Ada Create Privacy Policy
Introduction
Last modified 18 February 2025
This privacy policy describes how we will collect, use, share and otherwise process your personal data in connection with your use of:
Ada Create (the Platform)
Any of our services that are accessible through the Platform (Services)
Our website https://adacreate.com (the Website)
The Platform is not intended for those under 13 and we do not knowingly collect data relating to children.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
PersuasionXP Limited, company no. 13417973, registered address Little Ashe, Wheatsheaf Enclosure, Liphook, England, GU30 7EJ (PersuasionXP, we, us or our in this notice).
Data privacy manager: jg@persuasionxp.com
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review.
This version was last updated on the date at the beginning of it. It may change and, if it does, those changes will be posted on the Website You may be required to read and acknowledge the changes to continue your use of the Platform or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links and sites
Our Platform and Services will contain links to and from the websites of third parties, such as links to social media sites or other.
Please note that these websites (and any services accessible through them) are controlled by those third parties and are not covered by this privacy notice. You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or use these services.
The data we collect about you
We collect, use, store and transfer different kinds of personal data about you. To make it easier for you to use this privacy notice, we group these into the following categories. Each of these categories is described in more detail
Contact Data: e-mail address and telephone number.
Content Data: any content which is created using the Platform, including video materials, text and photographs.
Cookies Data: the information collected through the cookies and similar technologies listed in our Cookies Policy available here [LINK]].
Device Data: the type of device you use (Device), a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), network information, your mobile operating system, screen type and resolution, the type of web browser you use, the time zone setting.
Direct Marketing Data: information which we collect and store as a result of you being added to our mailing databases.
Financial Data: Stripe or other online banking details, including credit card information.
Identity Data: name, surname, gender, country of residence, date of birth.
Location: details of your use of our Services including, but not limited to, traffic data, statistics of content uploaded, downloaded and viewed. We may make use of location data sent from Devices. You can turn off this functionality at any time by turning off the location services settings for the mobile location on the Device.
Profile Data: e mail address, log-in, password.
Personalisation Data: data about your preferences while using the Platform.
Technical Data: protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Services.
Transaction Data: details required for products and samples to be delivered pursuant to transactions via the Platform.
Technical Data: protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Services.
Usage Data: date of registration on the Platform, personal log-in settings,
We do not intentionally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
We will collect data relating to criminal offences through the measures we take to secure and protect our Platform and users. Further details can be found at Criminal offence data and special category data.
How is your personal data collected?
We collect your personal data in the following way:
Registration. We collect your Identity Data and Contact Data when you register your account with us.
Communications. When you communicate with us via email, telephone, one of our online forms or chat we collect your Contact Data. If you contact us through the Platform using the chat function, we also collect Device Data to operate our chat function and respond to your messages. If the communication relates to an error or problem you are having with the Platform or one of our Services, we will also collect Usage Data for diagnosis and improvement.
Information you generate when using our Platform and Services. Each time you access and use our Platform and Services we collect Content, Device, Cookies, Personalisation and Usage Data. We collect Content Data where you upload it to the Platform or interact with the content available on the Platform. We collect Device, Cookies, Personalisation and Usage Data by using cookies and other similar technologies. Please see our cookie notice [LINK] for further details.
Information we collect through monitoring the use of our Platform, Website and Services. Each time you access and use our Platform and Services we collect information about that access and use, being Device, Content, Cookies, and Usage Data.
Additional information we otherwise collect through our Platform, Website and Services where we have your consent to do so. Where you provide your consent, we collect your Location Data on an ongoing basis while you have the Platform installed on your Device.
Direct Marketing. We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications.
Cookies
We use cookies (small files placed on your device) and other tracking technologies on the Platform and in our direct marketing emails to improve your experience and our development of the Platform and our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy [LINK].
How we use your personal data
We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:
Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by using our cookie banner or contacting us (see Your legal rights below).
Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.
Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.
Account Management and Profiling
Purpose or Activity: Combining the information we collect about you into a single customer account profile.
Type of Personal Data:
Contact
Direct marketing
Lawful Basis for Processing:
Legitimate Interests (to publicize and grow our business)
Delivery and improvement of our Platform and purchases
Purpose or Activity: To permit you to install the Platform and register you as a new Platform user.
Type of Personal Data:
Identity
Contact
Financial
Device
Lawful Basis for Processing:
Performance of a contract
Purpose or Activity: To take steps towards providing you with services at your request, to process and fulfil in-Platform orders/purchases and deliver Services to you, including managing payments and sending you service communications.
Type of Personal Data:
Identity
Contact
Transaction
Device
Location
Financial
Lawful Basis for Processing:
Performance of a contract
Purpose or Activity: Enforce our terms and conditions, including to collect money owed to us.
Type of Personal Data:
Identity
Lawful Basis for Processing:
Legitimate interests (to recover debts due to us)
Direct Marketing
Purpose or Activity: To send you direct marketing communications via email, text, and/or push notification.
Type of Personal Data:
Contact
Device
Direct Marketing
Lawful Basis for Processing:
Consent
Unless we can rely on the soft opt-in and you have not opted out, in which case we rely on Legitimate Interest (to publicise and grow our business)
Troubleshooting, Improvement, and Security
Purpose or Activity: To administer, monitor, and improve our business, Services, and this Platform, including troubleshooting, data analysis, and system testing.
Type of Personal Data:
Identity
Contact
Device
Lawful Basis for Processing:
Legitimate interests (for running our business, provision of administration and IT services, network security, maintaining the security of our Platform and Services, providing a secure service to users, and preventing fraudulent and other misuse of our Platform)
Purpose or Activity: Applying security measures to our processing of your personal data, including processing in connection with the Platform.
Type of Personal Data:
All personal data under this privacy notice
Lawful Basis for Processing:
Legal obligation (applying appropriate technical and organizational measures under Article 32 of the UK GDPR and the EU GDPR)
Rights and Obligations
Purpose or Activity: To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement, and government authorities' requests.
Type of Personal Data:
All personal data under this privacy notice
Lawful Basis for Processing:
Legal obligations
Cookies and Personalisation
Purpose or Activity: To deploy and process personal data collected via Cookies that are strictly necessary as set out in the cookies policy.
Type of Personal Data:
Cookies
Lawful Basis for Processing:
Legitimate interests (delivering and securing the Platform and our Services)
Purpose or Activity: To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in the cookies policy.
Type of Personal Data:
Cookies
Lawful Basis for Processing:
Consent
Purpose or Activity: To deliver (personalized) advertisements to you.
Type of Personal Data:
Personalisation
Lawful Basis for Processing:
Consent
Other Communications
Purpose or Activity: To notify you of changes to the Platform, Services, your purchases, and our terms and conditions for ongoing contracts.
Type of Personal Data:
Contact
Lawful Basis for Processing:
For ongoing or prospective contracts, Performance of a contract
Otherwise, Legitimate interests (in servicing our users and prospective users)
Purpose or Activity: To notify you of updates to this privacy notice.
Type of Personal Data:
Contact
Transaction
Lawful Basis for Processing:
Legal obligation (to inform you of our processing under Articles 13 and 14 of the UK GDPR and the EU GDPR)
Personal Data Sharing
Purpose or Activity: Share personal data with our third-party providers for purposes not otherwise set out above (see Disclosures of your personal data).
Type of Personal Data:
Contact
Transaction
Financial
Lawful Basis for Processing:
Legitimate interests (for the purpose relevant to the recipient, as set out at "Disclosures of your personal data")
Business Contacts
Purpose or Activity: Process personal data relating to staff members of our business contacts, including suppliers, customers, and prospects.
Type of Personal Data:
Contact
Lawful Basis for Processing:
Legitimate interests (servicing and receiving products or services, to or from our business contacts and carry out our B2B business)
Automated decision making and profiling
We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).
Criminal offence data and special category data
We do not intentionally collect criminal offence data about you. However, we may process data relating to criminal offences in monitoring the use of our Platform for security purposes, where we suspect you may have committed a crime, such as attempting to make a fraudulent purchase or claim or circumvent the security of the Platform or Services. In such circumstances we will provide that information to law enforcement and/or use it to establish, exercise or defend a legal claim. In those circumstances, according to the type of activity and purpose, we will rely on legitimate interests (protecting our business, employees and other users) and legal obligation (where required by legal, judicial or law enforcement to disclose or process that information.
Disclosures of your personal data
We may share your personal data with the following third parties:
Internal third parties.
Other companies in the corporate group who provide IT and system administration services and undertake leadership reporting.
External third parties.
Your mobile network operator to allow you to use the Platform on your Device.
Service providers who provide IT and system administration services, hosting services for our Platform, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
Our professional advisors including lawyers, auditors, insurers, and consultants who provide legal, accounting, insurance and other advisory services.
Your service providers that you have appointed and we need to contact to fulfil your requests, such as your banking or payment card provider to process your transactions.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Tax authorities, regulators, law enforcement, public authorities or other third parties based in any jurisdiction where necessary to exercise our rights or comply with a legal obligation.
International transfers
If there are situations where we transfer your personal data between the UK and the EEA those transfers are made pursuant to the UK government's adequacy decision in favour of countries in the EEA and the European Commission's adequacy decision in favour of the UK.
Whenever we transfer your personal data out of the UK and EEA (other than between our group companies), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers located outside the UK or EEA. we use specific contracts which give personal data the same protection it has in the UK and EEA.
Please contact the data privacy manager using the contact details above if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.
Data security
All information you provide to us is stored on our secure servers and located in the UK or EEA. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place procedures to detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.
Data retention
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have the following rights under data protection laws in relation to your personal data.
Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.)
Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.
Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
Restriction. Request that we restrict or suspend our processing of your personal data:
if you want us to establish the data's accuracy;
where our use of the data is unlawful, but you do not want us to erase it;
where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complain to the data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first using the contact details above so that we have the chance to put it right. However, you also have the right to make a complaint to the at any time to the regulator: Information Commissioners Office (ICO) who is responsible for data protection issues in the UK. How you can contact us | ICO.