Privacy Policy

Last Updated: April 10, 2026

This Privacy Policy (the “Policy”) describes how Adesic LLC, a Florida limited liability company doing business as Adesic (“Adesic,” “we,” “our,” or “us”), collects, uses, discloses, and protects personal information in connection with your access to and use of the services made available by Adesic.

This Policy applies to individuals who explore our Services (“Users”) and those who sign up for and access our Services as customers (“Customers”) (collectively, “you” or “your”). Our services include the services offered through our websites, including adesic.com, our mobile application, our application programming interfaces (“APIs”), third-party applications that rely on such APIs, and other products and services available for individual or business use (collectively referred to as the “Services”).

By accessing or using our Services, you acknowledge that you have read and understand this Policy. If you reside outside of the United Kingdom and the European Economic Area (“EEA”), your access to or use of the Services also signifies your acceptance of this Policy and its terms. If you do not agree with this Policy, you should not access or use the Services.

This Policy explains the types of personal information we collect, how we use and share that information, the choices and rights available to you, and how we protect the information we process. “Personal Data” or “personal information” means information that identifies, relates to, describes, or can reasonably be linked to you. Information that has been anonymized or de-identified so that it cannot reasonably be used to identify you is not considered Personal Data for purposes of this Policy.

We collect and use personal information in order to provide and improve our Services, personalize and enhance your experience, maintain the security and integrity of our platform, communicate with you, comply with law, and fulfill other legitimate business and operational purposes as described in this Policy. We may also share personal information with affiliates, service providers, and other third parties as described below in order to operate the Services, support our business, and satisfy legal or regulatory obligations.

You should read this Policy carefully. If you do not want your personal information to be collected, used, or disclosed as described in this Policy, or if you are under 18 years of age, you should not access or use the Services. If you have questions about this Policy or your privacy rights, you may contact us through our Support Portal or at support@adesic.com.

Adesic may update or modify this Policy from time to time in its discretion. Any changes will become effective when posted to the Site, unless otherwise stated. Your continued access to or use of the Services after any updated Policy becomes effective constitutes your acknowledgment of the revised Policy to the extent permitted by applicable law. We encourage you to review this Policy periodically.

How We Protect Your Information

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encryption, access controls, security monitoring, and regular staff training. However, no internet-based service can ever be 100% secure.

Blockchain Participants

Please note that by virtue of the public nature of the blockchain, the holdings and transactions associated with your cryptocurrency wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address (including, but not limited to, cryptographically secure non-fungible tokens, and other blockchain-based tokens), the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user's identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please consider how privacy and transparency on the blockchain works.

If you choose to make your Adesic activity public, or use a public wallet address, that information is inherently not subject to erasure or modification by Adesic. Transactions on blockchains are immutable and public by design; your rights to erasure or modification under certain privacy laws may not apply to information stored on public blockchains, even if such information relates to you.

Coverage

This Policy encompasses the entirety of the Site. However, it does not extend to entities not owned or controlled by Adesic, which includes advertisers or content developers. The Company may incorporate links to third-party sites on the Site. These third-party sites operate under their own privacy policies, not under this Policy. As such, we bear no responsibility or liability for the content and activities on these third-party sites. We strongly encourage you to review the privacy policy of any third-party site you engage with, both on and off the Site.

1. Our Gathering of Personal Information

We gather personal information in relation to your visit to and utilization of the Service. This collection comprises of information you provide while using the Service, data from third parties, and information gathered automatically such as via the use of cookies and other technologies. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, middle name, maiden name, last name, title, tax ID, marital status, date of birth, gender, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g. your passport or driver’s license).
• Contact Data includes billing address, residential address, email address and telephone numbers.
• Financial Data includes bank account details, wire transfer information, virtual USD account information (including account identifiers and balance information), payment method details, and other financial account information you provide or that is generated in connection with your use of the Services.
• Transaction Data includes details of your Services activity such as the amount, date, time, asset type, counterparty wallet address or account, and recipient for each transaction, as well as data generated by third-party financial infrastructure providers in connection with processing your transactions.
• Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.
• Profile Data includes your username or similar identifier, password, your preferences, feedback and any survey responses.
• Usage Data includes information about how you use the Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Survey and Customer Feedback Data includes information you provide in any survey or feedback forms on Services.
• Location Data includes information about your device location.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We retain your personal data only as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).

Information about criminal convictions

When you register for Services, we may receive information about your criminal convictions when we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e. to provide the Services to you). In this case, we may have to close your account or limit or restrict your access to other Services, in accordance with the terms of the User Agreement, but we will notify you if this is the case at the time.

Personal Information Gathered from Individuals

The following personal information may be gathered from individuals who submit to us via the Services:

• Account Details: To use specific aspects of our developer platform or governance portal Services, you may need to create an account for the Services. This may involve collecting your email address, social media handle, and when applicable, public blockchain address associated with your crypto wallet (refer to Crypto Wallets section below for more information). We may also collect your usernames and passwords for using our developer platform Services. We utilize this information to manage your account, provide the relevant services and information, communicate with you about your account, the Service, and for customer support.
• Token Details: Should you choose to trade using our Services, we may receive certain token transaction and event-related information, including your public blockchain address associated with your self-hosted crypto wallet, types of crypto wallets, quantities of digital assets and token balances, token ownership data, and other transaction and event-related information (e.g., transfers of digital tokens between wallets, the corresponding smart contracts, paid amounts, and metadata describing the transaction, and/or properties of a digital asset).
• Interactions: If you engage with us through any paper or electronic form (i.e., a “contact us” form, email), we may gather your name, email address, phone number, or any other personal information you choose to give us. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the services we provide to our users, and to manage and grow our business.
• Marketing Emails: Should you sign up for our newsletter, we collect your email address to send you regular updates about the Service, such as information about new opportunities available. We use this information to manage our communications with you and send you details about products and services we believe you may find interesting. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Please note that you cannot unsubscribe from certain service-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Event and Webcast Details: Registration information, call-in specifics, attendee badge data, company information, and contact details. We use this data to administer and facilitate the Services and improve and expand our business.
• User Content: You may upload or transmit audio, videos, images, data, or information through your communications with us, your posts in the forum, and when you use the Services in other ways (collectively, "User Content"). We may collect this information, and details about this content, such as when you created this content, along with other information about you, including your social media handle and crypto wallet details. Please note that Adesic may, but is not obligated to, monitor, record, and store User Content to protect your safety or the safety of other users, assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. For more information, please see our Terms of Service.
• Employment Application Details: Contact and demographic data, educational and work history, employment interests, information obtained during interviews, and any other information you choose to provide, if you apply for a job with us.

Automatically Collected Personal Information

Much like most digital platforms, we, along with our third-party providers, may automatically gather personal information from your device, browsing behaviors, and website usage patterns when you visit or interact with our Services. This information may include log data (e.g., internet protocol (IP) address, operating system, browser type, browser ID, the entered URL and the referring page/campaign, date/time of the visit, the duration spent on our Services, and any errors that might occur during your visit to our Services), analytics data (e.g., the digital path you took to access our Service, through our Services, and when exiting our Service, as well as your usage and activity on our Service) and location data (such as your general geographic location based on the log data we or our third-party providers collect).

To manage cookies, you may modify your browser settings to: (i) notify you when you receive a cookie, allowing you to choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please be aware that doing so might negatively affect your experience using our Services, as some features and services may not function properly or at all. Depending on your device and operating system, you may not be able to delete or block all cookies. Furthermore, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

For more information about these practices and your choices regarding cookies, please refer to our Cookie Policy.

Personal Information from Third Parties

We also acquire personal information from third parties, which we frequently integrate with the personal information we collect either automatically or directly from you.

We may receive the same categories of personal information as described above from the following third parties:

• Other Users or Individuals who Interact with our Services: We may receive your information from other users or individuals who interact with our Services. For instance, if you participate in one of our communities hosted on third-party platforms, such as Discord, we can view any public communications made within that platform.
• Business Partners: Your information may come to us from our business partners, such as companies that offer their products and/or services through our Service.
• Social Media or Third-party Platforms: When you interact with our Services through various social media networks, like when you follow us on Twitter or other social networks, we may receive some information about you that the social network allows to be shared with third parties. The data we receive is dependent on your privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you allow the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before linking or connecting them to other services.
• Crypto Wallets: When you connect your crypto wallets such as MetaMask or Coinbase Wallet, we receive information such as your wallet address, crypto wallet types (including amounts and balances), and any related transaction and technical information associated with your crypto wallet address, including network information regarding transactions. We use this information to manage your account and provide you with the relevant Service.
• Service Providers: Our service providers perform services solely on our behalf, such as marketing providers, collecting personal information and often sharing some or all of this information with us.
• Information from Other Sources: We may also collect personal information about individuals from other sources like publicly available sources such as permissionless blockchains, third-party data providers, blockchain analytics providers, customers, third-party digital wallet providers, or through transactions such as mergers and acquisitions. This information may include contact information, social media account information, general location, domains, crypto wallet address and related information, token ownership information (e.g., transfers of tokens between wallets), the corresponding smart contracts transactions paid and metadata describing each transaction and its properties as a digital asset, transaction recipient information, interest-in-services information, and employment-related information. We may integrate this information with the information we collect from you directly. We use this information to provide the Services, contact individuals, process employment applications and screen job applicants, send advertising or promotional materials or personalize our Services, and better understand the demographics of the individuals with whom we interact.

2. Our Use of Personal Information

We collect all of the information in Section 1 (Our Gathering of Personal Information) so that we can provide you with the Services. The information we collect allows us to:

• Deliver the full functionality of the Services;
• Keep in touch with you - whether it be for providing customer service, notifying you of new features or updates to the Services, or providing security notices or information;
• Verify your identity so that we can prevent fraud or unauthorized activity, and to comply with applicable laws; and
• Fulfill any other purpose for which the information was collected.

We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Support.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact Support if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Change of purpose: We will only use your personal data in accordance with the purposes described in this Privacy Policy and as provided for under applicable law for the purposes for which we collected it. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Third-party links: The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the data collection and processing practices of the third party and use of any third party websites is subject to their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or the personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information you provided at that time.

3. Our Disclosure of Personal Information

We disclose personal information in the following ways:

• Affiliates: We may share personal information with other companies owned or controlled by Adesic, and other companies owned by or under common ownership as Adesic, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. This is particularly applicable when we collaborate in providing the Services.
• Blockchain Participants: If you participate in our Services, due to the public nature of the blockchain, the holdings and transactions associated with your crypto wallet address will be publicly available and accessible to blockchain participants and other third parties, as well as any other information you choose to provide or make public.
• Contests, Sweepstakes, and Survey Providers: We share personal information with third parties who assist us in delivering our contests, sweepstakes, or survey offerings and processing the responses.
• Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Please see our Cookie Policy for more information.
• Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
• Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, conducting cryptocurrency transactions, employment application-related services, payment processing services, and administrative services.
• Financial Infrastructure Partners: To provide payment, virtual account, on-ramp, off-ramp, settlement, digital asset conversion, and related financial services in connection with the Services, we share personal information, financial data, transaction data, compliance information, and identity verification information with third-party financial infrastructure providers. We use HIFI to process financial transactions. By using our service, you also agree to HIFI's Terms & Conditions and Privacy Policy.
• Business Transaction or Reorganization: We may participate in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal process; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law.
• With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual's consent or direction we may post their testimonial on our Sites or service-related publications.

4. Control Over Your Information

You may control your information in the following ways:

• Email Communications Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
• Modifying or Deleting Your Information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at support@adesic.com. We may not be able to modify or delete your information in all circumstances, especially in relation to information on the blockchain.

5. Children's Personal Information

Our Services are intended only for individuals age 18 and older. We do not knowingly collect personal data from anyone under the age of 18. If you believe a child under 18 has provided us with personal data, please contact us at support@adesic.com and we will promptly delete such data as required by law.

6. Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

7. Region-Specific Disclosures

This section provides additional privacy disclosures and rights that may apply to you depending on your state or country of residence. These region-specific terms supplement the rest of this Policy where applicable.

Nevada

If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of certain future sales of covered information that a website operator has collected or will collect about the resident. Although Adesic does not currently sell covered information under Nevada law, Nevada residents may submit such a request by contacting us at support@adesic.com with the subject line “Nevada Opt Out Request.”

California

If you are a resident of California, please see the California Consumer Privacy Act Disclosures section of this Privacy Policy for additional information about your California privacy rights, including your rights to know, access, correct, delete, and opt out of certain sales or sharing of personal information, as applicable.

Other U.S. State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws, subject to certain limitations, exceptions, and exemptions. Depending on your state of residence and the applicability of state law to Adesic's processing activities, these rights may include the right to confirm whether we process your personal data, access your personal data, correct inaccuracies, delete personal data, obtain a copy of personal data, and opt out of certain processing activities such as targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

If you would like to exercise any privacy rights available to you under applicable U.S. state law, please contact us at support@adesic.com or through any privacy request mechanism identified elsewhere in this Privacy Policy. We may take steps to verify your identity before responding to your request, and your rights may be limited as permitted by applicable law.

If we deny your request, you may have the right to appeal our decision depending on your state of residence and applicable law. To submit an appeal, please contact us at support@adesic.com and include “Privacy Rights Appeal” in the subject line.

European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please see the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures section for additional region-specific privacy disclosures.

8. Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

9. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to support@adesic.com. Adesic LLC, is committed to addressing any inquiries or concerns you may have regarding the handling of your personal information.

Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures

These Additional Disclosures set out information about how we use your personal data when you access our Service from the European Economic Area (“EEA”), United Kingdom ("UK"), and Switzerland. Please ensure that you have read and understood these Privacy Disclosures before you access or use the Services.

• Personal Data: When we use the term “personal data” in these Privacy Disclosures, we mean information relating to an identified or identifiable natural person.
• Controller: Adesic LLC, a company duly incorporated and organized under the laws of United States of America is the “controller” responsible for the processing of personal data in connection with our Services. This means that we determine and are responsible for how your personal data is used.

Legal Bases for Processing

We only process and retain your personal information as permitted under applicable law. For example, we will only process your information where we have established a lawful basis to do, as follows:

When it is necessary for the performance of a contract to which you are party, or to take steps at your request prior to agreeing a contract: This applies to any processing where you sign a contract with us, for example when you become our customer, participate in our affiliate or premium partner program, or deliver services to us as a vendor or contractor. This may also include our Terms of Service.

We have a legitimate interest which we believe outweighs your interests or fundamental rights and freedoms. This applies to the following processing activities: When we communicate with you: To respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims. When you use our Services: To respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims.

When you access and use our Services, we process technical and analytics data to see if and how our Services can be improved, so that we can offer you a better user experience in the future. Global Suppression List: Avoid contacting you again if you have withdrawn your consent to marketing-related activities. Marketing to existing customers (unless you have consented to such marketing): To find, customize and offer products and services we hope you find useful and relevant, i.e., provide you with excellent customer service. Sharing personal information with other parties: To run our business efficiently and securely. Your consent: Wherever you clearly consent to the processing, for example when you sign up for our newsletters or events. Here, your consent is implied, meaning that you consent by submitting a particular form. We also rely on your consent for using cookies and other technologies on our website and here you explicitly agree to these. Note that your default setting depends on your location (country), as the rules for using such technologies vary across jurisdictions. We are subject to a legal obligation: For any processing where we need to comply with laws and regulations related to bookkeeping, accounting, taxation and employment, for example for keeping records.

Data Retention

We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in this Privacy Notice, and in accordance with our legitimate business interests and applicable law. For example, if your personal information is subject to the EU GDPR or UK GDPR, the criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

• Contract: Where we are processing personal data is based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
• Legitimate Interests: Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
• Consent: Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfill the underlying agreement with you or provide you with the applicable service for which we process that personal data.
• Legal Obligation: Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfill the legal obligation.
• Legal Claim: We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

Notwithstanding the general retention criteria above, financial records, transaction records, identity verification records, and compliance-related records (including KYC/KYB documentation and AML screening records) may be retained for a minimum period required by applicable law, including but not limited to the Bank Secrecy Act and related FinCEN regulations, which generally require retention of certain records for a minimum of five (5) years. We will retain such records for at least the minimum period required by applicable law or our contractual obligations, even if you delete your account or request deletion of your personal information.

Storing and Transferring Your Personal Information

Security: We implement appropriate technical, administrative, and organizational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. We will never send you unsolicited communications requesting your account credentials, password, payment card information, or government-issued identification numbers.

International Transfers of Your Personal Information: Our servers and operations are primarily located in the United States. If you access or use the Services from outside the United States, please be aware that your personal information may be transferred to, stored in, and processed in the United States and in other countries where we or our service providers operate. These countries may have data protection laws that differ from those of your jurisdiction.

Where required by applicable law, and in particular where we transfer personal data from the European Economic Area (“EEA”), the United Kingdom, or Switzerland to a country that has not been recognized as providing an adequate level of data protection, we implement appropriate safeguards designed to protect your personal information. These safeguards may include, as applicable:

• the European Commission's Standard Contractual Clauses for transfers of personal data from the EEA;
• the United Kingdom International Data Transfer Agreement (“IDTA”) or the UK Addendum to the European Commission's Standard Contractual Clauses for transfers of personal data from the United Kingdom;
• standard contractual clauses recognized under applicable Swiss data protection law for transfers of personal data from Switzerland; and/or
• transfers to jurisdictions or recipients recognized as providing an adequate level of data protection by the European Commission, the UK government, the Swiss Federal Council, or other relevant authority, as applicable.

We may also rely on other lawful transfer mechanisms or derogations where available under applicable data protection law.

If you would like more information about our international data transfer practices or the safeguards we use, please contact us at support@adesic.com.

Marketing and Advertising

From time to time, we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by contacting us at support@adesic.com.

Profiling

We may analyze personal data we have collected about you to create a profile of your interests and preferences to help us better understand and improve your use of the services, and so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively send product updates. We may also use personal data about you to detect and reduce fraud. The entering of personal data in our systems is optional and occurs only if consent is given to one of the purposes detailed in the Our Collection and Use of Personal Information section of the Privacy Notice; it automatically implies that Adesic personnel across the world, tasked with data processing, will be able to view the data, as well as to change and to update it.

Your Rights in Respect of Your Personal Information

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a). Right of access. You have the right to obtain: (i) confirmation of whether, and where, we are processing your personal information; (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your personal information; and (iv) a copy of the personal information we hold about you.

(b). Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c). Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d). Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e). Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f). Right to withdraw consent. There are certain circumstances where we require your consent to process your personal information. In these instances, and if you have provided consent, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

You have the right to provide instructions regarding the retention, deletion and disclosure of your personal information after your death. In the absence of instructions from you, it is possible for your heirs to request the disclosure or deletion of your personal information.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office and the Swiss Federal Data Protection and Information Commissioner If you wish to exercise one of these rights, we kindly ask you to contact us at support@adesic.com. Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

Cookies and Similar Technologies Used on Our Services

Our Services use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Services. This helps us to provide you with a good experience when you browse our Services and also allows us to monitor and analyze how you use and interact with our Services so that we can continue to improve our Services. It also helps us and our partners to determine products and services that may be of interest to you. Please see our Cookie Policy for more information about these practices and your choices regarding cookies.

Tracking Technologies Used in Our Emails

Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you. Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client - these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

Processing Method

Personal data will be processed with IT-based tools and/or processed manually for the length of time needed to achieve the purpose for which it was collected. In particular, personal data collected for the purposes outlined in the Our Collection and Use of Personal Information section of the Privacy Notice will also be processed with the usage of automated mechanisms based on procedures and logics that are strictly related to the purposes specified.

California Consumer Privacy Act Disclosures

The following Section applies to California customers only and supplements the information contained in the Privacy Policy.

Rights under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”)

In addition to the rights provided in the Privacy Policy above, the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides consumers (California residents) with specific rights regarding their personal information, subject to limited exceptions. In this Section, we will refer to both the CCPA and CPRA collectively as the “CPRA.” Under the CPRA, “personal information” includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Adesic collects personal information that may be covered by other laws, rules and regulations, including but not limited to the Gramm-Leach-Bliley Act and its related implementing regulations, and, therefore, such personal information may be exempt from the provisions of the CPRA. Although some categories of data collected by Adesic may be exempt from the CPRA, the full list of categories of personal information collected can be found in Section 1 (Our Gathering of Personal Information).

When we talk about the “sale” or “sharing” of personal information, we are also using those terms as they are defined in the CPRA.

This section describes your CPRA rights and explains how to exercise those rights.

• Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You have the right to request that we disclose to you: (a) the categories of personal information we’ve collected about you, (b) the categories of the sources from which the personal information is collected, (c) the business or commercial purposes for collecting, selling, or sharing the personal information, (d) the categories of third parties to whom we’ve disclosed personal information, and (e) the categories of personal information we’ve disclosed for a business purpose, sold, or shared and the third parties to whom we’ve disclosed, sold, or shared that personal information.
• Right to portability (request a copy of your personal information): You have the right to request and receive the specific pieces of personal information we’ve collected about you in a commonly used, machine readable format.
• Right to correct: You have the right to correct inaccurate personal information that we have collected from you and retained.
• Right to delete: You have the right to request that we delete any of the personal information that we’ve collected from you and retained, subject to certain exceptions.
• Right to opt-out of sale and sharing: You may request to opt out of any “sale” or “sharing” of your personal information that may take place.
• Right against discrimination: You have the right not to be discriminated against for exercising any of your CPRA rights.

Do Not Sell or Share Personal Information: Adesic does not sell personal information and does not disclose personal information to data brokers or for monetary consideration. However, Adesic may disclose certain personal information to advertising, marketing, and analytics partners in ways that may constitute “sharing” under the CPRA, including for cross-context behavioral advertising. California residents have the right to opt out of such sharing as described below.

Right to Opt Out of Sale/Sharing: California residents have the right to opt out of the sale or sharing of their personal information. Adesic does not sell personal information. To the extent Adesic engages in “sharing” under the CPRA, California residents may exercise their opt-out rights by submitting a request here.

Adesic also discloses personal information to service providers and contractors that support the operation of the Services, including identity verification, compliance, payment, and transaction infrastructure providers. These disclosures are made to provide the Services and are not disclosures for cross-context behavioral advertising.

The California Privacy regulations require us to state whether we have actual knowledge that we have sold or shared the personal information of consumers under 16 years of age. As stated in our User Agreement, the Services are not for use by anyone under the age of 18. We do not sell or share personal information of consumers we actually know are under 16 years of age.

Only you, or your authorized agent acting on your behalf, may make a request related to your personal information.

Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: your full name, prior communications with Adesic.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. If we are unable to verify your identity from information we have available, we may request additional information from you to verify your identity. If you use an authorized agent to make a request on your behalf, we may require proof from you that they have been authorized directly by you to act on your behalf. We will only use personal information provided in the request to verify the requestor's identity or authority to make it and for security or fraud prevention purposes.

We will respond to your rights request as required under the CPRA. We are only obligated to respond to a request from you, or your authorized agent acting on your behalf, twice within a 12-month period.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Please note that the above rights are not absolute, and we may be entitled to refuse requests in whole or in part, where exceptions under applicable law apply.

Retention of personal information: Please see the “Data Retention” section in the Privacy Policy above for information about how long we retain the personal information we collect.

Additional CPRA disclosures: We have set out below the categories (as defined by the CPRA) of personal information we have collected about California residents in the preceding 12 months with respect to the Services and, for each category of personal information collected, the business or commercial purposes for which the information was collected and used, and the categories of third parties to whom we disclosed the personal information for a business purpose.

Adesic does not sell personal information. However, Adesic may disclose certain personal information to advertising, marketing, and analytics partners in ways that may constitute “sharing” under the CPRA.

Sources of personal information: We collect this personal information directly from California residents themselves, automated technologies, Adesic entities, and third parties. The sources of personal information collected are noted in How We Collect Your Personal Data.