Effective on FEV 14, 2022

Glossary:
“AES”, “Adelphia”, “We”, “Us” : Adelphia Emerging Sciences S.A

“Users”, “User” : Every person that uses AES products and applications

“Applications”, “App” : AES Sites, Products and Services

“Data”, “Personal Data”, “Personal Information”, “User Data” : All kind of data relevant to the use of AES Applications, either provided by the user or collected automatically.

“Privacy and Cookie Policy”, “PCP” : the present document containing the privacy policy when using our Applications

Our company overview

Adelphia Emerging Sciences S.A. develops innovative technologies to prevent and detect online crime. In particular, we provide secure regulatory solutions and reliable reporting in the areas of risk management, identity fraud and fraudulent transactions so as to ensure transparency and consistency within the regulatory compliance framework.

1. Owner and Data Controller

Data controller within the meaning of the General Data Protection Regulation (“GDPR”) and other national data protection laws of the member states as well as other data protection regulations is:

Adelphia Emerging Sciences S.A.
3, Krushevo str,
2700 Blagoevgrad
Bulgaria

Represented by:
CEO :
Aristo Theodoropoulos

Data Protection Officer :
Hippocrates Papadimitrakos

In case of questions, comments or feedback regarding this Privacy and Cookie Policy, or any other privacy or security matter, a user may contact Us by email at privacy @ adelphiasciences.com.

2. General data processing information

As AES recognizes the need for the protection and the management of users personal information, we have adopted the present Privacy and Cookie Policy. It aims to assist our users in understanding what information we collect and how that information is used and shared, by keeping always their private details secured and safe.

This Privacy Policy document applies to the information AES collects when a user accesses, downloads, or otherwise uses our applications (web & mobile). Users must consent to the terms of this Privacy and Cookies Policy to be able to proceed in using our Applications. All users should first read and agree to our Privacy and Cookies Policy and the relevant personal data use practices AES applies. All kind of information we may collect is exclusively for continuing and improving our services. AES may collect personal information that users provide to Us directly, when they register in our platform, or via cookies, when they visit our Sites.

3. How and what information we collect

AES collects and manages users personal data only to the extent necessary to provide functional Applications, regarding its content and services. Unless otherwise stated in this Policy document, the processing of personal data takes place only after prior consent of the user itself (Art. 6 (1) (a) GDPR).

Among the types of personal data that this application may process independently or through third parties, there are:

  • tracking data;
  • usage data;
  • data communicated while using the service.

Complete details on each type of personal data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection.

Personal data may be freely provided by the User, or, in case of usage data, may get collected automatically when using this Application, provided that any necessary consent has already been given if necessary (device location for instance). Unless specified otherwise, all Data requested by this Application are indispensable and failure to provide them may make it impossible for our Application to provide its services. In case this Application specifically states that some Data are not necessary, users can avoid to communicate them, without consequences to the availability of the Service. Users who are uncertain about which personal data are indispensable, they are welcome to contact the Owner.

Ways we may collect information through our Applications:

a. Direct way
For example, when a user completes a contact form in one of our Sites, we collect the information he/she includes in such form (name, phone number, email address, etc.). We may also collect personal information provided directly to Us in the case of a business transaction. This information may include User’s name, phone number, email address, postal address, IP address, job title, place of work, and other transactional information relevant to our Product or to our Services.

We may collect similar information when a user contacts Us directly via email or telephone, or during any business-related events, trade shows, sales or marketing activities held by Us or by third parties. When a user speaks with our customer service or sales representative on the phone, his/her calls may be recorded and/or monitored for quality assurance or training purposes. In certain circumstances, we may collect User’s VAT registered number for purposes only such as the tax reporting relating to a payment for a customer referral, or to facilitate a money transfer.

b. Cookies
Cookies are small files of letters and numbers that we store on users browser when they visit our Applications. Cookies provide Us with feedback about their searches and interests. They also help Us track users, conduct research, allow users to back click to earlier pages and improve our content and services to them.

We are using cookies to automatically collect information that will be helpful to users experience and to Us. Whatever personal information AES collects, it is processed according to the legislation and to our guidelines, as presented in the current document.

There are cookies that we own and give Us directly the information we value as worthy, and cookies that belong to third parties that are our providers. Some of the cookies remain activated as long as a user is online and some others offline. The offline ones allow Us to recognize User’s device immediately when a user is back online.

The reason we use cookies is to help Us:

  • improve the functionality of our Applications, by monitoring the occurrence of any problems or delays to our services
  • market and promote our products and services by publishing our suggestions and recommendations that users might be interested in according to their usage habits·
  • measure or understand the effectiveness of our advertising activities·
  • improve our services according to users’ needs and expectations by keeping a valuable record of their usage habits·
  • make sure that all our programs are working properly·
  • reply fast at enquiries, assessing users’ history with us·
  • prevent fraud, violations of our acceptable use policies, and unlawful activities·

In order to allow the use of our cookies, users must previously accept them. Users can deny the use of cookies by declining to accept, using the relevant button on the consent form. Moreover users can delete all the cookies that are already on his/her computer and can set most browsers to prevent them from being placed. However, by doing this, users have to manually adjust some preferences every time they visit our Applications, and some services and functionalities may not work. Generally, it is the user who has the control by accepting, denying or deleting cookies, except from those that are strictly necessary for our services. Strictly necessary cookies are those required to log into secure areas of our Applications.

c. Logs
When a user uses our Sites, Products and Services, we may automatically log and collect certain information in electronic records (“Logs”). This may include who (e.g. name, user name) accessed the Sites, Products and Services that were accessed, how the Sites Products and Services were accessed, the dates and times remained in Sites, Products and Services that were accessed, from which geographical location the Sites have been approached and the results of the requests which have been done. Certain privacy and data protection laws may consider Logs as personal information. Logs may be retained locally within the Product or may be transmitted to and stored in our infrastructure, which may include our hosted infrastructure.

From time to time, we may combine the information we receive from other sources with the information the user gives Us and information we collect about the user for authentication reasons. we may supplement the information the user gives Us with information from other sources, such as information validating his/her address, information based on User’s zip code or location to improve the accuracy of the records we hold. These sources must have User’s consent and be legally allowed to provide their personal information to us.

d. Product Data and License Validation
Like most software providers and operators of cloud services, when our Products are used, we collect information relating to the access, usage, and performance of our Products, including data generated in connection with their use (e.g., analytics data, statistics data and performance data), hereby called “Product Data”. Certain privacy and data protection laws may consider product data as personal information. We also collect any personal information required to validate Product licenses.

e. Device and mobile information
This information may include User’s internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This automatically collected log information can be associated with other information we collect about our users while they use our Products or Apps. A Product that is downloaded and deployed to a mobile device by the user via an Adelphia Application, automatically records information that may include: addresses from the network card in or used with their devices; web requests, Internet Protocol addresses, phone numbers, browser types, browser languages, the date and time of request; and other information regarding internet connection activities.

In addition, the information collected and tracked depends upon the system configurations chosen by the administrator and the options enabled by the users and may include:

  • device location, device identifier and device user name;
  • status of the mobile device SIM card; MAC addresses and device serial numbers;
  • phone number, signal strength, cell tower, carrier, IMEI#, and other WWAN attributes;
  • first and last name and email address of the device user;
  • device check-out/check-in;
  • who uses which device, as well as the physical status of the device at the start of a session and then again at the end of a session;
  • applications loaded on the device (excluding content);
  • real-time GPS location tracking and mapping, including analysis of location data and history;
  • or mobile device remote control, including screen capture.

f. Information about the location of User’s device.
In order to guarantee the security of our services, we may collect information relevant to the type of the user’s device and/or track certain information that is derived from the use of our products, such as usage patterns, travel patterns, web site page views and traffic patterns. We may as well use this tracking and location information for statistical purposes to improve our products and services and to help users manage their environment and infrastructure more efficiently. Provided that this location relevant information is not required to be retained for legal proceedings, court orders, or legal processes, it will be deleted every six (6) months, unless it has been anonymized and does no longer contain personally identifiable data.

4. How we use the Information we collect

Adelphia may use the information collected through its applications in the following ways:

  • to review the quality and improve the functionality of its Applications;
  • to improve how its applications work with the User’s device;
  • to provide anonymized user analytics and industry benchmarking;
  • to share only anonymized data with third parties (like hosting partners and others);

Our applications may use tracking data for authentication reasons only based on User’s public IP. Tracking of these details only occurs during the authentication process. Also, we may use the personal information we collect in furtherance of our legitimate interests in operating our business, including our Sites, Products and Services. More specifically, we may use personal information to:

  • provide, make available, and/or troubleshoot and maintain our Sites, Products, and Services;
  • set up a user account for our Products or Services;
  • process and complete transactions, and send related information, including transaction confirmations and invoices;
  • improve our marketing and promotional activities ;
  • improve our Sites, Products, and Services, including the content, functionality and usability;
  • validate licenses;
  • investigate and prevent fraudulent activities, unauthorized access to the Products or Services, and other illegal activities;
  • provide users with effective customer service;
  • contact users with information and notices related to their use of our Sites, Products, and Services;
  • contact users about exclusive offers and other information we believe will be of interest, if this is in accordance with users marketing preferences;
  • invite users to participate in surveys in order to understand better their needs and interests and provide Us their feedback ;
  • conduct internal research and development activities.

All kind of information we collect and use that may be considered as personal information, will be under applicable data protection laws, as required by regulations.

5. How we Share Information we May Collect

We may share information with an external provider, in case we shall use third party services within our Products. Our providers might assist Us in providing products or services such as handling the processing and delivery of mailings, providing customer support, hosting websites, do the customer billing, processing transactions, or performing statistical analysis of our services. Those companies will be permitted to obtain only the necessary information required to deliver their services and they are committed in keeping that information secure and confidential. Using the information we share for any other purpose is strictly prohibited.

We may disclose any information we collect from users also, only and if an action is necessary to be taken:

(a) to comply with any law, judicial proceeding, possible government request, court order or any legal process;

(b) to protect and defend the rights or the property of Adelphia;

(c) to secure and protect the safety of our users;

(d) to detect and prevent fraud, spam, malware, identity theft or other unauthorized access to or unlawful activity for security or technical issues;

or (e) to act in urgent circumstances or emergencies.

We will inform our users via email and/or a prominent notice on our website If we get acquired by or merged with a third party, for any change in ownership, about changes in the use of their personal information, and the evolution of the choices users may have regarding their personal information. Provided that such third party agrees and guarantees to maintain procedures no less protective than those found in our Privacy Policy and always according to the law.

Users may opt-out of related collection of information by uninstalling our mobile applications from their device or stop visiting our existing web Applications. In that case their mobile device log-data will be removed from our logs within six (6) months. Additional data, related to the services users are still using our Apps for, such as user identity, will not be removed by that process. Data will remain in service until users ask for the deletion of their data, or when User’s customer relationship with Us is terminated.

6. Safety of Users Privacy

We guarantee that users personal data information are secured, always used only for internal purposes and will never be published. We responsibly take care of the security of users personal information that they provide to us. We use all the necessary equipment and trained staff to secure and protect the users personal information.

Our risk protection is in accordance with the most efficient systems existing, secured in all levels to determine any way of processing users personal information, included any possible third parties.

Users should take notice and be very careful with whom they share their private information, as internet on its own cannot guarantee privacy. Users should keep their account password secret. Also, the users should let Us know immediately if they have suspicions that their password was compromised. Users are responsible for any activity of their account by the time they are logging in using their account password or other credentials.

7. Data Protection and User Rights

The data are located in Europe Union.

Under the European Union’s General Data Protection Regulation (“GDPR”), we rely on the following legal grounds to process our users personal information :

Compliance with the law – In 2certain circumstances we may be obliged to process users data in order to comply with legal obligations to which AES is subject.

Consent – Some of the personal information we may collect is provided by our users voluntarily, for example when they sign up to join a mailing list or register for an event and is therefore collected and used with their permission. If a user desires to withdraw his/her consent to such use, they can contact Us at privacy @ adelphiasciences.com

Legitimate interests – We may use users personal information for our legitimate interests, such as to improve our products and services and the content on Adelphia websites. We may also use user contact information to keep them and others who have provided Us with their contact information up-to-date on recent product and service developments.

As permitted by law, users have the right to access any of their personal data that is stored as well as its origin and the purpose for which their data have been processed. Users have also the right to have this data corrected, blocked or deleted from our data base. It is the users right to withdraw their consent on collected and processed personal information that they had consented to share, but that right cannot be retroactive.

The present Privacy and Cookie Policy may be occasionally updated. We will notify users regarding any changes to this Policy by posting an updated version on our Applications. We will post a notice at the top of the PCP page, notifying users when it is updated or modified in a material way.

All of our applications are provided on “As-Is” basis, without any warranties, service levels or service level credits.

8. Children protection

Individuals under the age of 16 are prohibited to use our Applications. Should we identify an underaged User, we will promptly remove that person’s personal data from our records immediately.