Privacy Policy
INTRODUCTION:
This website is owned and operated by Aste Able Tech SRL Ltd
We committed to protecting the privacy of our customers. Accordingly, we adhere to the EU General Data Protection
Regulation ((EU) 2016/679) ("GDPR") and any applicable industry and regulatory guidelines. We regularly review and
update our Policy and procedures to ensure the safety and protection of personal information in our possession.
the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- Personal Information we collect
You may access certain areas of the Website without providing any personal information at all. However, to use all
features and functions available on the Website you may be required to submit certain personal information.
Without limitation, we may collect any of the following personal information (which is information that identifies you or
relates to you as an identifiable person) from time to time:
- Information you provide us
We collect personal information on the Website when Users choose to reveal it to us. For example, when you register
an account with us, when you sign up to attend an event, when you contact us to request a demonstration of our
products or services, when you otherwise send us questions, we will collect personal information such as name,
email address, telephone and fax numbers, username, password, job title and role, professional contact details, postal
address and postcode, preferences and interests, financial information such as credit / debit card numbers, feedback
on our products or services.
Where you choose to provide it, we may collect sensitive personal information on the Website, such as dietary
requirements, sensory and diagnosis information, (or other health related data).
-  Personal Information collected automatically
We may collect common information found in communications sent over the Internet, from which we can often infer
such things as: (1) browser type (e.g., Chrome or Internet Explorer); (2) operating system (e.g., Mac OS or Windows);
(3) browser language (e.g., English or Spanish); (4) Internet Protocol (IP) address; (5) Internet Service Provider (e.g.,
BT); (6) geolocation and (7) a list of URLs starting with a referring site, your activity on this Website, and the site you
exit to (automatically collected). This information may be personal information.
-  Personal information used to contact you and for Marketing
When you sign up for our Services on our Website, we will use your name and email address to send newsletters
and other useful information to you regarding our Services. You may at any time choose to stop receiving our
newsletter or marketing emails by following the unsubscribe instructions included in the emails you receive
Use of personal information
We will only use personal data when the law allows us to. Most commonly, we will use your personal data if:
· we need to so we can perform the contract we are about to enter into or have entered into with you;
· it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not
override those interests; or
· we need to so we can comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing personal data other than in relation to sending
direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing
at any time by contacting us
However if you provide us with sensitive personal data you consent to us processing it for the performance of a contract
we are about to enter into or have entered into with you, to identify types of customers for our products and services,
and to develop our business and to inform our marketing strategy.
The information we collect through our Website helps us to provide you with the best possible services and experience
when using our Website, to identify ways that we can continue to serve our customers in the best way possible and for
the reasons set out in the table below. We have also identified the legal basis on which we rely to process your
personal data as well as our legitimate interest, where appropriate.

Cookies that we use
Google Analytics Cookies:
__utm(a,b,c,z)
This is a system used by many websites to record information about users that visit a website. These cookies are used
mainly to enable us to examine the success of our website, to improve our users’ experience and to differentiate
between first time visitors to a website and repeat visitors.
They do not contain any personally identifiable information. You can find out more about how Google use cookies
at http://www.google.com/intl/en/analytics/privacyoverview.html

Purpose/Activity

To process payment, delivery services and
other contract fulfilment requirements
including to contact you with sales related
information or assistance. We will request
your prior consent where required by
applicable law

Type of data

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications

Lawful basis for processing

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to
recover debts due to us)

To send administrative information to you, for
example, information regarding the Services
or an event in which you are attending and
changes to our terms, of use and policies

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate interests (to
keep our records updated and to study how
customers use our products/services)

For internal record keeping

(a) Technical
(b) Usage

Necessary for our legitimate interests (to
define types of customers for our products
and services, to keep our website updated
and relevant, to develop our business and
to inform our marketing strategy)

For transmission by email of promotional
materials that may be of interest to you

(a) Identity
(b) Contact

Necessary for our legitimate interests (to
keep our records updated and to study how
customers use our products/services)

To determine how you found out about us
and what your interests are regarding our
Services

(a) Identity
(b) Contact
(c) Usage
(d) Profile

Necessary for our legitimate interests (to
develop our products/services and grow our
business)

For our business purposes, such as data
analysis, audits, fraud monitoring and
prevention, developing new products,
enhancing, improving or modifying our
Services, identifying usage trends,
determining the effectiveness of our
promotional campaigns and operating and
expanding our business activities

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests
(for running our business, provision of
administration and IT services, network
security, to prevent fraud and in the context
of a business reorganisation or group
restructuring exercise, to develop our
products/services and grow our business)
(b) Necessary to comply with a legal
obligation

As we believe to be necessary or appropriate
under applicable law, to comply with legal
process, to respond to requests from public
and government authorities, to protect and
pursue our rights

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

(a) Necessary to comply with a legal
obligation

Sharing and disclosing your personal information
Other than as expressly set out in this Policy or as otherwise required or permitted by law, we will not share, sell, or
distribute any of your personal information without your consent.
Because aggregated or anonymised information does not personally identify you, we may use it for any purpose. If we
combine anonymised or aggregated data with personal information, we will treat the combined information as personal
information according to this Policy.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
advertising. You will receive marketing communications from us if you have requested information from us or
purchased goods and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Able
Techgroup of companies for marketing purposes.
International transfers
We provide our Services globally and as such, subject to applicable law, may transfer your information to selected third
parties outside the country where you are located and where information protection standards may differ. We will take
steps to ensure that your personal information is only transferred once adequate safeguards are in place.
Links to Other Websites
This Website may, from time to time, provide links to other websites We have no control over third party websites you
may go to from our Website and is in no way responsible for the content thereof. This Policy does not extend to your use
of those websites. Users are encouraged to read the privacy policy or statement of other websites prior to using them.
Changes of Business Ownership and Control
From time to time, we may expand or reduce our business and this may involve the sale and/or the transfer of control of
all or part of Inclusive Technology. Personal information provided by Users will, where it is relevant to any part of our
business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the
terms of this Policy, be permitted to use the personal information for the purposes for which it was originally supplied to
us.
In the event that any personal information submitted by Users is to be transferred in such a manner, as required under
applicable law, you will be contacted in advance and informed of the changes.
Your Rights in relation to your Personal Information
You are entitled to know what personal information we hold about you and you may ask us to make any necessary
changes/corrections to ensure that it is accurate and kept up to date.
You can access the personal information that we hold on you by logging into your account and making any changes to
your personal information as necessary. You are also entitled to request that we give you access to, correct or delete
any personal information that we hold about you, subject to any lawful exemptions. You can also ask us to transfer the
personal data we hold about you to another person, or delete your account altogether.
If you have registered an account with us, it is your responsibility to ensure that you submit true, accurate, and complete
information to your account, and keep it up to date. You may also update your personal information by contacting us
through the contact details provided below. We may from time to time reach out to you to ensure the personal
information you provide is up to date in any case.
If you have any questions about the personal information that we hold about you, would like us to correct or delete such
data, or would like to request access to it so you may view it yourself, please contact us using the contact information
provided. Where you have requested that we provide your personal information to you, you will not have to pay a fee to
access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your
request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these
circumstances. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we will notify you
and keep you updated.
Security
Data security is of great importance to us and to protect your personal information we have put in place adequate
physical, electronic and managerial procedures to safeguard and secure personal information collected via this
Website.
Cookies
This Website may place and access certain Cookies on your computer. We use Cookies to improve your experience of
using the Website and to improve our range of products and services. We have carefully chosen these Cookies and
has taken steps to ensure that your privacy is protected and respected at all times.
The types of technologies used via the Website include:
· Cookies: Small text files that contain a string of characters. Able Tech uses cookies to uniquely identify an Internet
browser. Certain browsers or browser settings sometimes block cookies, and cookies may not work effectively on
some mobile devices. For more information about cookies, please visit www.allaboutcookies.org
Managing Cookies
You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to
choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept
cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete cookies at any time however you may lose any information that enables you to access the
Website more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance
provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
Data Retention
If you send us information or create an account on our Website, we will retain your information for as long as your
account is active with us or for as long as you are receiving our Services. Please be advised that even after you have
closed your account with us or ceased to use our Services, we may retain and use your personal information as
necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Cookies set via the
Website will expire within two years.
Information provided on someone else’s behalf
If you provide us with information about someone else, please ensure you have the person’s permission to do so for the
purposes detailed in this Policy.
By providing personal data relating to another person, you confirm that you have their consent to do so, or are entitled to
consent to the processing on their behalf (for example for children where you have parental responsibility).
Our customers
To the extent you are a customer of Inclusive Technology, you acknowledge that you have your own obligations in
relation to the personal information you provide to us and that we process on your behalf. It is your responsibility to
ensure that any information shared with us is done so in accordance with the laws applicable to you.
Changes to this Policy
From time to time we may revise this Policy. If we make revisions that change or affect whether or how we collect or use
personal information we will notify you by email (sent to the e-mail address specified in your account) or by means of a
notice on our Website thirty days prior to the change becoming effective. In any event, you should review the Website
periodically so that you are up-to-date on our most current policies and practices.
Contact
If you have any questions or concerns about this Policy then please contact us

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