We mind your privacy

Adaptive Cybersecurity Practices (hereinafter: ‘ACP’) is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.acpsec.com (“Website”), you accept and consent to the practices described in this policy. If you don’t accept the terms of this policy, please refrain from using the Website. Your personal data is controlled by Adaptive Cybersecurity Practices , a business registered in Spain whose registered office is at Navalcarnero, Madrid. Our local Data Privacy Officer can be contacted using the following email address: dpo@acpsec.com.

Information we may collect and hold about you

 We may collect and process the following personal data about you: 

– Information you’ve provided to us, such as your name, email address, and phone number. You may give us information about you by filling in forms on the Website or by corresponding with us by phone, email or otherwise.

This includes information you provide when you:

– ask us to contact you in relation to services we provide;

– subscribe to our mailing lists, newsletters or bulletins;

– order services from us;

– report a problem with our Website.

We may also collect information when you visit the Website, including but not limited to your IP address, location, time of access, the browser you use, your operating system and the pages you visit.

How long do we retain your information

 If we are providing services to you, we will retain your personal information for the duration of the services and for 4 years thereafter, unless otherwise agreed. When you visit our Website, you will be asked whether you consent to the use of Cookies. If you consent, we will retain the information collected about you in accordance with the retention periods outlined in our Cookie Policy. Unless otherwise set out in this privacy policy, any other information we process about you will be retained by us until we no longer need it for the purposes for which it was collected, as set out in this privacy policy and/or the relevant fair processing notice. We will base that decision on a number of criteria, including whether we are required by law to keep the information for a certain period of time, whether you have withdrawn consent to the processing, whether a contract has been performed and the likelihood of us needing to retain the information in the event of a claim arising, whether the data is still up to date, and whether there are exceptions set out in the applicable data protection legislation that allow us to retain the personal data for a longer period or indefinitely. We will review and delete or destroy personal data on a regular basis. If we are unable, using reasonable endeavours, to delete or destroy personal data we will ensure that the personal data is encrypted or protected by security measures so that it is not readily available or accessible by us.

How we may use your information

 In addition to using your information to fulfil our contract to provide you with requested services, we may also use your information in the following ways: 

– to monitor and improve our, services and the Website;

– to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about or that we feel may be of interest to you;

– to notify you about changes to our services;

– to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

– to enable us to comply with any legal or regulatory requirements.

The basis on which we collect your information

 We collect much of your information on the grounds of: (1) legitimate interests (for example, to send you direct marketing about services similar to those you have purchased from us or negotiated or enquired about; and (2) fulfilment of a contract with you (for example, to provide you with services you have purchased from us). If we require your personal data for fulfillment of a contract with you (for example, to provide services to you or to receive payment from you), we may be unable to fulfill the contract without your personal data. If we are unable to rely on legitimate interests, fulfillment of a contract or any other ground set out in the General Data Protection Regulation 2016/679 (“GDPR”) to process your personal data, we will obtain consent from you to the processing. This will be the case if, for example, you download documentation from us and we would like to send you marketing communications about our services. If you give us your consent, you can withdraw it at any time by emailing dpo@acpsec.com. . Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.

Sharing your information

 We will NOT share your information unless we are legally enforced to disclose or share your personal data in order to comply with any legal obligation.

Where we store your personal data

 We store the data that we collect from you while using this Website in the European Union (EU) and will not be transferred to another destination outside of the EU. We will take all steps reasonably necessary (security and privacy controls) to ensure that your data is protected accordingly and in agreement with this privacy policy.

Your rights

 Access to your data
You have the right to ask us to confirm that we process your personal data, as well as to have access to and receive copies of your personal data. We will provide this information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We will provide the information you request as soon as possible and in any event within one month of receiving your request. In order to make sure we provide this information to the right person, we may ask you to identify. Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate for us to do so, in which case we’ll let you know why. We’ll also let you know in time if we need more time to comply with your request. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you: 

– where we no longer need your personal data for the purpose for which we collected it;

– where we have collected your personal data on the grounds of consent and you withdraw that consent;

– where you object to the processing and we don’t have any overriding legitimate interests to continue processing the data;

– where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and

– where the personal data has to be deleted to comply with a legal obligation.

 Right to restrict processing
In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you: 

– if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;

– if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;

– if the processing is unlawful; or

– if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

 Data portability
Where Adaptive Cybersecurity Practices acts as a Data Controller, you have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another Data Controller. This right only applies: 

– to personal data you provide to us;

– where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and

– where we carry out the processing by automated means.

We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know. Right to object
You are entitled to object to us processing your personal data: 

– if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;

– for direct marketing purposes (including profiling); and/or

– for the purposes of scientific or historical research and statistics.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defense of legal claims. If you would like to exercise any of your rights in respect of your personal data, please contact us at dpo@acpsec.com.

Changes to our privacy statements

 Any changes we may make to our privacy statements in the future will be posted on the pages of our website and, where appropriate, notified to you by e-mail. Please check the relevant statements regularly to remain updated with any changes to our privacy statements.


The Adaptive Cybersecurity Practices website may, from time to time, contain links to and from the websites of other business and/or advertisers. If you follow a link to any of these websites, please note that these websites have their own privacy & cookie policies and that we do not have any influence regarding their policies. We therefore cannot accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Contact with our Privacy Department

 Last update: October 2020 Questions, comments and requests regarding these privacy statements are embraced and can be addressed to dpo@acpsec.com.