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Privacy Policy

Both privacy and confidentiality are relevant aspects for ADHARA. For this reason and according to the European Union General Data Protection Regulation 2016/679 (GDPR), by means of this Policy it is established the way how ADHARA processes personal information. This Privacy Policy intends to keep the website’s and ADHARA application’s users informed about how their personal information is collected and processed by ADHARA.

Please note that this Privacy Policy may change at any time due to any legal change or due to new implementation criteria set out by the relevant data protection authority in each case.

Who is the controller of the personal information processing

The information and details about the owner of this website and controller of the personal information processing are the following:

Controller: ADHARA LIMITED (hereinafter, “ADHARA”)
Address: International House, 24 Holborn Viaduct, London, EC1A2BN
Email address: info[at]adhara[dot]io

Purposes of the personal information processing

To provide our services
We will use your personal information in the following ways:

  • To enable you to access and use our services
  • To provide and deliver products and services that you may request.
  • To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.

To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our services. We may also use your information to respond to your comments and questions regarding the services we offer, and to provide you and other users with general customer service.

We do not process your personal information for any other purpose different than those stated in this Private Policy.

Use for new purposes
We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will let you know as soon as possible and no later than one month from taking such a decision. In such a case we will explain to you the purpose for processing your data, the applicable legal basis for that use and, if such legal basis is your consent, we will seek your consent.

Source and category of personal information processed

We collect personal information in three ways:

Information you give us
Information we may collect from you includes:

  • Identity information, such as your first name, last name, and username or similar identifier;
  • Profile information, such as your username and password, blockchain private key, interests, preferences, feedback and survey responses;
  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our services, receive customer support or otherwise correspond with us;
  • Usage information, such as information about how you use our services and interact with us;
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
  • Login information, such as a video used for verification for recovery of account

Information we get from others
We may get information about you from other third party sources and we may add this to information we get from your use of our services. When we get information about you from others, we will let you know as soon as possible and no later than one month from collecting such information. In such a case we will explain to you the purpose for processing your data, the applicable legal basis for that use and, if such legal basis is your consent, we will seek your consent.

Information automatically collected
We may automatically record certain information about how you use our Site (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Site to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our Site that a user clicked on or used, and other statistics. We use this information to administer our services and we analyze (and may engage third parties to analyze) this information to improve and enhance our services by expanding its features and functionality and tailoring it to our users’ needs and preferences.

Term of the processing

The personal information collected will be kept during the time necessary for the purposes they were collected and, afterwards, for the time necessary to comply with any potential legal obligation or request according to the laws and regulations in force.

Legal basis for the processing

These are the legal bases for the processing of the personal information we carry out:

  • The data subject’s consent (Article 6.1.(a) of GDPR)
  • Compliance with a legal obligation (Article 6.1.(c) of GDPR)
  • Legitimate interests pursued by the controller (Article 6.1.(f) of GDPR)

Recipients of the personal information

We do not send any personal information collected by ADHARA except when specifically requested by a public authority.

Assignment of personal information

We generally do not share your personal information with any other entity. However, we may share your personal information exclusively with any of the companies belonging to the Adhara Group, if necessary for the purposes of their processing. In such event the recipient company member of the Adhara Group will let you know as soon as possible and no later than one month from sharing such information such information and it will explain you the purpose for processing your data, the applicable legal basis for that use and, if such legal basis is your consent, we will seek your consent.

International transfer of personal information

Please be aware that your personal data may be transferred, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our site or using our services.

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Please contact us at info[at]adhara[dot]io if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Exercise of the rights of the data subjects

Under the GDPR you have certain rights regarding your personal information. These are the actions you can ask us to take in relation to the personal information we hold about you:

  • Opt-out: you may request ADHARA to stop sending you communications which you have previously consented to receive.
  • Access: you may request to have access to the personal information about you that we process.
  • Rectification: you may request that your personal information is updated and that any mistake about it is rectified and corrected.
  • Erasure: you may request that your personal information which is inappropriate or excessive is eliminated.
  • Processing restriction: you may request that some restrictions to the processing of your personal information in the future are applied.
  • Portability: you may request a copy of the information that we hold about you.
  • Objection: you may object to our reliance on our legitimate interests that impacts your rights.

In case you want to exercise any of these rights you can address ADHARA by sending an email to info[at]adhara[dot]io indicating the specific right you want to exercise and attaching a copy of your national ID or passport. In addition, you have the right to ask the Spanish Agency of Personal Data Protection to enforce your rights. 

Security measures

Taking into account the nature, scope, context and purposes of processing of the personal information collected through this website, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, ADHARA has implemented the appropriate technical and organisational measures to ensure that processing is performed in accordance with GDPR. Those measures are updated every time it is necessary.

Amendments to this Privacy Policy

ADHARA reserves the right to modify, wholly or partially, this Private Policy without prior notice.