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Privacy policy

Adriawire.com Privacy Policy

Effective Date: June 10th, 2024

This Privacy Policy describes how Adriawire.com ("Adriawire," "we," "us," or "our") collects, uses, and discloses your information when you use our B2B marketplace website (the "Website"). It also describes the choices you have associated with your information and how you can contact us.

1. Introduction

At Adriawire ("we", "our", "us"), we recognize the importance of privacy and the confidentiality of personal information. Adriawire is a business-to-business ("B2B") platform that connects and facilitates sales and purchases of products and services between suppliers ("Sellers") and buyers ("Buyers"). Collectively, the Sellers and Buyers are referred to as the "Users". The Platform is intended for B2B transactions and is available for use by businesses, not individuals for personal use.

This Adriawire Privacy Policy ("Privacy Policy") explains how we collect, process, and disclose information in connection with the operation of the Platform for visitors (i.e., non-registered Platform Users) and the Users, including personal information about visitors and representatives and employees of the Users. This Privacy Policy also applies to your use of the Platform via a mobile device, either through mobile applications or mobile-optimized websites.

If you are from the European Union or the United Kingdom, specific disclosures can be found in the section “7. USERS FROM THE EUROPEAN UNION AND THE UNITED KINGDOM”.

For details on the personal information we collect when you use or interact with other Adriawire services, please refer to the applicable privacy policy for those services.

This Privacy Policy does not apply to the extent we process personal information in the role of a processor or service provider on behalf of other companies.

If you have any questions or concerns about the use of your personal information, please contact us using the contact details provided in the section “11. HOW TO CONTACT US” of this Privacy Policy. All capitalized terms not defined in this Privacy Policy shall have the meanings ascribed to them in the Terms of Use for the Platform.

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2. Details of Data Processing

Below you will find an overview of the types of personal information we process about you and the purposes for which we collect this personal information.

Purpose: Account Administration
We use your information to verify your eligibility to register as a Platform user in accordance with our Terms of Use and to set up/administer user accounts, such as providing log-in IDs and developing a Platform profile.

Data Categories:
- Contact information
- Account information
- Business information
- Social media account information

Purpose: Purchase and Delivery of Products and Services
We use your information to handle orders, deliver products and services on the Platform, process payments, provide logistics and warehousing services, facilitate customs clearance declarations/applications, and offer customer service support.

Data Categories:
- Contact information
- Account information
- Business information
- Transaction information
- Payment information
- Communication information
- User-generated content
- Device information
- Online activity information
- Location information

Purpose: Communicate with You
We use your personal information to facilitate communication between Users and us, and between Buyers and Sellers via the Platform, for processing transactions, assessing fund withdrawal requests from Sellers, and improving our services.

Data Categories:
- Contact information
- Account information
- Transaction information
- Payment information
- Device information
- Location information
- Communication information
- Online activity information

Purpose: Provide Voice, Image, and Camera Services
When you use services requiring access to contents/functions on your devices (e.g., contacts, photos, videos, microphone, camera), we use your personal information to respond to your requests, provide the requested services, and improve our services.

Data Categories:
- Contact information
- User-generated content
- Communication information
- Device information

Purpose: Recommendations and Personalization
We use your personal information to recommend features, products, and services, identify preferences, and personalize your experience. For Buyers, we share details of last-viewed products to enable Sellers to contact you with relevant information. You can opt-out via Buyer Privacy Settings.

Data Categories:
- Contact information
- Business information
- Transaction information
- Online activity information
- Marketing and advertising information
- Location information

Purpose: Marketing and Advertising
We use your personal information to send and serve tailored marketing and advertising based on your Platform use, browsing records, and order history. Cookies or similar technologies may be used for this purpose.

Data Categories:
- Contact information
- Business information
- Transaction information
- Online activity information
- Marketing and advertising information
- Location information

#Purpose: Research and Development
We use your personal information for research or statistical analysis to improve the content and layout of the Platform, and to enhance our product offerings and services.

Data Categories:
- Contact information
- Account information
- Business information
- Device information
- Location information
- Online activity information
- User-generated content
- Social media account information

Purpose: Fraud Prevention and Credit Risks
We use personal information to prevent and detect fraud and abuse, and to protect the security of the Platform. We may also use scoring methods to assess and manage credit risks.

Purpose: Comply with Legal Obligations
In certain cases, we collect and use your personal information to comply with laws, such as verifying your identity and conducting security checks, KYC (know-your-customer), and anti-money laundering due diligence.

Data Categories:
- Contact information
- Account information
- Business information
- Communication information
- Transaction information
- Payment information
- Online activity information

The categories of personal information described above are detailed below:

Information You Provide to Us:
- Contact Information: Name, address, phone number, email address, job title, department, ID information.
- Account Information: Username, password, gender, account settings.
- Business Information: Company name, registration number and date, official website, business type and industry, corporate registration details, business license, proof of business operation.
- Transaction Information: Transaction statements, billing/delivery address, payments, orders.
- Payment Information: Bank account numbers, credit/debit card details, tracking information from cheques or money orders, bank statements.
- Device Content: Contacts, photos, videos, files from your devices.
- Event Information: Contact details collected during trade shows, industry events, etc.

Information That We Collect Automatically:
- Device Information: Device type, unique device identification numbers, IP addresses, browser type, browsing patterns, advertising identifiers.
- Online Activity Information: Page views, searches, content interactions, access times, and duration.
- Location Information: General geographic location, approximate location data of your mobile device.
- Communication Information: Posts, comments, uploaded content.
- Marketing and Advertising Information: Interests based on Platform use, purchases, survey responses, preferences for marketing content, product/service preferences, subscription data.
- User-Generated Content: Profile photos, videos, audio recordings.
- Other Information: Statistical information about Platform visitors, browser software, operating system, software and hardware attributes, sessions, unique visitors.

Information That We Receive from Third Parties:
- Social Media Account Information: Social media username, profile picture, login details.
- Communication Information: Feedback, correspondence with customer support, disputes/complaints, chat information.
- Verification Services: Anti-money laundering, fraud, KYC checks, due diligence, verification information.
- Interactions with Group Companies and Affiliates: Information about interactions with products and services.
- Review and Rating Information: Personal information from third parties conducting reviews or ratings of products/services on the Platform.

Some of this information may be collected using cookies and similar tracking technology, as explained further under our Cookies Policy.

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3. Disclosure or Sharing of Personal Information

We may disclose (or provide access to) personal information to the following categories of recipients:

- Other Platform Users: Where necessary in connection with the facilitation of purchases and communications made between you and other Users.
- Group Companies and Affiliates: Our affiliates and their designated service providers that work with us to provide processing services such as software, tools, systems, and messaging services for purposes described in this Privacy Policy.
- Third-Party Business Partners and Service Providers: Engaged by us or working with us to assist in providing services to you or processing personal information for purposes described in this Privacy Policy or notified to you when we collect your personal information. Categories of these partners or service providers include:
- Business Partners: Partners that offer supplementary services to those provided by us, such as partners that resell our products and services, to the extent you consent to such sharing (where required by applicable law).
- Marketing and Advertising Platforms: Such as Google, Twitter, Facebook, and Instagram, and providers of analytics services relating to Users’ behavior, to tailor the content you see when visiting our Platform. These platforms may combine information collected on our Platform with data from their platforms and other websites for targeted advertising. Some of this information may be collected using cookies and similar tracking technology, as explained further under section 5. “COOKIES” below. The processing activities of these third-party marketing platforms are governed by their own privacy policies.
- Due Diligence and Verification Service Providers: Collect and process personal information to perform due diligence and business verification services.
- Payment Service Providers: Collect and process personal information to assist with settling payments for transactions or process withdrawal requests for Sellers. The activities of payment service providers may be governed by their own privacy policies.
- Credit Risk Assessment Providers: Conduct risk assessments on Sellers to determine if a Seller can be permitted to make a fund withdrawal.
- Logistics Partners: Provide delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers.
- Custom Agents: For customs clearances purposes.
- Cloud Computing Service Providers: Provide cloud storage services.
- Instant Messaging Service Providers: Enable communications between Buyers and Sellers via the Platform.
- Software Development Kit (SDK) Service Providers: Provide SDK services.
- Customer Service Providers: Provide after-sale services.
- Risk Control Service Providers: Assess the security of Users’ accounts and transaction risks.
- Third-Party Rating/Reviewing Service Providers: Carry out reviews of our services with Users who participate in reviewing or rating Adriawire’s products and/or services.

- External Professional Advisers, Law Enforcement Agencies, Insurers, Government, and Regulators: Where it is necessary to comply with applicable laws or to exercise, establish, or defend our legal rights or protect your vital interests or those of any other person.
- Business Acquirers: In connection with any actual or proposed purchase, merger, or acquisition of any part of our business, provided that we inform the acquirer that it must use your personal information only for the purposes disclosed in this Privacy Policy.

We may provide anonymized data to third parties in a de-identified format that does not personally identify you.

We have established relationships with third parties and websites to offer you products and services which we do not offer. We provide access to these other parties and their websites either through hyperlinks to these sites from our Platform or through co-branded sites. In some cases, you may be required to submit personal information to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third-party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information you submit to those third parties. You should read the relevant privacy policy for those third-party sites and co-branded sites before responding to any offers, products, or services advertised by those parties.

The instant messaging service on the Platform is provided by our partner. Partner will collect your chat information and device information and share a copy of your chat information with us. We will use your chat information based on security, risk control, compliance requirements, legal and regulatory requirements, and for services (including but not limited to transaction processing and dispute settlement between Buyers and Sellers, User complaints handling) and other analytical and service needs. You may refer to the applicable privacy policy of DingTalk for more data processing details relating to such service.

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4. Retention

We retain your personal information as long as we have an ongoing legitimate business need to do so, such as to provide services or products to you, or as required or permitted by applicable laws, including tax and accounting laws.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

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5. Cookies

To enable our systems to recognize your browser or device and to provide and improve our services, we or our authorized service providers may use cookies, beacons, and/or other similar technologies (collectively, “Cookies”).

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6. Your Rights

As a user of the Platform, you may have the following data protection rights, which you can exercise pursuant to applicable laws at any time by contacting us using the contact details provided under section 11. “HOW TO CONTACT US” below:

- The right to access, correct, update, or request deletion of your personal information.
- The right to object to the processing of your personal information when it is based on our legitimate interests, and separately, the right to object to direct marketing.
- The right to ask us, in some situations, to restrict the processing of your personal information or request portability of your personal information.
- The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under section 11. “HOW TO CONTACT US” below.
- If we have collected and processed your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. If you live in a jurisdiction that provides for a right to appeal a denial of your request to exercise such rights, you may submit your appeal using the contact details provided under section 11. “HOW TO CONTACT US” below.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

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7. Users from the European Union or the United Kingdom

If you are from the European Union or the United Kingdom, below you will find an overview of the personal information we process about you, the purposes, the legal basis, and where we collect this personal information.

If you need us to provide you with our services or fulfill a contract with you, or because we are required to do so by law, but do not provide us with your personal information, we may be unable to provide our services or fulfill our contractual obligations to you.

Purpose: Account administration
Description: We use your information to verify your eligibility to register as a Platform user in accordance with our Terms of Use, and to set up/administer user accounts, such as providing log-in IDs and developing a Platform profile.

Data Categories:
- Contact information
- Account information
- Business information
- Social media account information

Legal Basis (where applicable):
- Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you
- Art. 6 (1) (f) GDPR - our legitimate interest in the security, stability, and usability of our Platform

Purpose: Purchase and delivery of products and services
Description: We use your information to take and handle orders, deliver products and services on the Platform, process payment, provide logistics and warehousing services via the Platform, facilitate customs clearance declarations/applications via the Platform, and provide Users with customer service support, such as responding to queries, feedback, and managing claims and/or disputes.

Data Categories:
- Contact information
- Account information
- Business information
- Transaction information
- Payment information
- Communication information
- User-generated content
- Device information
- Online activity information
- Location information

Legal Basis (where applicable):
- Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you

Purpose: Communicate with you
Description: We use your personal information to facilitate communication between Users and us, and between the Buyers and Sellers via the Platform, for the purpose of processing transactions and settlement between the Buyers and Sellers made over the Platform, assessing fund withdrawal requests from Sellers, and improving the services and products of the Platform.

Legal Basis (where applicable):
- Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you

Purpose: Provide voice, image, and camera services
Description: When you use services that require access to contents stored in and/or functions on your devices (including but not limited to contacts in address book, photos, videos, microphone, and/or camera), we will use your photos, videos, contact information in your address book, and other personal information to respond to your requests, provide the requested services to you, and improve our services.

Data Categories:
- User-generated content
- Communication information
- Device information

Legal Basis (where applicable):
- Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you
- Art. 6 (1) (f) GDPR - our legitimate interest in improving our services based on the information obtained
- Art. 6 (1) (a) GDPR - your consent

Purpose: Recommendations and personalization
Description: We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with the Platform. If you are a Buyer, we will share details of the last viewed products on the Platform to enable Sellers, their respective affiliates, and/or their third-party services provider to contact you with details of products and/or services that might interest you. You can opt not to share this information with Sellers via the Buyer Privacy Settings here.

Data Categories:
- Contact information
- Business information
- Transaction information
- Online activity information
- Marketing and advertising information
- Location information

Legal Basis (where applicable):
- Art. 6 (1) (a) GDPR - your consent
- Art. 6 (1) (f) GDPR - our legitimate interest in offering recommendations

Purpose: Marketing and advertising
Description: We use your personal information to send and serve you tailored marketing and advertising that we believe will be of interest to you based on the ways in which you use the Platform, your browsing records, and order history. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests. Please see section 5. “COOKIES” below for more information about how we use cookies.

Data Categories:
- Contact information
- Business information
- Transaction information
- Online activity information
- Marketing and advertising information
- Location information

Legal Basis (where applicable):
- Art. 6 (1) (a) GDPR - your consent
- Art. 6 (1) (f) GDPR - our legitimate interest in offering recommendations

Purpose: Research and development
Description: We use your personal information to perform research or statistical analysis in order to improve the content and layout of the Platform, and use your personal information to improve the product offerings and services on Adriawire.com, including, for example, using anonymized data for machine learning purposes.

Legal Basis (where applicable):
- Art. 6 (1) (f) GDPR - our legitimate interest in improving the content and layout of the Platform

Purpose: Fraud prevention and credit risks
Description: We use personal information to prevent and detect fraud and abuse in order to protect the security of the Platform, our customers, and others. We may also use scoring methods to assess and manage credit risks.

Data Categories:
- Contact information
- Account information
- Business information
- Transaction information
- Payment information
- Communication information
- User-generated content
- Device information
- Location information

Legal Basis (where applicable):
- Art. 6 (1) (f) GDPR - our legitimate interest in preventing and detecting fraud and carrying out assessments to evaluate credit risks

Purpose: Comply with legal obligations
Description: In certain cases, we collect and use your personal information to comply with laws. For instance, we use your information to verify your identity and conduct security checks, KYC (know-your-customer), and anti-money laundering due diligence in order to set up user accounts.

Data Categories:
- Contact information
- Account information
- Business information
- Communication information
- Transaction information
- Payment information
- Online activity information

Legal Basis (where applicable):
- Art. 6 (1) (c) GDPR – Compliance with legal obligations

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time. We will advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you with all of our services, and for you to use all the features of our Platform.

For processing operations based on our legitimate interests, we have carried out a legitimate interest assessment to ensure that our interests are not prejudiced by your interests or fundamental rights and freedoms.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under section 11. “HOW TO CONTACT US” below.

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8. International Transfers of Personal Information

At Adriawire, we prioritize the security and protection of your personal information. When you use our platform, we may collect and store your personal information in various locations, including the United States and Germany.

As a global B2B platform, Adriawire understands that there may be instances necessitating the international transfer of users' personal information among the aforementioned countries. These jurisdictions may have differing data protection laws compared to your own country. Rest assured, any international transfers of your personal information will be undertaken solely for legitimate purposes and with a legal basis, or as permitted by applicable law.

We are committed to safeguarding your privacy throughout any international data transfers. Adriawire takes proactive measures to ensure that recipients of your personal information are bound by duties of confidentiality. Additionally, we implement appropriate technical and organizational safeguards in accordance with our Privacy Policy to maintain the security of your personal information. These measures may include employing standard contractual clauses.

For further information regarding these safeguards or to request a copy of the clauses, please reach out to us at DataInfo@adriawire.com.

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9. Security Measures

At Adriawire, we prioritize the security and integrity of your information. We employ suitable technical and organizational measures to prevent unauthorized access to our platform, maintain data accuracy, and ensure the proper utilization of the information we collect.

For registered users of Adriawire, certain personal information can be accessed and managed through your account, which is protected by a password. It is imperative that you keep your password confidential and secure. Under no circumstances should you disclose your password to anyone. Our team members will never request your password through unsolicited phone calls or emails. If you share a computer with others, refrain from saving your login credentials (such as user ID and password) on the shared device. Remember to log out of your account and close your browser window after each session for added security.

While we implement appropriate technical and organizational measures to safeguard the information entrusted to us, it's important to note that no method of data transmission over the internet or wireless networks can be guaranteed to be completely secure. Therefore, while we strive to protect your information, we cannot guarantee the absolute security of any data you transmit to us, and you do so at your own risk.

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10. Changes to This Privacy Policy

Adriawire reserves the right to update this Privacy Policy periodically in response to evolving legal, technical, or business developments. When modifications are made to our Privacy Policy, we will take appropriate measures to inform you, commensurate with the significance of the changes implemented. In cases where we materially alter this Privacy Policy in a manner that diminishes the protection of your previously collected personal information, we will seek your consent.

Any revisions to this Privacy Policy will be communicated by posting an updated version on the Adriawire platform. Once published, the amended Privacy Policy will take immediate effect. You can ascertain the latest update of this Privacy Notice by referring to the "last updated" date indicated at the top of the notice.

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11. How to contact us

You can click here to exercise your rights after accessing your account. And if you have any requests, questions or concerns about our use of your personal information and this Privacy Policy, you can contact our Data Protection Officer at info@adriawire.com.

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