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CA Privacy Supplement - Adaptas Solutions LLC

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In addition to the Adaptas Solutions LLC’s Privacy Notice for Sisweb (“Sisweb Privacy Notice”), this California Privacy Supplement provides supplemental information for consumers who are residents of California, USA, about Adaptas’ collection, use, disclosure, and retention of personal information obtained in connection with their dealings with Adaptas in the preceding twelve months from the effective date of this Supplement (i.e. from 31st July 2025).

This California Privacy Supplement should be read together with the Sisweb Privacy Notice and Cookies Notice and will be applicable exclusively to California consumers. In the event there is any conflict or inconsistency between the terms and provisions of the Sisweb Privacy Notice and the terms and provisions of this California Privacy Supplement the latter shall prevail and govern the rights, duties and obligations of the relevant users based in California.

We reserve the right to update and modify this California Privacy Supplement at any time and for any reason. You are encouraged to periodically review this document to stay informed of updates (please see the date at the end of this document for the most recent update).

1. Business purposes for collecting, using and retaining your personal information

Adaptas typically collects, uses, processes and retains your personal information for the following lawful business purposes -

CodeBusiness Purpose
1.To advertise and market our products and services: to identify prospects and assess the best products for your organization, and analyse existing and new requirements including through sponsored events and tradeshows
2.To provide products and services including online and support services: to deliver products to physical locations, to deliver online and support services including to monitor the usage of our online or support services, to manage your registration as a user of our online or support services.
3.For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or products and services you have purchased on behalf of your own organization.
4.To contact you: to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted online or support services, including the security updates, when necessary or reasonable for their implementation.
5.To provide you with news: special offers and general information about other goods, products and services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
6.To manage your requests: to attend to and manage your requests to us.
7.For business transfers: to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our products and services users is among the assets transferred. For the avoidance of doubt, such transfers are not considered “sales” under the California Privacy Rights Act.
8.For other purposes: we may use your personal information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products and services, products, products and, marketing and your experience.
9.To conduct required legal checks or meet legal requirement: we may use your personal information to undertake required compliance checks to meet legal requirements including local and global trade compliance and anti-corruption requirements. We may also use information as necessary to comply with security, health and safety and other laws.
10.For product research and improvement: we may use your feedback, information from your use of products or invite you to participate in customer research groups to improve our products and services.

2. Categories of personal information collected by us

In the preceding twelve months from the effective date of this Supplement, Adaptas has collected the following categories of personal information and used them for the following business purposes. Note that some personal information may appear on more than one category.

 

Category of personal information collected

Examples of personal information collected in such category

Business purpose code (as given in Section 1)

Disclosures in previous 12 months

 

Service Providers

Sale or Sharing

A. Identifiers.

Names, contact information, postal address, unique personal identifier, online identifier, email address, account name, Social Security number, driver s license number, signature.

1

2

3

4

5

6

7

8

9

10

Y

N

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver s license or state identification card number, insurance Notice number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information.

1

2

3

4

5

6

7

8

9

10

Y

N

 

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex sexual orientation, veteran or military status.

1

2

3

4

5

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8

9

10

Y

N

 

D. Commercial information

Property, products or products and purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

1

2

3

4

5

6

7

8

9

10

Y

N

 

E. Biometric information.

N/a

 

N/a

N/a

 

F. Internet or other similar network activity

 

Browsing history, search history, information about consumers interaction with Adaptas or other websites or applications

 

1

2

3

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5

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9

10

Y

N

 

G. Geolocation data.

IP address and/or GPS location (latitude & longitude) recorded via browsers, mobile apps etc.

1

2

3

4

5

6

7

8

9

10

Y

N

 

H.  Audio, electronic, visual, thermal, olfactory, or similar information.

 

Photographs or CCTV video footage captured during your employment. Temperature checks at sites for visitors as required for infection control.

1

2

3

4

5

6

7

8

9

10

Y

N

 

I.  Professional or employment-related information.

 

Professional data for sales and marketing purposes. For conducting compliance checks as required by law including anti-bribery and corruption laws.

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2

3

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5

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7

8

9

10

 

 

Y

N

 

J.  Education information

Education records maintained by schools / colleges you attended such as grades.

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2

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5

6

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8

9

10

Y

N

 

K.  Inferences drawn from categories above to profile consumer s preferences, characteristics etc

Analytics used to assess and score whether a consumer is likely to purchase products or services.

1

2

3

4

5

6

7

8

9

10

Y

N

Note: some categories of personal information (e.g., education records) are collected solely in the context of employment or recruitment and are not applicable to general website users or customers.

3. Disclosure of your personal information

Adaptas may disclose your personal information for the business purposes to Adaptas’ affiliates, contractors and to products and services providers and advisors who require the personal information data to assist us in supporting our business (e.g. CRM platforms, ordering and logistics companies enterprise technology platforms, legal advisers). These entities are subject to written contracts and authorized to use your personal information only as necessary to provide these products and services to Adaptas. Adaptas also discloses personal information to third parties where required or permissible by applicable law to perform our legitimate business activities. Some of these third parties may use this information for the purposes of serving relevant advertisements and/or sell that information to other businesses for advertising and other purposes.

You can opt out of such selling or sharing of your personal information by completing the attached form California Request Form.

4. Retention and deletion of your personal information

Adaptas retains your personal information only for the time required to fulfil the business purposes outlined in Section 1 of this Supplement. For further details on retention and deletion, please see Section 5 of the Sisweb Privacy Notice.

5. Your rights

In addition to the statutory rights outlined in Section 9 of the Sisweb Privacy Notice, all California residents are provided certain additional rights with respect to their personal information under the California Consumer Privacy Act 2018 (“CCPA”). These are –

  • a) The Right to Know

    You have the right to request the following information relating to your personal information we have collected and disclosed in the last 12 months:

    • The categories of personal information we have collected about you;
    • The categories of sources of the personal information;
    • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
    • The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
    • The business or commercial purposes for collecting or, if applicable, selling the personal information.
    • Copy of specific pieces of personal information we have collected from you;
  • b) The Right to Request Deletion

    You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

  • c) The Right to Correct

    You have the right to request that Adaptas correct inaccurate information processed by Adaptas (e.g., to ensure Adaptas has correct and current contact details in its payroll system). Note that this right is subject to some limitations.

  • d) The Right to Opt-out of Sales / Sharing

    You have the right to opt out of sale or sharing of personal information.

  • e) The Right against Non-discrimination

Adaptas will not discriminate against you for exercising any of your CCPA rights.

To exercise your rights under CCPA, please contact Adaptas Solutions LLC. Please specify in your request what personal information you would like to access, correct, opt-out or delete (or complete this California Request Form).

We will first acknowledge receipt of your request within 10 business days after receipt of your request. We will provide a substantive response to your request within 45 calendar days after its receipt. If we require more time (up to 90 days or the permitted timeframe), we will inform you of the reason and extension period in writing.

Only you or an authorized agent (as described below) may make a verifiable consumer request related to your personal information.

  • How to Authorize an Agent: You may designate an authorized agent to submit your verified consumer request on your behalf, only if the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.
  • How We Verify your Request: To respond to your request, we must verify your identity or the authority of your authorized agent. We will only use the personal information provided to us in context to verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us. To allow us to verify your request, we will require that you provide at least two pieces of personal information, including your email address and phone number, that we already have in our possession. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud.

6. Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to dataprotection.US@imi-precision.com with the subject line “Shine the Light Request”

7. Contact us

Please contact us as follows or in accordance with the “Contact Us” section of the Sisweb Privacy Notice.

This Privacy Notice Supplement was last updated August 2025.