not pose any risk to your privacy or your safe use of the Site, it does enable Hadrian to continually improve the Site, making it a better and more useful experience for you.

In addition to the controls that Hadrian provides, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.  It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Changes to this Privacy Policy

Hadrian may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if Hadrian changes its business in a way that affects Personal Data protection. Any changes will be immediately posted on this Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of this Site following the alterations. Hadrian recommends that you check this page regularly to keep up-to-date.