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Adaptive & Co
Effective date: 1st of January, 2026 Last updated: 10th of August, 2026
1. Who we are
Adaptive and Co Studio Ltd., trading as Adaptive & Co ("Adaptive", "we", "us"), is a company registered in Ireland under company number 575317, with its registered office at Charlemont Exchange, Charlemont Street, Dublin 2, D02 VN88, Ireland.
Adaptive Studio Inc. trading as Adaptive & Co ("Adaptive", "we", "us"), is a Delaware incorporated company in the United States of America.
This policy explains how we handle personal data when you visit adaptiveco.io, contact us, subscribe to our communications, use our online tools, or apply for a role with us. Privacy contact: privacy@adaptiveco.io
2. The two roles we act in
As a controller. For the personal data described in this policy - website visitors, prospective and current clients, subscribers, tool users, and job applicants - we decide why and how the data is processed. This policy governs that data.
As a processor. When we deliver analytics, measurement, and marketing services, we process personal data on our clients' instructions and on their behalf. In that context our client is the controller, their own privacy notice governs, and our processing is set out in the data processing agreement between us. If you believe your data is processed by us as part of a client engagement, contact that organisation in the first instance, or contact us and we will direct your request appropriately.
3. Personal data we collect
You give us:
Identity and contact details: name, job title, employer, email address, telephone number.
The content of your enquiry, message, or correspondence with us
Details submitted through our online tools, including the website address you ask us to scan and the email address you provide to receive results.
Recruitment data: CV, work history, right-to-work information, and anything else you include in an application.
We collect automatically:
Device and connection data: IP address, browser type and version, operating system, and device type.
Usage data: pages viewed, referring source, time on page, and interactions with the site.
Data collected through cookies and similar technologies, as set out in section 5.
We receive from others:
Analytics and advertising data from the platforms named in section 6.
We do not knowingly collect special category data through the website, and we ask that you do not include it in enquiry forms.
4. Why we use it, and our legal basis
Purpose: Responding to enquiries and providing requested information.
Basis: Legitimate interests: responding to people who contact us; or steps prior to entering a contract
Purpose: Delivering services and managing the client relationship
Basis: Performance of a contract; legitimate interests in managing client accounts
Purpose: Sending marketing communications
Basis: Consent, or legitimate interests for business-to-business marketing where permitted. You may withdraw or object at any time
Purpose: Operating and securing the website
Basis: Legitimate interests: keeping the site available, functional, and secure
Purpose: Analytics and understanding site performance
Basis: Consent, where set through our cookie banner
Purpose: Advertising and measuring campaigns
Basis: Consent, where set through our cookie banner
Purpose: Recruitment
Basis: Steps prior to entering a contract; legitimate interests in assessing candidates; legal obligation for right-to-work checks
Purpose: Meeting legal, tax, and regulatory obligations
Basis: obligationsLegal obligation
Where we rely on legitimate interests, we have assessed that our interest does not override your rights, and you may object at any time using the contact details above.
5. Cookies and similar technologies
We use cookies and similar technologies to operate the site, to understand how it is used, and, with your consent, for advertising and measurement.Managing your choices. We use OneTrust to manage cookie consent. Non-essential cookies are set only after you consent. You can change or withdraw your choices at any time through our Cookie Preference Centre and through your browser settings.
Categories we use:
Category & Purpose Set
Category: Performance and analytics
Purpose: Understanding how the site is used so we can improve it
Category: Functional
Purpose: Remembering preferences and enabling embedded content
Category: Targeting and advertising
Purpose: Delivering and measuring advertising, including on third-party platforms
A full, current list of the cookies in each category, with their providers and durations, is available in the Cookie Preference Centre.
Consent signals. We support Global Privacy Control and similar browser-based opt-out signals where required by applicable law.
6. Who we share personal data with
We do not sell personal data. We share it only as follows:
Service providers acting on our instructions, including hosting and productivity infrastructure (Google Cloud Platform and Google Workspace), website hosting Webflow, consent management (OneTrust), and our customer relationship and email systems Hubspot These providers act under contract and may use the data only as we direct.
Analytics and advertising platforms, where you have consented: Google Analytics, Google Ads, Meta, LinkedIn and Microsoft Advertising
Professional advisers including lawyers, accountants, and auditors, where necessary.
Authorities or third parties where required by law, or to establish, exercise, or defend legal claims.
A successor entity in the event of a merger, acquisition, or sale of assets, subject to this policy.
7. International transfers
We are based in Ireland and operate in the United Kingdom and the United States. Some of our providers process data outside the European Economic Area.Where personal data is transferred outside the EEA or the UK, we rely on an adequacy decision where one applies, or otherwise on Standard Contractual Clauses (and the UK Addendum or International Data Transfer Agreement where relevant), together with any additional measures the transfer requires. You may request further information about the safeguards in place using the contact details above.
8. How long we keep it
We keep personal data only as long as necessary for the purpose it was collected for, and to meet legal, accounting, or reporting requirements.
Data & Retention
Enquiries that do not become client relationships
Retention: 24 months
Client records and contract documentation
Retention: Duration of the relationship plus 12 months for legal and tax purposes
Marketing subscriber data
Retention: Until you unsubscribe or object, then a suppression record retained to honour your choice
Website analytics data
Retention: 14 months
Unsuccessful job applications
Retention: 12 months
Consent records
Retention: 12 months
9. How we protect it
We maintain technical and organisational measures appropriate to the risk, including encryption in transit (TLS 1.2 or higher) and at rest (AES-256), least-privilege role-based access, multi-factor authentication, centralised audit logging, mandatory annual security awareness training, and a documented incident response plan. Adaptive holds Cyber Essentials certification, and our hosting infrastructure is independently certified to recognised international standards.No system is completely secure, and we cannot guarantee absolute security of data transmitted to us over the internet.
10. Your rights in the EEA and UK
You have the right to:
Access the personal data we hold about you.
Rectification of inaccurate or incomplete data.
Erasure in the circumstances the law provides for.
Restriction of processing in certain circumstances.
Portability of data you provided to us, where processing is based on consent or contract and is automated.
Object to processing based on legitimate interests, and to direct marketing at any time and without qualification.
Withdraw consent at any time, without affecting processing carried out before withdrawal.
To exercise any right, contact us using the details in section 1. We respond within one month, extendable by two further months for complex requests, and we will tell you if an extension applies. We may need to verify your identity first.
Complaints. You may lodge a complaint with the Irish Data Protection Commission (dataprotection.ie), or with the supervisory authority in your country of residence or workplace. In the United Kingdom, this is the Information Commissioner's Office (ico.org.uk). We would appreciate the chance to address your concern first.
11. Your rights in the United States
This section applies to residents of US states with comprehensive privacy laws, including California, Virginia, Colorado, Connecticut, Utah, and Texas, and other states as their laws take effect.
Sharing for advertising. We do not sell personal information for money. We do use advertising and analytics technologies that build and match audiences on third-party platforms, including Google, Meta, and LinkedIn. Under California law this activity is treated as "sharing" for cross-context behavioural advertising, and the definition of a "sale" is broad enough that it may also apply where value rather than money is exchanged. Other states treat the same activity as targeted advertising. We disclose it here and give you a straightforward way to opt out.
Your right to opt out. You can opt out of this sharing at any time:
Use the "Do Not Sell or Share My Personal Information" link in our website footer.
Or open the Cookie Preference Centre and turn off the Targeting and Advertising category.
Or send a Global Privacy Control signal from your browser or extension. We treat a GPC signal as a valid opt-out request for the browser it is sent from.
Opting out through the banner or GPC applies to the browser and device you use. To opt out across all channels, contact us using the details in section 1.
We collect these from you directly, automatically as you use the site, and from the advertising and analytics platforms named in section 6. The purposes are set out in section 4, and retention in section 8.
Sensitive personal information. We do not collect sensitive personal information for the purpose of inferring characteristics, and we do not sell or share it. We do not knowingly sell or share the personal information of anyone under 16.
Your rights. Depending on your state, you may have the right to know what we collect and how we use it, to access a copy, to correct inaccuracies, to delete, to opt out of sale, sharing, targeted advertising, or profiling with legal effects, and to be free from discrimination for exercising these rights. Exercising them will not result in different pricing, service, or quality.
How to exercise them. Use the opt-out routes above for advertising, or contact us using the details in section 1 for any other right. You may use an authorised agent where the law allows, and we may ask for proof of authority and verify your identity before acting.
Appeals. If we decline your request, you may appeal by writing to us at the address in section 1. We will respond within the period your state's law requires and, where required, tell you how to contact your state Attorney General.
Opt-out preference signals. We honour Global Privacy Control as an opt-out of sale and sharing.
12. Children
Our website and services are directed at businesses and are not intended for children. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, contact us and we will delete it.
13. Automated decision-making
We do not make decisions producing legal or similarly significant effects about you based solely on automated processing.
14. Third-party sites
Our website may link to third-party sites and platforms. We are not responsible for their privacy practices, and we encourage you to read their policies.
15. Artificial Intelligence Systems
Adaptive may use artificial intelligence systems, including large language models, machine-learning tools and other generative or analytical AI systems ("AI Systems"), to facilitate (i) the performance of the Engagement, and/or (ii) certain administrative, analytical, operational or quality-assurance functions.Where Adaptive uses AI Systems in connection with the Engagement, Adaptive shall ensure that all Client information processed in that context is handled confidentially and securely, in accordance with the General Data Protection Regulation EU 2016/679 (GDPR) and the Data Protection Act, 2018. Adaptive shall ensure that no Client confidential information is intentionally used to train, improve, or develop AI Systems unless:
such information has been appropriately anonymised so that it does not constitute personal data or confidential information; or
has obtained the Client's prior written consent for that specific use.
Adaptive shall at all times apply the principle of data minimisation and limit the information processed by AI Systems to what is strictly necessary for the relevant purpose.Adaptive will review, validate and assess all outputs generated by AI Systems before using such outputs for the purpose of the Engagement or providing such outputs to the Client. Adaptive acknowledges that AI Systems may occasionally generate inaccurate or incomplete content and that such content will not be relied upon without further human review and verification by Adaptive.Further information about Adaptive's processing of personal data, including in connection with the use of AI Systems, is set out in Adaptive's privacy notice , as updated from time to time and available upon request. The Client shall be provided with a copy of Adaptive's Privacy Notice upon Engagement or as soon as practicable thereafter.
16. Changes to this policy
We may update this policy from time to time. The effective date at the top shows when it last changed. Where changes are material, we will provide a more prominent notice.
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