Public Records Privacy Policy

ADAMftd Ltd is a company whose purpose is to collect, use, and make available certain personal data in accordance with this Privacy Notice and in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) of the European Union where applicable. For the purposes of the GDPR, we act as a “controller” of personal data.

Many countries publish information about companies as part of their official public record, often including details about the ownership and officers associated with the company. This information typically contains personal data since the owners and officers are generally individuals.

We collect this information only from public sources worldwide such as:

• Official company registers (e.g., ACRA in Singapore, Companies House in the UK, etc)
• Government gazettes
• Trademark and/or patent registrars
• Ship registrars
• Charity registers
• Other regulatory data sources
• Customs bureaus
• Statistics bureaus
• Media outlets for public news
• Government sanctions offices
• Government statistics offices
• Stock exchanges
• Shipping bureaus
• Ports and port agents
• Logistics and shipping firms
• Trade finance companies
• Other authoritative sources

The specific information we collect may vary depending on the territory and the information available in the particular official public record. We strive to be transparent about the sources of our data, and where possible, we provide a link to the source of the data we have collected.

If you are or were, for example, an officer, shareholder, or (ultimate) beneficial owner of a company, or a sole trader registered with a company registry, we may collect and process the following personal information about you:

• Name
• Address
• Unique identifier
• Partial or full date of birth
• Occupation
• Nationality
• Details of the company you are or were an officer for, and filings that refer to you
• Details of your relationship with the company, such as your position (e.g., shareholder/director) and period of association (start and end dates)
• Gazette notices referring to you

If you are the registered owner of a trademark, license, or trading/”doing business as” name related to a company record processed by ADAMftd, we may collect and process your name and address in our public records register.

ADAMftd processes this information to fulfill our transparency mission by:

1. Compiling a comprehensive database of international sanctioned entities, trade transactions, company, and company officer profiles, based on publicly available corporate, trade and economic data.
2. Enabling members of the public to access this database through the ADAMftd platform which is accessible via our website to subscribed users.
3. Providing data via API and bulk downloads to third parties, such as financial institutions, public authorities, NGOs, journalists, and academics for investigative, compliance, and research purposes.

We make our services available to:

• The public via our website.
• Third parties via our API and bulk downloads.

The third parties to whom we make our database available include:

• Commercial entities, including, but not limited to, manufacturers, international exporters and importers, trade finance companies and financial institutions conducting due diligence checks.
• Public authorities, including foreign direct investment agencies, export promotion agencies, economic development agencies, government trade ministries, and law enforcement agencies investigating corporate crime and tax evasion.
• NGOs, journalists, and academics for journalism and research purposes.

We may also share information, including personal data, with law enforcement or other authorities in accordance with applicable law.

The information we collect forms part of our historical archive of company data. We aim to provide a complete and accurate picture of historical economic activity and corporate affiliations and associations, including historical transactions and corporate connections. Therefore, we do not automatically delete or remove information from our records register after a certain period. Maintaining this information is crucial for our mission and particularly important for investigative purposes.

The basis we rely on for processing personal information in our public records register is to the extent possible in accordance with the provisions of Article 6(1)(f) of the General Data Protection Regulation (GDPR). This article allows for the processing of personal data when it is necessary for the purposes of the legitimate interests pursued by the data controller or a third party, provided these interests are not overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.

Our legitimate interests include the following key aspects:

1. Enhancing Transparency in International Trade:
   • Supply Chain Traceability: We seek to enhance transparency across supply chains, enabling companies to trace their supply chains and conduct due diligence on their suppliers in a more transparent manner.
   • Risk Reduction: By providing detailed information on suppliers, their networks, and potential trading partners, we seek to help companies and governments reduce risks in their supply chains.
   • Compliance with Supply Chain Transparency Laws: The data which we make accessible should aid companies in complying with various supply chain transparency laws, such as anti-slavery, anti-child labor, conflict mineral, and other traceability laws.
   • Extended Supply Chain Transparency: We seek to provide transparency not only into direct supply chains but also into the suppliers and customers of those suppliers, identifying potential sanctioned entities and reducing compliance risks.
2. Enhancing Corporate Transparency:
   • Mission Fulfillment: Our primary mission is to increase and promote transparency in the corporate and business world. This involves providing detailed information about the organization, ownership, and activities of business entities, as well as the people connected with them.
   • Public Benefit: By maintaining and providing access to a platform that  compiles data from public records, we contribute to  having the public be more informed, enabling individuals and organizations to engage with companies on a global basis with greater confidence.
3. Public Access to Comprehensive Corporate Data:
   • Information Availability: We aim to enhance access to a more comprehensive picture of the corporate world for a wide audience, including members of the public, journalists, law enforcement agencies, financial institutions, NGOs, and researchers.
   • Corporate Accountability: Providing corporate data plays a crucial role in making it possible to identify corporate corruption, malpractice, fraud, tax evasion, money laundering, and other illegal activities. This supports the broader goal of fostering a more trustworthy and transparent business environment.
4. Data Accuracy and Reliability:
   • Facilitating Error Detection: By enabling easier access to data held in official registers, we contribute to achieving better corporate data accuracy and reliability. This facilitates the detection of errors or questionable aspects of the data, thereby improving the quality of corporate information available to the public, for the benefit of the public interest.
5. Combating Corporate Crime:
   • Law Enforcement Support: Our data processing activities aim to support the fight against corporate crime, including activities such as money laundering, tax evasion, and other forms of financial crime. By making this data available, we assist law enforcement agencies and other relevant authorities in their investigative efforts.
   • Creating a Trusted Environment: Our efforts contribute to creating a more trusted corporate environment for all stakeholders, which is essential for the healthy functioning of markets and economies.
   • Counterfeit Prevention: Our efforts help combat counterfeit products in international trade, which is a significant issue not only for brand protection but also for public health, safety, and economic security.
   • Trade-Based Money Laundering Prevention: Our platform helps identify and prevent trade-based money laundering, where trade transactions are used to disguise the origins of illegally obtained money.
   • Sanctioned Entity Exclusion: Our data helps to reduce the involvement of sanctioned entities in legitimate supply chains, ensuring compliance with international sanctions and improving supply chain integrity.
6. Transparency and Supply Chain Mapping:
   • Supply Chain Transparency: We enhance transparency across supply chains, helping entities to understand their supply chains better and comply with various legal requirements.
   • Traceability Laws Compliance: Our data aids companies in meeting their obligations under anti-slavery, anti-child labor, conflict mineral, and other traceability laws, ensuring ethical practices across their operations.
7. Global Sanctions Data:
8. • AML and KYC Compliance: We serve as a comprehensive source of information for global sanctions data, assisting entities in complying with Anti-Money Laundering (AML) and Know Your Customer (KYC) legal requirements. This helps organizations to identify and avoid transactions with sanctioned entities and individuals, thereby ensuring regulatory compliance.

The benefits of our data processing activities include:

• Transparency and Public Insight: The enhanced transparency provided by our database helps the public gain better insights into the corporate landscape.
• Corporate Responsibility: The availability of accurate corporate data helps to hold companies and their officers accountable, discouraging illicit activities and fostering a culture of compliance and ethical behavior.
• Support for Investigations: The data we provide helps to support crucial investigations by law enforcement and regulatory agencies, aiding in the detection and prevention of financial and corporate crimes.
• Regulatory Compliance: Our platform supports entities in meeting various regulatory compliance requirements, including AML, KYC, and supply chain transparency laws, thereby promoting ethical business practices and reducing the risk of legal penalties.

We are committed to maintaining transparency about our data processing activities and ensuring that individuals’ rights are respected. Our practices are designed to comply with applicable data protection laws, including the GDPR, and we continuously review and update our processes to reflect best practices in data protection and privacy.

Under the GDPR, our data processing activities are aligned with the following specific provisions:

• Article 5 (Principles Relating to Processing of Personal Data): We adhere to principles such as lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.
• Article 6 (Lawfulness of Processing): Our reliance on legitimate interests (Article 6(1)(f)) is based on an assessment that our interests are not overridden by the data subject’s interests or fundamental rights and freedoms.
• Article 13 and 14 (Information to be Provided to Data Subjects): We further provide transparency by providing comprehensive information about our data processing activities to data subjects upon their request.

Given the global nature of our web-based service, information in the ADAMftd public records register can be accessed widely. For transfers of our public records to third parties, we take appropriate steps to safeguard personal data, such as data transfer agreements with those third parties, in accordance with applicable law.

We have implemented appropriate security measures to prevent personal information from being accidentally lost or accessed in an unauthorized way. Additionally, we have procedures to handle any suspected data security breaches, including issuing public notifications as required by law.

Under data protection laws, individuals have rights regarding their personal data, including:

• The right to access personal data we hold about you.
• The right to correct any inaccuracies in your personal data.
• The right to object to our processing of your personal data.
• The right to request the erasure of your personal data.
• The right to request the restriction of processing your personal data.
• The right to data portability.
• The right to lodge a complaint with a supervisory authority.

Requests to exercise these rights can be submitted to us via our contact details. Each request will be assessed on a case-by-case basis, and we will communicate the outcome to you.

Our database aims to provide company data as reflected in official public records. If a public company register removes or limits access to certain information, we will update our records accordingly and temporarily remove the relevant information from our database while this process is carried out.

Requests for redaction of personal information must be made by the individual concerned or their legal representatives and verified by us.

We do not intentionally process personal data about minors. However, on rare occasions, public records may include such information. If we become aware that data in our records clearly relates to minors, we will restrict access to logged-in users and add a no-index tag to prevent the information from appearing in search engine results.

We strive to resolve any queries or concerns you may have about our use of your information. However, you also have the right to lodge a complaint with a supervisory authority. The supervisory authority in Singapore is the Personal Data Protection Commission (PDPC), which can be contacted through their website.

For any questions or concerns about this Privacy Notice or our data practices, please contact us at:

ADAMftd Pte Ltd

• Email: support@adamftd.com
• Phone: +1 202 991 2218

This Privacy Notice was first published on July 1, 2024 and last updated on July 22, 2024. We may update this notice periodically to reflect changes in our practices or applicable laws. The latest version of this Privacy Notice will always be available on our website.