This website notice provides an overview of the privacy policies to be observed by the companies of ADHARA GROUP: Adhara Ltd, Adhara Blockchain Technologies South Africa (Pty) Ltd and Adhara Blockchain Technologies Spain SLU (hereinafter “ADHARA” will mean the ADHARA Group or the relevant company belonging to the ADHARA Group).

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, 36-38 Cornhill, London, EC3V 3NG
Email address: privacy[at]adhara.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 privacy[at]adhara.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 privacy[at]adhara.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.

These terms of use of this website provides an overview of the privacy policies to be observed by the companies of ADHARA GROUP: Adhara Ltd, Adhara Blockchain Technologies South Africa (Pty) Ltd and Adhara Blockchain Technologies Spain SLU (hereinafter “ADHARA” will mean the ADHARA Group or the relevant company belonging to the ADHARA Group).

 Owner

The information and details about the owner of this website can be found below, which are provided in compliance of the principles set out by Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market:
Owner: ADHARA GROUP
Address: International House, 36-38 Cornhill, London, EC3V 3NG
Email address: privacy[at]adhara.io

Conditions of use

These are the conditions that govern the use of this website. By accessing the website, the User acknowledges to be aware of these terms of use and accepts to comply with them without any reservation. The user who violates this obligation will be deemed liable for any damages caused to ADHARA or to any third party. ADHARA reserves the right and will be entitled to deny, suspend, interrupt or cancel the access to all or part of the website to any user who is in breach of these Terms of Use. 

In addition, ADHARA reserves the right to withdraw, cancel, amend or modify wholly or partially the content of this website and its elements without prior notice.

Intellectual and Industrial Property Rights

All intellectual and/or industrial property rights relating to the contents of this website are property of ADHARA or third parties unless indicated otherwise. This includes, but not limits to, any text, trademark, trade name, logo, distinctive sign, picture, photograph, video, audio-visual content, image, icon, file, graphic design, colour combinations, web structure and design.

It is prohibited for the User to reproduce, transform, distribute, communicate and explode in any way the contents of this website without the prior and express authorisation provided by ADHARA.

The user is not allowed to delete, modify, amend or manipulate any protective devices or security systems which may be installed on the website. 

The fact that ADHARA provides access to the User to its services does not imply any renounce, transfer, whole or partial assignment of the intellectual and industrial property rights by ADHARA and does not entitle the User to any use of the website which exceeds the necessary actions to visit the website and to use the services offered on it.  The User will refrain from reproducing or copying for private use any content of this website that may be deemed as subject to intellectual or industrial property rights protection.

Hyperlinks

This website may offer different links or hyperlinks to other websites managed by third parties over which ADHARA has no control and, therefore, may change or disappear at any time. ADHARA will not be liable for the contents of such websites. Any link or hyperlink to any website which does not belong to ADHARA does not imply that ADHARA recommends or approves its contents. 

Additionally, any user who wants to insert a link or hyperlink to this website in his website must comply with the following rules:

• Links or hyperlinks that may create confusion about the identity of ADHARA or that suggest that the content linked is owned or has been created by someone different than ADHARA will not be allowed.
• Acts of unfair competition, unfair comparison or imitation or that may lead to exploit ADHARA’s or its trademark’s reputation will be prohibited.
• No false or inexact information about ADHARA, its shareholders, clients, commercial partners or employees shall be included.

Exclusion of liability

By accessing this website, the User assumes its use at his own risk. Neither ADHARA nor its partners, shareholders, associates, managers, employees or representatives shall be liable for any mistake, omission, lack of truthfulness or exhaustiveness and/or inaccuracy of the information in this website and/or for any action taken by the User on the basis of the information provided in this website.

ADHARA does not offer any warranty of any kind that the website is free of viruses, worms or any other malware that may cause damages or alter the User’s computer systems, documents or files. Therefore, ADHARA will not be liable for any damages that the User may suffer due to the presence of any of the elements mentioned in the previous paragraph. The User is responsible for using the appropriate software and to have enabled the appropriate tools to prevent him from suffering damages for such a reason.

The User will be deemed liable for any damages caused to ADHARA or to any third party in breach of these Terms of Use.

This website is run on the basis of some facilities, telecommunications networks and other services provided by third parties over which ADHARA has no control. Therefore the contents of the website and the services provided through this website may be cancelled, suspended or interrupted at any time. ADHARA will not be liable for any damages caused to the User due to any suspension, cancellation, interruption and/or disconnection of the website and the services offered through it, even in absence of prior notice.

Reporting illegal or inappropriate conduct

In the event that the User of the website is aware of the fact that any link or hyperlink included in the website leads to a site whose contents and/or services are illegal, harmful, demeaning, violent, immoral or inappropriate, the User may report it to ADHARA sending the following information:

• Reporter’s identification details: full name, address, telephone number and email address;
• Description of the facts reported: a detailed description of the facts subject to report and reasoning why such facts are to be deemed inappropriate.
• When the facts reported refer to a violation of intellectual or industrial property rights, any documents and/or proofs of such infringement and the legitimate holder of such intellectual or industrial property rights. When appropriate, the fact that the reporter is duly authorised by the legitimate owner of the intellectual or industrial property rights is to be proven. 

Governing law and jurisdiction

This Terms of use and the relationship between the User and ADHARA will be governed by the laws of New Jersey, Spain, United Kingdom and South Africa. The website is hosted in New Jersey in the United States of America.

In relation to any legal action or proceedings that may be taken and/or initiated, ADHARA and the User, by accessing this website, irrevocably submit to the exclusive jurisdiction of the laws of England and Wales, and waive any objection to proceedings in such courts on the grounds of lack of jurisdiction or territorial competence.

Introduction

Adhara and its subsidiaries (“Adhara”) are committed to compliance with relevant anti-bribery and corruption laws, regulations and professional standards in all jurisdictions in which it operates. This includes but is not limited to the United States of America, United Kingdom, Spain and South Africa.

At Adhara, our relationships are built upon ethical business practices and the strengths of our products and services. We maintain a zero-tolerance policy towards corruption, bribery, and other improper advantages.

Responsible parties

The anti-bribery and anti-corruption policy is binding for all full time, part time, temporary employees; independent contractors or consultants under our direct control.

These policies also form part of the framework in which Adhara vets and engages with third parties / business partners. Third parties / business partners are expected to have appropriate anti-bribery and anti-corruption policies as a prerequisite for Adhara to enter into or maintain a business agreement with them.

For more information

Please feel free to reach out to info[at]adhara.io if you have any questions about the above.