2. DATA WE COLLECT
We collect, process, review, distribute, store and use personal information have set out in the paragraph below :TechnicalUpon visiting our Website, we process technical data related to your usage of the Website, including but not limited to IP address, location data (down to city level), access-provider, referring URL, date, time, access tokens, session key, browser type and version, browser language, operating system, amount and state of transferred data. This information can be related to you, therefore, Personal Identification Information can be processed as well. This data may also be processed as anonymized statistical data.
In case you interact with us via our Website live chat, e-mails, and sign-up forms, Facebook page, Youtube channel, Twitter page or Telegram or any other official social media account, we process, in addition to Personal Identification Information (limited in case of contacting via social media), also the contents of your message.
When you use the Software
Personal Identification Information
Name, e-mail address, 2FA key, IP address, KYC token, language, Google Analytics client ID, Avatar image.
Financials and Transactions: Exchange Account username, API key, API secret, passphrase, transaction data (date/time/amount of transaction), transaction request/response, Referral status, billing information (country, phone number, address, city, postal code; in case of an entity: business name, registry code)
The personal data we process is collected from one of the following sources: The data is disclosed by you directly to us;We receive the data from your Exchange Account provider by you connecting your Exchange Accounts to the Client Account;We receive the data from the social media service provider when you are registering or contacting us via your social media account;We receive the data from the payment service provider when you execute the User Agreement and pay for the Subscription;We receive Technical Data automatically from your browser, our servers, and systems;
3. What do we use your personal data for
We have set out in the table below the reasons why we process your personal data:
The purpose for collecting and processing information:
a) Client authentication, use of the software and its functionalities,
b) Communicating via devices, social media, and apps (for example, mobile app, e-mail, Website, Telegram Bot),
c) Direct marketing campaigns - Client marketing campaigns in relation to the Software, its functionalities and products,
d) Processing data for predictive analytics and insights, improvement and development of the Software,
e) Diagnostics and resolution of the technical issues related to the Software and the Website,
f) Storing information containing personal data in backup systems,
g) Data disclosures to potential acquirers of ADA WEALTHTECH LLC business, including legal advisors, auditing service providers in case of a merger, acquisition or selling the whole or part of our business,
h) Data disclosure to our service providers, i) Mandatory disclosures to law enforcement and data protection authorities,
k) Client identity verification (KYC) for recovery,
l) Client's transaction history,
m) Responding to your enquiries and requests submitted via the website, sign-up forms, live chat or e-mail or any social media platforms,
n) Client invoicing for the User Agreement,
o) Transfer of funds from a payment service provider to your Client Account and making out payments upon your withdrawal request via payment service provider.
Categories of personal information:
Personal Identifiable Information, Financial, and Transaction Data.We may process your personal data for other purposes, provided that we disclose the purposes and use to you at the relevant time, and that you either consent to the proposed use of the personal data, other legal grounds exist for the new processing purposes or the new purpose is compatible with the original purpose brought out above.
4. SHARING YOUR PERSONAL DATA
Any data you provide will not be publicly displayed or shared with other Website visitors or clients. Certain employees of ADA WEALTHTECH LLC have access to personal data to the extent necessary for the performance of their work duties.We use third-party processors and separate data controllers to help provide our service. They will have access to your personal data as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.With Affiliates and SubsidiariesFor purposes limited to and consistent with this Privacy Notice, a list of the Affiliates andSubsidiaries we share personal information with are set out in the Deed Poll to ADA WEALTHTECH LLC Corporate Privacy Rules are available here. We also share non-personally identifiable information, such as anonymized or aggregated information, with suppliers for purposes such as analysis, identifying trends in the areas of our products, and helping research and develop newADA WEALTHTECH LLC Services.
We occasionally have relationships with third parties that are not suppliers or vendors but areworking with us to offer certain opportunities such as sweepstakes, contests, and similarpromotions, to enable joint products or research studies, or to facilitate services like messageboards, blogs, or other shared platforms. In these cases, additional terms or privacy notices maybe provided. For third parties or uses not described in this Notice, we share your informationonly with a lawful basis to do so.For Advertising and MarketingWe share your information with our third-party company partners to prepare and deliver advertising and marketing content, provide content services, and enable them to provideyou with more personalized ads and study the effectiveness of our campaigns. In particular, we use third-party companies to communicate regarding goods and services that may be ofinterest to you, in accordance with your preferences. You may receive this content by a variety of means such as email, phone, or when you access and use the ADA WEALTHTECH LLC Services and other websites. Content may be based on information obtained, for example, through prior purchasesor transactions, through your device's physical location, through information about what advertisements and content you have viewed, or through cookies and similar technologiesrelating to your access to and use of the ADA WEALTHTECH LLCServices and other websites. Please read our ADA WEALTHTECH LLC Cookies and Similar Technologies Notice for more information.You can choose whether to allow or deny uses and/or sharing of your device's location by changing your device settings,but if you choose to deny such uses or sharing, our partners may not be able to provide you with the applicable personalizedADA WEALTHTECH LLC Services and content. ADA WEALTHTECH LLC does not share your personal information with non-affiliated third parties for their own advertising or marketing usewithout your permission. For information about how to decline our advertising and marketing, please see the section entitled "Your Choices & Rights" below.
Research and Study
We may disclose personal information to collaboration partners to conduct research to improveour technology, or the use of our technology, in various fields of study and to identify new uses or design new products. With Your Consent, ADA WEALTHTECH LLC may disclose your personal information to any other person or entity where you consent to the disclosure. Your Choices & Rights ADA WEALTHTECH LLC respects your rights in how your personal information is used and shared. You may request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from ADA WEALTHTECH LLC at all).
5. ENSURING THE SECURITY OF PERSONAL DATA
We have taken necessary technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss, or alteration and against unauthorized disclosure, abuse, or other processing in violation of applicable law. We also encourage you to take measures to ensure the safety of your personal data. In particular, we advise you not to share your personal data with us or any of our partners via any public forums or other public channels, unless you acknowledge and accept that relevant data will be publicly accessible.
6. RETENTION AND DELETION OF PERSONAL DATA
Your personal data (all data categories mentioned in Section 2) shall be stored insofar as reasonably necessary to attain the objectives stated in Section 3 above, or until the legal obligation stipulates that we do so. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the processing purposes, and whether we can achieve these purposes through other means, and applicable statutory obligations. Whilst retaining the personal data, we take into account the viable need to resolve disputes and enforce the contract between us or anonymize your personal data and retain this anonymized information indefinitely.
In case you are Client, as a general rule, we will retain all your data for 7 days after the termination of the Client Agreement in a manner that would allow you to re-activate the Client Account. Otherwise, please see the following non-exhaustive summary on storing your personal data:
For accounting purposes, we retain Financial Data, Transaction Data, and Personal Identification Information connected to it for a period of 7 years from the end of the financial year when the respective business transaction took place;
Data connected to the Client Agreement or the Purchase Agreement, which is first and foremost Personal Identification Information, is retained for the whole period when the respective agreement is in force and at least 3 years from the moment of termination of the respective agreement under our legitimate interests to protect ourselves against potential disputes or enforce claims. In case we have a reasonable doubt that a party has acted in bad faith, has breached any obligations intentionally, or has threatened us with a dispute, we may prolong such retention period for a maximum of 10 years.
Technical Data will be retained for 30 days as of the collection of such data;
Communication Data, unless clearly connected to the Client Agreement or the Purchase Agreement, will be retained for a period of 3 years from the moment the respective communication flow has been closed.
In case any of the data stipulated in Section 2 above is needed for purposes of protection against ongoing or threatened disputes, we shall retain the related data as long as the dispute is solved.After the expiry of the retention period determined above or the termination of the legal basis for processing purposes, we may retain the materials containing the personal data in the backup systems, from which the respective materials will be deleted after the end of the backup cycle. We ensure that during the backup period appropriate safeguards are applied and the backed-up materials are put beyond use.
7. YOUR RIGHTS AND PREFERENCES
Under data protection law, you have rights including:
Right to be informed and to access. You may get information regarding your personal data processed by us.
Right to data portability. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format.
Moreover, you may request that the personal data be transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.
Right to erasure.
You have the right to have the personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes.
Right to object and restrict.
You have the right to object to the processing of your personal data and restrict it in certain cases.Right to rectification. You have the right to make corrections to your personal data.
Right to withdraw consent.
When you have given us consent to process your personal data, you may withdraw said consent at any time.To exercise any of the aforementioned rights, please contact our customer support team via e-mail indicated in Section 8 below.
8. OTHER IMPORTANT INFORMATION
Newsletter, notifications, and direct marketing campaignsWith your explicit consent, you may be subject to direct marketing campaigns, we may send you our newsletter or provide you with notifications. You may opt-out of the direct marketing campaigns, newsletters, and notifications on your account settings.
We may also provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.Please note that email marketing messages include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).
Clicking on the link in an email will opt you out of further messages of that category. You can use the Account Settings page to exercise choices about all categories of email and push marketing communication.
We do not knowingly collect any information from individuals under 18 years of age. If we discover a user of being younger than 18 years old we will require the user to close their account and we will take steps to delete any collected information as soon as possible.Identifiers (excluding online identifiers), such as first and last names, email addresses, phone numbers,2FA key, social media account information (such as Facebook UID, Facebook profile name, Facebook email), in the case on an entity: business name, business registry code, and VAT ID.
Commercial information, such as records of your transactions with us; content of messages; and services considered.Financial information, such as billing and mailing address, exchange account username, API key, API secret, passphrase, transaction data (date/time/amount of transaction), transaction request/response, referral status, billing information (country, phone number, address, city, postal code; and other payment-related information.
Online identifiers, such as operating system type and version number, manufacturer and model; browser type; screen resolution; IP address; unique device identifiers; and your user ID.Geographical data, such as the city of your location identified by your IP address.
We do not sell your personal information in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your activity on ours and other online services. This is called interest-based advertising.
We may change this Privacy Notice from time to time so it accurately reflects our practices, the ADA WEALTHTECH LLC Services and legal requirements. The "Last Revised" section at the top of this Notice states when this Privacy Notice was last amended and we update this date each time a revision is posted. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the ADA WEALTHTECH LLC Services.
You should check back regularly to stay informed of our privacy practices. If any change to our Privacy Notice materially affects the use of your personal information, we use reasonable efforts to notify you in advance, such as by sending an email or posting a prominent notice of the changes on our website and give you a reasonable period of time to object to any changes. In some cases, objecting to changes may affect the availability or functionality of the ADA WEALTHTECH LLC Services available to you. We will treat your continued use of the ADA WEALTHTECH LLC Services after the effective date of any updated Privacy Notice as your acceptance of the changes we have made.
However, we will seek your affirmative consent to any material changes in our use of your personal information as described in an updated Privacy Notice if and where this is required by applicable data protection laws. We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share personal information.
How to contact us:
ADA WEALTHTECH LLC
Suite 305, Griffith Corporate Centre, Beachmont, Kingstown, St.
Vincent & Grenadines
Email: [email protected]