Version: 1.0 Revision Date: 31/01/2025
Administrate Inc., who operates from 220 West Lamme, Suite 3C Bozeman, MT 59715 (“Administrate”, “we,” “us,” or “our”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data about you will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1 Information We Collect
- 1.1 We may collect and process the following data about you:
- 1.1.1 information about you that you give us by filling in details on our website located at the domain name www.getadministrate.com (“our Website”) or by corresponding with us by phone, email, Linkedin, social media (including, but not limited to, Facebook, Twitter, Pinterest, Instagram) or otherwise. The information you give us may include your name, address, email address and phone number, gender, date of birth, financial and credit card information and other relevant information;
- 1.1.2 if you contact us, we may keep a record of that correspondence;
- 1.1.3 if you complete surveys that we use for research purposes (although for the avoidance of doubt you do not have to respond to such surveys), the information which you provide in response to that survey;
- 1.1.4 technical information regarding your visits to our Website including, but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, geographical location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- 1.1.5 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
- 1.1.6 in cases where we have a reason to believe an organization may benefit from our services we may send marketing emails to your work address. In these cases the marketing is assessed as legitimate interest as defined by the GDPR and a risk assessment is performed based on the ICO guidance for a 3-stage test.
2 IP addresses and Cookies
- 2.1 We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and Website quality improvements. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
- 2.2 Our Website may use cookies to distinguish you from other users of our Website. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a more personalised service when you browse our Website and also allows us to improve our Website.
- 2.3 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Website.
3 How we use your personal data
- 3.1 We may use the information which we collect and hold about you in the following ways:
- 3.1.1 to carry out our obligations arising from any contracts entered into between you and us as is necessary for the performance of our contract with you;
- 3.1.2 to provide you with the information and services that you request from us prior to entering into a contract with us;
- 3.1.3 to provide you with information which you request from us as is in our legitimate interest to do so;
- 3.1.4 to answer your enquiries in accordance with our legitimate interests;
- 3.1.5 to maintain our business relationship with you, where you are a user of our Website as a customer in accordance with our legitimate interests;
- 3.1.6 in respect of candidates who have applied to work for Administrate Inc., and its parent company, Administrate, Ltd., to allow us to process and evaluate your application or CV in respect of any job vacancy with us that you have applied for as a step prior to entering into any contract with you;
- 3.1.7 to notify you about changes to our service as is in our legitimate interests to do so;
- 3.1.8 to provide you with information about other services we offer that are similar to those that you have already been provided with where it is in our legitimate interests to do so. You may unsubscribe at any time from receiving further communications from us for these purposes;
- 3.1.9 to provide you with information about services we feel may interest you, any news or industry updates, upcoming events or other information, where you have consented to be contacted for such purposes, or where we have evaluated your business and your role from publicly available sources and have followed a documented process to determine you are likely to have a legitimate interest in the service. You may unsubscribe at any time from receiving further communications from us for these purposes;
- 3.1.10 to ensure that content from our Website is presented in the most effective manner for you and for your computer as is in our legitimate interest;
- 3.1.11 to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes so as to allow us to provide you with the best possible service and experience as is in our legitimate interest to do so; and
- 3.1.12 as part of our efforts to keep our Website safe and secure as is in our legitimate interest;
For the purposes of the above, our ‘legitimate interests’ include the proper administration, monitoring and improvement of our business and the Website, the promotion of our business including direct marketing and the maintenance of the goodwill and reputation of Administrate Inc. which includes the provision of excellent customer service and care.
4 Providing your personal data to others
- 4.1 We may share your personal information with:
- 4.1.1 Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, insofar as reasonably necessary for the purposes set out in this policy.
- 4.1.2 Selected third parties including:
- 4.1.2.1 business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you, which include web hosting facilities, data processors for services like automated emails, and contracted development firms; and
- 4.1.2.2 those who perform functions on our behalf and who also provide services to us such as professional advisors as it is in our legitimate interest to do so.
- 4.1.4 We will disclose your personal information to third parties:
- 4.1.4.1 In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets as part of the sale or purchase process in order to allow such transaction to complete as is in our legitimate interest to do so;
- 4.1.4.2 If Administrate Inc or substantially all of its assets are acquired by a third party or its business merges with another business or company, we may share personal data with the new owners of the business or company or their professional advisers as is in our legitimate interests to do so; and
- 4.1.4.3 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Administrate Inc., our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction as it is in our legitimate interests to do so.
- 4.1.4.4 If we are required, or under a duty to respond, to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
5 Where we store your personal data and international transfers of your data
- 5.1 If you are a resident of the European Union, be aware the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) which has not been confirmed as having adequate levels of protection for personal data from an adequacy decision issued by the European Commission. It may also be processed by staff operating outside the EEA who work for us. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy including ensuring that the transfer is made subject to appropriate safeguards including the use of standard data protection clauses approved by the European Commission.
- 5.2 We and our other group companies have offices and facilities in the U.S.A. and Lebanon. Transfers to the offices in the U.S.A. and Lebanon will be protected by appropriate safeguards. For the U.S.A see clause 5.3 and for Lebanon the use of standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council. All staff are obligated by contract to abide by privacy and security rules laid out by the parent company and are trained on these obligations regularly.
- 5.3 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- 5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
6 Retaining and deleting personal data
- 6.1 We shall ensure that any personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain and delete your personal data for the periods set out in our Retention Policy which you can find at https://www.getadministrate.com/trust.
- 6.2 Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with our legal obligations.
7 For EU Individuals: Your Rights under the General Data Protection Regulation
- 7.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by clicking the unsubscribe link on any marketing communication we send to you by email or by contacting us at the URL https://www.getadministrate.com/data-subject-access-request/
- 7.2 You can exercise the right to request any amendments or rectifications to your personal data by contacting us at Administrate Inc., 220 West Lamme, Suite 3C Bozeman, MT 59715 or at the email address [email protected] or at the URL https://www.getadministrate.com/data-subject-access-request/ if you would like us to delete or erase your data or, in certain circumstances, if you would like us to restrict the manner in which we process your data. Please note in certain circumstances we may not be able to delete or erase your personal data such as where this is still required for the purpose for which it was provided or where we have overriding legitimate interests in retaining your data.
- 7.3 Where you have given us your consent to the specific processing of your personal data please note you have the right to withdraw that consent at any time. Should you wish to withdraw your consent please contact us at the address above. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
8 For California Residents: Your Rights Under the California Consumer Privacy Act
- 8.1 You shall have the right to request that Administrate disclose the following:
- The categories of personal information it has collected about you.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about you.
To make a request, you may either:
- Complete the form on our website: https://www.getadministrate.com/data-subject-access-request/; or
- Send an email to [email protected] with the subject line “CCPA Data Access Request”
To see the categories of information collected and third parties shared, visit: https://www.getadministrate.com/california-privacy-notice/
- 8.2 In regards to selling personal information, the CCPA establishes rights to request and details about data that can be, or has been sold. Administrate does not and has not sold any personal data. If you want to opt out of selling data, no need! Administrate’s practice to not sell personal data already protects you.
- 8.3 Non-Discrimination: Administrate will not discriminate against a you because the you exercised any of the consumer’s rights under, including, but not limited to, by:
- Denying goods or services to you.
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of goods or services to the consumer.
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
- 8.4 Participation in the Data Privacy Framework (DPF) Program:
The U.S.-based entity of Administrate participates in the Data Privacy Framework (DPF) Program, which is an approved mechanism to legally transfer (or access) personal data from the European Union, United Kingdom, and Switzerland to the U.S. The company adopts and abides by the principles set by the DPF, and additional information on the program and its principles, and also our membership details can be found via https://www.dataprivacyframework.gov/. - Administrate Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Administrate Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Administrate Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the DPF Principles and/or the Swiss-U.S. DPF Principles (DPF Principles), the Principles shall govern. To learn more about the Data Privacy Framework Program (DPF Program), and to view our certification, please visit https://www.dataprivacyframework.gov/.
- With respect to personal data received or transferred pursuant to the DPF Program, Administrate is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
- Pursuant to the DPF Program, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the DPF, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.
- We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].
- In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- If you are an EU, UK, or Swiss Individual, where we transfer your personal data to third party service providers who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.
- In compliance with the DPF Principles, Administrate Inc commits to resolve DPF Principles-related complaints about your privacy and our collection or use of your personal information. EU, UK, or Swiss individuals with inquiries or complaints regarding our handling of personal data in reliance on the DPF should first contact Administrate Inc at: [email protected]
- Administrate has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.
- If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.
9 Changes to our privacy policy
- 9.1 Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
- 9.2 Our Website may, from time to time, contain links to and from external websites as a service to our visitors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. The provision of a link on our Website to an external website should not be taken as an endorsement by us of that external website, its owners or their products / services.
10 Contact
- 10.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Administrate Inc., 220 West Lamme, Suite 3C Bozeman, MT 59715 or by contacting us by email at [email protected].