Privacy Policy

Introduction

This privacy policy gives you information about how we, Accelera Digital Group (ADG), collect and use personal data, including any data you may provide when we provide our services. Reference to your personal data in this policy includes all personal data you provide to us, including personal data relating to your staff, consultants, agents and customers.

ADG is made up of different legal entities, including ADG (PTY) LTD, ADG ENVEZA DMCC and ADG VELENTE LTD. This privacy policy is issued on behalf of ADG so when we mention ADG, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in our group which is responsible for processing your data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. Our DPO may also be referred to as our Information Officer. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section of this policy.

The types of personal data we collect

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone settings and locations, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our services.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our platforms, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data (which is not personal data) to help improve our service offering.

How is personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms, using our services, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services, create an account on our platforms, use our services, or give us feedback or contact us.
• Automated technologies or interactions. As you interact with our services, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
• Third parties or publicly available sources. We will receive personal data about you from various third parties such as analytics providers, our third-party licensors, providers of technical, digital or payment services, aggregators, or publicly available sources.

How we use personal data

We only collect personal data where we have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the services under a contract we have with you or need to collect or use personal data in order to offer, provide a quote for, amend or adapt our services.
• Legitimate interests: We may use personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to protect your data and enable us to give you the best and most secure customer experience.
  We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. If we have entered into a service agreement with you then you are deemed to have provided consent for us to use your personal data as expressly set out in such agreement.

Purposes for which we use personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so.

We have also identified what our legitimate interests are where appropriate. We may also need to use your data as required by law, we will inform you of this unless the law restricts us from doing so.

Disclosures of personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• Internal Third Parties: meaning other entities within our group of companies or its employees. In such cases there will be a duty of confidentiality.
• External Third Parties: meaning other entities who may provide services on our behalf or our third- party licensor such as Sage, Click-Up, Google Cloud and others. In such cases either you or we will have entered into a data protection arrangement with them.

• Other 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 policy.

  We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Unless we have your consent, we do not allow our external third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  In some cases, our products and platforms may include links from third parties. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or their collection of your personal data. We encourage you to read the privacy policy of every website you visit and check with the relevant third parties how your data will be collected and used.

International transfers

We may share your personal data within our group. This will involve transferring your data out of country. Whenever we transfer your personal data out of country, we always ensure that a similar degree of protection is afforded to it by ensuring that this policy applies together with our Data Protection Policy.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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 a number of rights under data protection laws in relation to your personal data including the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

  • 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 you need us to hold the data even if we no longer require it as you need 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.

  If you wish to exercise any of the rights set out above, please contact us.

Contact details

If you have any questions about this privacy policy or about the use of your personal data or want to exercise your privacy rights, please contact us by email at legal@adg.io.

You have the right to make a complaint at any time to the relevant data protection regulator however, we would appreciate the chance to deal with your concerns so please contact us in the first instance.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on 7 April 2025.

Changes to personal data

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 your relationship with us, for example a new contact number or email address.