Adorvia’s Privacy Policy describes our practices in connection with information that we collect through our websites. By providing Personal Information to us, you agree to the following terms and conditions of this Privacy Policy.

Scope

Personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This privacy notice applies to the personal information we obtain through our normal business activities, both online and offline i.e. collection in connection with sales and marketing, partner and supplier engagement and investor relations. This Privacy Policy does not apply to personal information obtained through our Careers website, which is subject to the Applicant’s Privacy Notice.

Personal Information We May Collect

“Personal Information” is the information that identifies you as an individual, such as:

• Name

• Postal Address

• Telephone Number

• Email address

• Job description

If you submit any Personal Information relating to someone other than yourself, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We May Collect and Use Personal Information

We may collect Personal Information through our websites.To the extent permitted by applicable law, we may use Personal Information:

• to respond to your inquires and fulfill your requests, such as to send you newsletters or to respond to your questions and comments.

• to send administrative information to you, for example, information regarding changes to our terms, conditions, and policies.

• to provide you with updates and announcement concerning our products, promotions and programs and to send you invitations to participate in special programs.

• to contact you if we have not heard from you in a while.

• for our business purposes, such as analyzing and managing our businesses, market research, audits, developing new products, enhancing our websites, improving our services and products, identifying usage trends, determining the effectiveness of our promotional campaigns, tailoring the websites experience and content based on your past activities, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).

• as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our and/or your rights, privacy, safety or property; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

To the extent permitted by applicable law, your Personal Information may be disclosed:

• to our third-party service providers who, under confidentiality obligations, provide services such as website hosting, data analysis, infrastructure provision, IT services, customer service, email delivery services and other services, to enable them to provide services.

• as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our and your rights, privacy, safety or property; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:

• Demographic information and other information provided by you

• Location information

• Aggregated information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We May Collect Other Information” section below, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

How We May Collect Other Information

We may collect Other Information in a variety of ways, including:

• From you: Information such as hobbies and interests, consumption habits, zip code, and your preferred means of communication, may be collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.

• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the sites (for example, we may use Personal Information to calculated the percentage of our users who have a particular telephone area code)

If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as the information is combined.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the Websites or otherwise to us.

Data controller

The Controller of your data is our company that initially collected your data and decided the purposes and means for using your data.

If you have questions about who the Controller of your data is or any other questions about your data, please contact our Privacy Officer by using the email-address shown below.

Recipients of personal data

Within our company: business functions which require access to your data in order to perform our contractual and legal obligations (i.e. sales, accounting, operations, legal) or for the purpose of our legitimate interests (i.e. marketing).

Third parties: we may use third parties to provide or perform services and functions on our behalf. We may make personal information available to those third parties to perform these services and functions. Any processing of that personal information will be on our instructions and compatible with the original purposes.

As required by law: we may also make personal information available to public or judicial authorities, law enforcement personnel and agencies as required by law, including to meet national security or law enforcement requirements, and including to agencies and courts in the countries where we operate. Where permitted by law, we may also disclose personal information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims, or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions.

Mergers and acquisitions: personal information may be transferred to a party acquiring all or part of the equity or assets of our company or its business operations in the event of a sale, merger, liquidation, dissolution or other.

Affiliates: we may also transfer and share information to our affiliates in compliance with applicable law.

Retention

We will retain your personal information as long as we have an ongoing relationship with you or as long as necessary to achieve the purpose for which it was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law.

Your rights

You have the right to obtain without constraint at reasonable intervals and without excessive delay or expense a copy of all data relating to you that are processed.

You have the right to obtain the rectification or update of inaccurate or out-of-date personal information.

You have the right to erasure of personal data.

You have the right to object, relating to your particular situation, to the processing of your personal data, unless that processing is required by law.  Where the objection is justified, the processing must cease.

You may have the right to request data portability. Data portability is the provision of your personal information in a structured, commonly used and machine-readable form so that it may be transferred to another company easily. The right to data portability is subject to restrictions i.e. data portability does not apply to paper records and must not prejudice the rights of others or sensitive company information.

You have the right not to be subject to decisions based solely on automated decision making if those decisions produce legal effect or significantly affect you.

You have the right to withdraw any consent previously granted for a specific purpose, if consent is the legal basis for the processing of your personal information.

We respect these rights and have processes in place to recognize and respond to individuals wishing to exercise these rights. You may request to exercise any of these rights through your local contact.

Security

We are committed to making sure that your personal information processed is kept secure and has implemented appropriate technical measures and security policies that protect the information it has under its control from:

• Unauthorized access.

• Improper use or disclosure.

• Unauthorized modification.

• Unlawful destruction or accidental loss.

All our personnel and any third parties which we engage to process your personal information are obliged to respect the confidentiality of your information.

Privacy concerns and how to contact us

If you are concerned about an alleged breach of privacy law or any other regulation by us, you can contact us.

If we do not address any of your requests or fail to provide you with a valid reason why we are unable to do so, you have the right to contact supervisory authority to make a complaint.

Changes to our privacy notice

We reserve the right to change, modify and update this privacy notice at any time.  Please check periodically to ensure that you have reviewed the most current notice.

About Policy Updates

We may change this Privacy Policy. Please take a look at the the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on a Site. Your use of the Websites following these changes means that you accept the revised Privacy Policy.