Copyright ©ADIT 2020

This statement last updated at 01.07.2020

We Respect Your Privacy & Business Personal Data
ADIT is the controller of any business personal data collected by or disclosed to the ADIT business or the ADIT website.

The ADIT privacy policy has 8 parts

A Cookies Policy

B ADIT & Your Business Personal Data

C How You Can Access & Correct Your Business Personal Data

D Privacy & Safe-Guarding

E Acquisition or Changes in Ownership

F Our Commitment to Data Security

G Legally Compelled Disclosure of Business Personal Data &/or Linked Information

H Privacy Policy Statement Modification Notice

A. Cookies Policy

Our Website makes use of tracking technology called “cookies”, in order to
gather anonymous statistical information about site use.

A1. The 3 cookies currently placed by this website are:

_jsuid
This anonymous cookie holds a random number generated the first time someone from a particular ip address visits the website.
Its purpose is to identify new visitors to the website.
If not deleted by the user’s browser at end of session it will expire after 13 months

_referrer_og
This anonymous cookie name is associated with Website Analytics.
Its purpose is to better identify new and unique visitors to the website.
It stores the external referrer for a visitor, eg Google, etc so that on future visits the same referrer will be attached to the same unique user.
Works with _jsuid
If not deleted by the user’s browser at end of session it will expire after 13 months

_ga
This anonymous cookie is associated with Google Universal Analytics.
This cookie is used to distinguish unique users by assigning a randomly generated number as a visitor identifier.
It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
If not deleted by the user’s browser at end of session it will expire after 24 months

NB – Other cookies may be detected by the user that were not placed by this website.
What those cookies are will depend on the browser used and any prior settings eg being logged into a Google account.

A2. In using this website you accept the use of these anonymous cookies.

This website will still function correctly if your browser is set to block third party cookies.

Cookies can be deleted from your computer through your web browser settings.
Instructions or instructional videos on how to block or clear cookies can be found through your web browser search box.

A3 What Are Cookies?

In our case, a cookie is a way of detecting unique visits & recording the popularity of pages selected.
The cookie trail describes an anonymous visitor’s behaviour on the website.

A cookie is a small text document, which often includes an anonymous unique identifier (the “visitor”).

When you visit a Website, that site’s server asks your computer for
permission to store this file in a part of your hard drive specifically designated for cookies.

Each Website can send its own cookie to your browser if your browser’s preferences allow it,
but (to protect your privacy) your browser only permits a Website to access the cookies it has
already sent to you, not the cookies sent to you by other sites.

Cookies DO NOT allow us to gather any personal data (for example, biographical information) about you.
And
We DO NOT store mirror copies of cookie trails for future data processing or disclosure.
And
We DO NOT process cookie data in order to make an implicit link to business personal data.

A cookie cannot retrieve any other data from your hard drive or pass on computer viruses.

Browsers are usually set to accept cookies by default.

However, if you would prefer not to receive cookies, you may alter the configuration of your web browser.

A4. How Do We Use Anonymous Cookie Information?

As you visit and browse our Website, the site cookies anonymously record pages visited.

Cookies, in conjunction with our web server’s log files, allow us to calculate the
aggregate number of people visiting our Website and which parts of the site are most popular.

This helps us gather feedback to improve our Website and better serve our visitors and customers.

A5. IP Addresses

IP addresses are used by your computer every time you are connected to the Internet.

Your IP address is a number that is used by computers across the internet to identify your computer.

IP addresses are automatically collected by our web server as part of demographic & profile data
known as traffic data and so that data (such as the Web pages you request) can be sent to your computer.

An IP address identifies the general geographic location of the computer you are using.

The IP address is a set of numbers. It does not contain any personal data about you.

We DO NOT store IP addresses for data processing or disclosure.
And
We DO NOT process IP address data in order to make an implicit link to business personal data.

A6. Web Server Log Files & IP Addresses

We make use of anonymous web server log files, in order to learn statistical information about our website.

For example, number of visitors, geographical location, pages visited, etc.

We DO NOT store web server log files for any data processing or disclosure purpose.
And
We DO NOT link Web Server Log Files &/or IP address data to any business personal data we may hold.

B. ADIT & Your Business Personal Data

B1. The Brands We Represent, Sell & Communicate Business to Business are:

<ADIT Logo>

ADIT is the exclusive UK trade representative of
Zwiesel Kristallglas AG brands

<Schott Zwiesel Logo Zwiesel 1872 Logo Jenaer Glas Logo Zwiesel Glas Logo>

Schott Zwiesel | Zwiesel 1872 | Jenaer Glas | Zwiesel Glas

And

ADIT is the exclusive UK & Eire trade representative of

<Fortessa Inc Logo>

Fortessa(r) Inc

ADIT market, sell & communicate the brands we represent business to business.

B2. Legitimate Interest in Holding & Processing Business Personal Data

This relates specifically to the Business Personal Data we collect day-to-day through
our business ADIT / ADI Trading Limited including emails sent to e.g. Person@aditrading.com.

These data are not stored on this website.

Our legitimate interest, in holding and processing business personal data, is communication with
individuals in their capacity as a business person fulfilling a role for a corporate entity.

The businesses we interact with generally operate in, or service, the Catering, Drinks,
Hospitality, Retail and Wine trades.

It is our legitimate interest to process business personal data for the purpose of:

a) The communication of relevant information about the brands we represent
to business people who are:

enquirers
specifiers/proposers
influencers
decision makers
buyers & accounting staff
corporate end-users
of our brands’ products & services

b) The progression of business enquiries, sales, product/service fulfilment, deliveries and
after sales activity related to our business.

c) Informing influencers & commentators about our brands’
products & services.

B3. Privacy Policy Statement for Business Personal Data

We’ve created this statement of privacy policy to demonstrate our commitment
to the reasonable use and privacy of business personal data.

This statement is designed to help you understand how we collect, process, use and
safeguard business personal data provided to us or researched by us
(from public and commercial sources) in the course of our business.

We will extend this privacy policy in the light of new technologies, business practices
& our enquirers/customers’ needs.

B4. What Business Personal Data Do We Collect & Why?

It is our legitimate interest to collect & process business personal data about people:

• in their business capacity from published public or commercial sources.
• when they (or their commercial representative) interact with ADIT for enquiry, sale or registration
• from their business cards
• if they enter data to an online form published by us

The business personal data (BPD) we will collect and rely on during the course of our
business is limited to some or all of the following data:

BPD – Initial/Forename
BPD – Surname
BPD – Linked Personal mobile phone number (where given)
BPD – Linked Job Title
BPD – Linked BUSINESS Email address
BPD – Linked PERSONAL Email (where given)
BPD – Linked Area(s) of interest (where known)
&
– A place of business address (where known)

WE DO NOT process business personal data in order to link anonymous data like
IP addresses, cookie trails or survey data to an individual’s business personal data.

B5. Request a Data Access Report

For a Data Access Report, showing the business personal data we may hold about you,
please see section D below.

B6. Inbound Email Content Linked to Business Personal Data

If you choose to correspond with us through email, we may retain the content of
your email messages together with your business personal data and our responses.

We take care with these data. However, you are advised that email is an insecure
form of communication and you should never disclose sensitive personal data
(for example your date of birth or personal banking details) in any email communication sent to us.

B7. How Do We Use Business Personal Data?

It is our legitimate interest to process & use business personal data in order to deliver
information on the design, commercial aspects & economic benefits of the brands, goods &
services we provide, that we reasonably believe are relevant to:

– that person and/or
– the job function they perform and/or
– the business they are in

B8. Opt out or Un-subscribe

All of our outbound communications implicitly or explicitly offer the recipient the means
to “opt-out” or unsubscribe from receiving communications from us & the brands we represent.

B9. Business Personal Data & Third Parties

We do not sell or lease any business personal data we have collected.

Where relevant, it is our legitimate interest to share business personal data with third
parties in order to perform commercial tasks such as the fulfilment of sales enquiries,
the performance of sales-administration, deliveries and the like.

We will also share business personal data as required by law enforcement.

B10. How long do we keep Business Personal data for?

In the case of business personal data collected during public record research,
at exhibitions, from enquiries & sales administration, we retain that data until a person has:

• opted-out of a communication channel
• notified change of job role or we detect that
• they are gone away i.e. left a business.

All of our outbound communications implicitly or explicitly offer the recipient the means
to “opt-out” or unsubscribe from receiving communications from us and the brands we represent.

B11. Business Personal Data AND This Website

a) Linkable Data

Business Personal Data, email addresses and content are not held on the same server as Aditrading.com website

We do not process business personal data in order to link it to IP address (geographical location),
website Cookies (browsing habits e.g. areas of interest) & other web browsing logs.

C. How To Access & Correct Your Business Personal Data &/or Linked Information

We may disclose business personal data & linked information when legally compelled to do so.
In other words, when we, in good faith, believe the law requires disclosure
for the protection of our or others’ legal rights.

C1. How Can You Access & Correct Your Business Personal Data?

You, as the data subject, may request a Data Access Report showing your business
personal data (BPD) that we may hold and process.

Contact us by email at

include in the subject line “Attention Data Protection Officer”.

You must include a relevant street address.

We will not disclose business personal data by email or telephone.

With the exception of disclosure to law enforcement officers, we will not disclose
business personal data to a person other than the named data subject.

We will provide the Data Access Report within 14 days.

C2. Please note, the business personal data (BPD) we will disclose, if held by us, is limited to some or all of the following data types:

BPD – Initial/Forename
BPD – Surname
BPD – Linked Personal mobile phone number (if known)
BPD – Linked Job Title
BPD – Linked BUSINESS Email address
BPD – Linked PERSONAL Email (if known)
BPD – Linked Area(s) of interest (if known)
&
– A place of business address (where known)

We Do Not process data in order to link cookie trails, IP addresses, web browsing data
or anonymous survey responses to Business Personal Data.

D. Privacy & Safe-Guarding In Relation To This Website

D1. Website – Links to/from other Websites

What about Other Websites with Links To/From Our Website?

We are not responsible for the practices employed by websites linked to or from our Website.

Nor are we responsible for the information or content contained within websites
linked to or from our Website.

Links to other websites are provided solely as pointers to information on topics
that may be useful to the users of our Website.

Please remember that when you use a link to go from our Website to another
website, our Privacy Policy is no longer in effect.

You’re browsing/interaction on any other website is subject to that
website’s own rules and policies.

Please read those rules and policies before proceeding to explore the third party website.

D2. Online Forms – Self-selected Marketing Communications

This relates to the capture of business personal data through online forms published
at this website or third party websites e.g. Online Survey Providers.

Entering these data is voluntary.

We will store & process these data on the reasonable assumption it has been
entered by the person identified in the data.

D3. Opt-In/Opt-Out by Channel of Communication

Service Provision

Where we are fulfilling a service after online registration we will communicate by email, telephone or
mail in order to fulfil that service only.

In addition the person registering will have the opportunity to opt-in to channels of
communication they may prefer contact by in the future.

Marketing Interaction & Communications

Marketing interactions & communications covers activities such as newsletter registration
or survey participation, among others.

If the online activity is not anonymous, at registration we will provide, as relevant,
an opt-in form covering the use of business personal data & marketing communication channel preferences.

We will collect these business personal data on a double opt-in basis.

That means: A person registers through an online form (Opt-in 1) to receive e.g. email newsletter from us.

The subscriber will then receive a welcome email through which they must “click through a link”
in order to activate their subscription (opt-in 2).

Outbound email or paper communications from us will include an opt-out or unsubscribe link.

After unsubscribing we will discontinue sending business to business messages
as soon as technically feasible, certainly within 30 days.

D4. Special Note about Children

Nothing on this website is harmful to children.

Children are not eligible to register any personal data on any online form we may publish.

We ask that children (under the age of legal consent in your country) do not submit
any personal data on this website for any purpose.

D5. Business Personal Data Collected at this Website & Third Parties

We do not sell or lease any business personal data.

Where relevant, we do share business personal data with third parties in order to
perform commercial tasks such as the fulfilment of sales enquiries, the performance
of sales-administration, deliveries and the like.

We will also share business personal data as required by law enforcement.

E. Acquisition or Changes in Ownership

In the event that ADIT and/or this Website (or a substantial portion of its assets)
is acquired by a third party, business personal data would be considered part of
those assets, and may be part of those assets that are transferred.

F. Our Commitment to Business Personal Data Security

F1. Managing the Store & Processing of Data including Business Personal Data

To prevent unauthorized access, maintain data accuracy, and ensure the correct use
of information, we have put in place appropriate physical, electronic, and managerial procedures
to safeguard and secure the business personal data we control and process.

If, for some reason, we suffer a data breach we will inform individuals, who may be affected.

G. Legally Compelled Disclosure of Business Personal Data
&/or Linked Information

We may disclose business personal data & linked information when legally compelled to do so.
In other words, when we, in good faith, believe the law requires disclosure
for the protection of our or others’ legal rights.

H. Privacy Statement Modification Notice

We reserve the right to amend this statement of privacy policy at any time without notice.

/ends