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TREATMENT, PRIVACY, ETHICS AND PERSONAL DATA PROTECTION POLICY. ADA INTELLIGENCE

Validity: July 2024

Hello, welcome to ADA Intelligence, an artificial intelligence created so that people have the possibility to use their data to create their own well-being.

We know that focusing on building an ethical, safe, and reliable platform will allow hundreds of people around the world to access better data that will help them develop better socio-emotional skills that will propel them towards a better life.

But we know that this means we have a huge responsibility to do the right thing with the data we have.

That is why ADA assumes a policy of the highest ethical standards, based on the immovable commitment to never sell personal information, since we recognize that privacy is a human right.

That's why our number one focus is and always will be continuous improvement in the use, storage, protection, analysis, and anonymization of data. We will only use your personal data as set out below.


So how do we actually use your data?
ADA is a system that mixes psychometrics and data science to give organizations, and individuals, the ability to measure socio-emotional ones. therefore, we will use the data they share with us so that they can answer the tests and generate the report that interprets the results obtained from the measurements of socio-emotional skills.

In addition, we gather data from all the different sources we have (after making them fully anonymous) and use them for research or to identify big trends in important areas to improve instruments for measuring socio-emotional skills. We then use this to help other companies make better decisions. When we do this, the data on the major trends in socio-emotional skills is one hundred percent anonymized, guaranteeing the right to privacy.

We believe that our approach to privacy is ethical, humane, safe and responsible with human rights, which is why we have adopted a statement of ethical principles that you can learn about here.

ADA is governed by ethical principles focused on guaranteeing the protection of rights such as Habeas Data, privacy, intimacy, good name, image and autonomy, for this purpose all actions will be governed by principles of good faith, legality, computer self-determination, freedom and transparency.

We will always be 100% clear about how we use your data, and we will always be completely upfront about how we make money as a company.

If all this is fair and clear, and if you would like more information, our Policy on the Processing, Handling and Protection of Personal Data is detailed below.

Better data, better skills, better life.

ADA Intelligence.

ADA Intelligence Privacy Policy

ADA Business Intelligence Corp. operates the www.adaintelligence.comwebsite, ADA Business Intelligence Corp. is a Delaware general corporation. Our address is 2055 Limestone Rd STE 200-C Wilmington, DE 19808. Our contact email address is legal@adaintelligence.com

This Policy applies to all visitors, data subjects, and others who access our Apps and Services ("User(s)" or "You"), including people who purchase the services for their computers ("Subscribers").

Who are we?

We are ADA Business Intelligence Corporation ("ADA", "we", "us" or "our"), and ADA is our friendly representation in the form of a robot of an artificial intelligence, ADA is the one who accompanies you when you are taking a test or test, to measure your socio-emotional skills. ADA will be present when:

ADA allows you to access the Measure of Social-Emotional Skills. ADA uses recognized scientific models such as OCEAN and HEXACO to accurately measure social-emotional skills. Our assessments are based on People Analytics and Data Science, ensuring accurate and valuable results for personal and professional development. Features: Assessments based on OCEAN and HEXACO models; Detailed reports on each skill; Identification of strengths and areas for improvement.

ADA allows you to view and access a dynamic Data Dashboard, a powerful tool that allows companies to access and visualize detailed data about their team's social- emotional skills. With interactive charts and advanced analytics, you'll be able to gain deep, actionable insights.

Features: Interactive graphics and clear visualizations; Global and group statistics; Individual reports detailed by skill.

ADA Generates a Custom Report: according to the answers that users give to the tests within the ADA platform. An automatic report is generated where each user accesses the detailed results of their socio-emotional skills, based on scientific foundations. These reports facilitate individual understanding and offer specific recommendations for ongoing development. Features: Reports tailored to each individual; Specific recommendations for development; Easy access and understanding.

ADA Allows Organizations to Create Custom Tests: Companies can design Assessments that Are Tailored to their Specific Needs. Our software allows the creation of Tests that fit the measurement of the company's socio-emotional skills.

ADA allows companies to create Unlimited Testing: Unrestricted Access for Continuous Assessment. With ADA, companies have access to Unlimited Testing, allowing for continuous assessment of their team's social-emotional skills. This functionality ensures that you will always have up-to-date and relevant data to make informed decisions.

ADA has High Ethical and Scientific Standards: Commitment to Ethics and Science in Every Evaluation, our priority is ethics and scientific accuracy. Our assessments are based on rigorous scientific principles and adhere to the highest ethical standards, ensuring reliable, safe and bias-free data.

We are constantly developing and improving the ADA mobile app, the ADA web app (collectively, the 'Apps'), and the ADA website, so we will also be reporting on new ADA features that we release in the future.

ADA will continue to grow, advance, and learn from its users so that we can provide you with a personalized experience that will be of great help to you.

Important: ADA Usage Statement

Age Restriction: Prohibited Use by Minors: ADA is not designed or intended for use by minors.

Purpose of ADA:

- Social-Emotional Skills Measurement: ADA provides data and metrics on social-emotional skills with the goal of offering ethical, safe, and reliable information to users.

- No Substitution for Professional Advice: The reports and metrics generated by the ADA should not be construed or used as advice, consultation, or

professional advice. They do not replace the need to seek medical, psychological, psychiatric, clinical, mental health, or emotional counseling.

Limitations of Use

- Prohibition of Clinical Use:Numerical data and reports generated by the ADA should not be used as clinical, psychiatric, psychological, or medical measures.

- Objective of the Results: The results provided by ADA are intended to serve as a starting point for users to understand their social-emotional skills.

Subsequently, it is recommended to work with competent professionals to improve these skills on an ongoing basis.

Disclaimer

- Use by Third Parties: ADA is not responsible for the use, interpretation and handling that third parties may give to the data and reports generated by the

platform. The responsibility for interpreting and applying the data lies entirely with the user and any professionals with whom they choose to collaborate.

How is ADA's relationship with Data?

Without access to your personal data and the right to process it as required and set out in this Privacy Policy, ADA cannot perform for you the core functions for which it has been designed.

Your privacy and security are our number one priority and your data is always protected by the strictest levels of processing and security.

This Privacy Policy sets out how and on what basis we collect information about you, and the ways in which you and your data are protected when you use the Apps and our website.

To find out exactly what that means, read on to learn about our data protection principles and how we use your data. Before we get to that, please understand that ADA is a data controller of the personal data that you provide to us or that we collect. 'Data Controller' refers to a company that collects or stores personal data and has the decision-making power to decide what to do with that personal data. Personal data under this privacy policy is any data relating to an individual who is identified or can be identified from the data itself (so it would include things like a name, identification number, or online identifier); See section 2 for more information.

Please read this Privacy Policy carefully to understand how we handle your personal data. By interacting with us in the manner set forth in this Privacy Policy, you confirm that you have read and understood this entire Privacy Policy as it will apply to you.

You have the right to object: You have a number of rights in respect of our use of your personal data, as set out in the "Your Key Rights" section below. The fundamental right you should be aware of is that you can ask us to consider any valid objections you have about our use of your personal data when we process it on the basis of our legitimate interest or that of a third party.

You can exercise this right by emailing us at:

legal@adaintelligence.com.

What does this Privacy Policy contain?

1. An overview of our data protection principles

2. What personal data do we use and how do we use it?

3. Our legal basis for the use of your personal data

4. Your Key Rights

5. Where do we store your personal data?

6. Protecting your personal data

7. Who we share your personal data with

8. How long do we keep your data?

9. Using computers to make decisions about yourself

10. Communicating the benefits of ADA

11. Links to Other Websites

12. Prohibition for Minors

13. Changes to our Privacy Policy

14.Personalized advertising and cookies

15.Data Anonymization.
16.Our contact details and other resources

1. A summary of our Data Protection Principles:

Privacy and security are at the heart of ADA:

We strongly protect and secure the personal data we hold about you.

We will only use your personal data to deliver our Apps to you and create services that generate revenue for us so that we can continue as a business,

while ensuring your privacy and the security of your personal data.

When we track your use of our Apps and website, we do so to continually improve and personalize your experience.

When we reuse your personal data, we do so to avoid asking you for the same data twice and we do so for the same purpose or a purpose that is compatible with the core purpose of ADA.

We may use vendors to help us provide our service, but we restrict the use of your data to what you allow us to do and bind it to data protection laws and strict confidentiality. For more information, please see the 'Who We Share Your Personal Data With' section below.

When data is shared with a partner, they become the data controller of the data they receive and their use of the data thereafter is governed by their

applicable privacy terms and policies.

You are always in control:

If you no longer want your personal account information displayed on the Apps or stored by ADA, you can delete these accounts from the platform or by emailing us at legal@adaintelligence.com

You have the right to be forgotten: You can close your ADA account by emailing us at legal@adaintellignce.com, or through the apps if that feature

is available. We retain your personal data for no longer than is necessary for the purposes for which the personal data is processed. The length of time for which we retain personal data depends on the purposes for which we collect and use it and/or as necessary to comply with applicable laws and to

establish, exercise or defend our legal right.

If ADA or you have provided any data to a partner service that you have accessed through the Apps or the website, that partner may still process that data. You must request the deletion of that data and your right to be forgotten directly with them if you want this to happen.

In understanding these principles, it is important that you recognize that the use of your personal data to personalize your experience with the app and provide you with specific information that is intended to assist you is an integral part of the ADA service we offer you as described. in our Terms and cannot be deactivated. If you prefer that we do not use your personal data in this way, you should not use the ADA service.

2. What Personal Data do we use and how do we use it? What do we mean when we say "personal data"?

Personal data is any data relating to an individual who is identified or can be identified from the data itself (so it would include things like a name, identification number, or online identifier).

You may provide us with personal data when you interact with the Applications, visit our website, or correspond with us.

We (or third parties on our behalf) may collect and use any of the following categories of personal data about you:

Registration Information/Contact Details: Mobile phone number, email, address, country, date of birth, and legal first and last name.

Account Information: Information collected to answer questions from the various questionnaires about social-emotional skills. For example, an emotional intelligence test will ask you about your personal tastes and preferences.

Additional Personal Information: including location, address, device details, interaction tracking data, and data customized by you (e.g., tags, updated

categories), supplemental information that we may request from you from time to time (e.g., education level) or that you choose to provide to us (e.g., signing up for a third-party newsletter). Depending on the services or products you are requesting or purchasing, we may also ask for your date of birth, number of dependents and/or your employment status.

Vulnerability Information**: Information you choose to provide to us in relation to your personal circumstances, such as if you are living with a mental illness or physical disability and/or have difficulty understanding numbers or the written word and/or your life circumstances are causing you difficulty.

Technical Information: Your IP address and general processing or monitoring data for technical and performance purposes.

Support Information: Messages or emails you send to us, as well as anycomments you choose to make on ADA's social media.

Unique Customer Identifier: A reference number that relates to you as an individual.

Mandatory information: data that we are required to retain for reporting or auditing purposes.

*As part of the information provided in the tests, information may be inferred that reveals political beliefs, data about your racial or ethnic origin, political opinions, philosophical beliefs or trade union membership, as well as health data or data relating to your sex life or sexual orientation. We will only display this data where you have made it available to us as part of our provision of services and we will do so in strict compliance with the law and we do not intend to process this special category data.

** As part of your Vulnerability Information, we may process special categories of personal data. For example, if you tell us that you need certain accommodations in the way we communicate with you. We will only retain this data where you have made it available to us as part of our provision of services and we will do so in strict accordance with the law and as set out in the table below.

We use the above personal data for the purposes set out in the table below. You can read more about our legal basis for processing your personal data in section three.

Object / activity

To send you updates about our

app and services if you have

registered on our website.

To stop sending you ADA advertising if you are already a Customer

Send you communications to help you complete your ADA registration.

To register as a customer so you

can use ADA

To identify you as a customer and create your ADA account

To communicate with you about your account and ADA features and benefits and to improve your experience using ADA

To provide the ADA service as explained in our Terms

To understand our customer base

To fulfill offers, promotions and

incentives

To allow you to access and view your data, test results, comparative data with other

members of group, company, and/or work areas. while you are registered for the ADA

service (this information will be automatically updated from time to time)

Suggest products that can meet your needs using our algorithms.

To provide you with information and content relevant to you using our algorithms

To inform other customers about your experience, opinions, recommendations, or whatever you suggest.

To provide customer support and maintain your account

Monitor and improve the ADA Service

Provide a forum for you to receive updates and interact with us and other ADA customers and allow ADA to verify that all participants comply with the ADA forum code of conduct.

To share information for the media or public relations.

To create Research studies, from which all personal data is deleted.

Help other businesses engage new customers more effectively by building audiences excluding ADA customers.

To comply with regulatory and audit requirements.

To investigate customer service inquiries or complaints after closing.

Our legal basis for processing this personal data

Consent

Legitimate interests: to ensure that our advertising is properly targeted

Legitimate interests: to help us grow and develop our business and to assist our customers with the account opening

process.

Fulfilling our contract with you

Fulfilling our contract with you

Perform our contract with you (and the substantial public interest when we process your special category data as part of the Vulnerability Information)

Fulfilling our contract with you

Legitimate interests: Understanding the

demographics, preferences, and behaviors of our users so that we can improve the relevance of ADA to individual customers and grow ADA's business (and the substantial public interest when we process your special category data as part of the Vulnerability Information).

Fulfilling the terms of the offer with you

Consent

Consent (or legitimate interests where we

process historical information for this

purpose)

Legitimate interests: so that we can improve the relevance of ADA to individual and collective customers (companies, institutions, teams, organizations).

Consent

Perform our contract with you (and the

substantial public interest in which we

process your special category data as part of the Vulnerability Information and tailor

our customer service to meet your needs)

Legitimate interests: Track ADA usage and

identify areas where we can improve

performance or functionality (business and

technical)

Legitimate interests: To provide you with a

way to share information with you about

the ADA and other relevant topics, and so

that you can view posts from other users

and post yourself if you wish. You may also

receive emails from us providing you with

information or notifications you request

about changes to the topics.

Consent

Legitimate interests: In order for us to

continue as a business and continue to

provide a service, we may provide

research services, from which all personal

data is deleted, and only anonymized

data will be used. We may also use the

same services to provide potential

customers with generic information.

Legitimate interests: In order for us to

continue as a business and continue to

provide a service, we may provide

information to enable them to create

similar digital audiences to market to. Your

personal information will always be

removed from any advertising audience

so that you do not receive advertising on

the Internet based on your behaviors

identified in the ADA.

Legal obligation

Legitimate interests (and substantial public

interest where we process your special

category data as part of the Vulnerability

Information)

Type(s) of personal data we use for this purpose

Name Email

Registration Information/Contact Details

Registration Information/Contact Details

Registration Information/Contact Details

Unique Client Identifier

Registration Information/Contact Details, Vulnerability Information, Partner Services Information, Additional Personal Information, Account Information, Technical Information

Registration Information/Contact Details, Account Information, Transactional Information, Additional Personal Information, Technical Information, Partner Services Information

Vulnerability information, additional personal information, partner services information.

Registration Information/Contact Details, Partner Services Information, Additional Personal Information, Account Information

Registration information/contact details, account information, additional personal information, vulnerability information, group, team, company information.

Registration information/contact details, account information, additional personal information, vulnerability information, group, team, company information.

Registration information/contact details,

account information, additional personal

information, vulnerability information, group, team, company information.

Alias/Preferred Name

Registration Information, Unique Customer Identifier, Account Information, Vulnerability Information, Technical Information, Support

Information, Partner Services Information

Technical Information, Additional Personal

Information, Partner Services Information

Email address, name, technical information, support information

Registration Information/Contact Details

Account Information, Additional Personal

Information, Partner Services Information

Registration information,

account information.

Required information

Registration Information/Contact Details,

Unique Customer Identifier, Vulnerability Information, Account Information, Technical

Information, Support Information, Partner Services Information

Collection and Protection of Protected Health Information

The ADA recognizes the importance of protecting the privacy and security of users' protected health information. If ADA collects protected health information as part of its social-emotional skills assessment, ADA is committed to complying with the requirements of the United States Health Insurance Portability and Accountability Act (HIPAA) to ensure the privacy and security of this data.

In the event that protected health information is collected, ADA will implement appropriate measures to protect it, including:

Restricted access to protected health information only to authorized personnel who need access to such information to perform their functions.

Implementing technical, physical, and administrative measures to protectprotected health information from unauthorized access, disclosure, alteration, or destruction.

Regular training of staff on privacy and security policies and procedures for protected health information.

Establishing procedures to notify users of any data security breaches affecting their protected health information.

By using the ADA software, users consent to the ADA collecting and processing their protected health information in accordance with the

requirements of HIPAA and other applicable privacy and data protection laws and regulations.

3. Our legal basis for using your personal data

We consider the legal bases for the use of your personal data as set out in this Privacy Policy to be as follows:

(A) Contractual Performance: If you download our App and/or enter our platform and want us to provide our services to you as described in our Terms, we will only be able to perform these services if we are able to process your personal data for this purpose. Therefore, most of our processing of your personal data is necessary to perform the contract we have with you, as described in the "What personal data do we use and how do we use it?" section above.

Please note that if you do not want us to process your personal data for most of the purposes set out above, we will not be able to provide our services to you through the ADA app. Without the use of your data, the ADA app does not make any profit and therefore, if you do not want your personal data to be processed in this way, you should not use the ADA app.

(B) Legal obligations: We will also process your personal data where we are legally required to do so. For example, to:

Prevent and detect security issues.

Comply with laws and regulations, as well as any industry-specific mandatory guidelines and regulations.


(C) Legitimate interest: We also process your personal data on the basis of our legitimate interest or the legitimate interests of others. Our legitimate interests are:

understand the demographics, preferences, and behaviors of our users so that we can improve the relevance of ADA to individual or collective customers.

track the use of the Applications and the website and identify areas where we can improve performance or functionality (business and technical)

continue as a business and continue to provide a service, which means we can (i) provide investigative services, from which all personal data is deleted,

to other businesses in exchange for revenue, or (ii) work with other companies to help them build audiences in exchange for revenue; When we do this, your personally identifiable information will not be used or shared in a manner that allows these companies to market to you..

to help us grow and develop our business and help our customers with their internal processes.

operate our website and our applications generally.

Conduct market research and business development.

Helping potential clients complete their onboarding process.

Provide services to our customers.

invest in and implement new services to benefit our existing customers and attract new customers;

for commercial purposes.

4. Your Key Rights

You have the following rights in relation to your personal data:

Right to object: You have the right to ask us to consider any valid objections you have to our use of your personal data where we process your personal

data on the basis of our legitimate interest or that of a third party.


Right of access: All data you have provided to us is accessible through theApplications. You may request a copy of all personal data you have provided

by emailing us from the email address you use for your ADA account. We can only provide you with the data we have ourselves. Any data a partner holds

about you belongs to that partner. You must request access to that data directly with them. We will help you in any way we can.


Right to data portability: You have the right to ask us to provide your personal data to a third-party service provider.


Right to rectification: You will be able to control your data through the Apps. Where you are unable to change this data through the Apps, you have the right to ask us to rectify any inaccurate or incomplete personal data we hold about you.


Right to erasure: You have the right to ask us to delete your personal data. You may close your ADA account by emailing us at legal@adaintelligence.com, or by using the appropriate feature in the Applications, when available. Please note that the partners you have used may still have data about you. You will need to contact them directly to have this data deleted.


Right to restrict the use of your personal data: You have the right to ask us to restrict the way we process your personal data in certain specific circumstances. We will also pass on your request to other recipients of your personal data, unless this is impossible or involves disproportionate effort.

If you wish to exercise any of the rights set out above, please email us at legal@adaintelligence.com. We aim to respond to all requests within one month. Sometimes, it may take us longer than a month if your request is particularly complex or if you have made multiple requests. In this case, we will notify you and keep you informed.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who does not have the right to receive it. We may also contact you to request more information in relation to your request to expedite our response.

Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example, if we need to continue to use the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.


5. Where do we store your personal data?

Your personal data is processed and stored in secure IT systems located in: the United Kingdom, the European Economic Area and the USA. The following providers may store or access your personal data:

Amazon Web Services – ADA Hosting Platform (EEA – Ireland)

If we provide personal data about you to any of the providers outside of the United States listed above, we will take appropriate steps to ensure that the recipient adequately protects your personal data in accordance with this Privacy Policy. These measures may include:

ensure that there is an appropriateness decision by the United States Government in the case of transfers outside the United States, which means

that the receiving country is deemed to provide adequate protection for such personal data;;

when we have standard model contractual agreements with the recipient that have been approved by the United States Government. These Model Contractual Clauses include certain safeguards to protect personal data.

Partners and services that you choose to use through the ADA service may choose to store your data in other countries or parts of the world. We encourage you to read their privacy policies carefully. When you use a partner service, the partner or our apps will provide you with easy access to these privacy policies.

International Data Transfer and Privacy Shield Compliance

ADA recognizes the importance of protecting the privacy and security of the personal data of European and Swiss citizens. If ADA collects data from European or Swiss citizens, it is committed to complying with the Privacy Principles of the EU- U.S. Privacy Shield Framework. U.S. and Switzerland-U.S. The U.S. Department of Homeland Security is a U.S. data carrier for transatlantic data transfer.

In the case of the transfer of data of European or Swiss citizens, ADA will guarantee the following:

Compliance with the Privacy Shield Framework Privacy Principles U.S. and Switzerland-U.S. Notice and Choice Principles, including the principles of

notice, choice, accountability for onward transfer, data security, data integrity, and purpose limitation.

Protection of the personal data transferred through appropriate technical and organisational measures to ensure its security and confidentiality.

Provision of appropriate mechanisms for European and Swiss citizens to exercise their rights in relation to their transferred personal data, including

access, rectification, deletion, restriction of processing and objection to processing.

Collaboration with the relevant data protection authorities in the event of complaints or disputes relating to the transfer of transatlantic data.

By using ADA's software, European and Swiss citizens agree that ADA may transfer their personal data outside of the European Union or Switzerland and that this data will be processed in accordance with the Privacy Principles of the EU-U.S. Privacy Shield Framework. U.S. and Switzerland-U.S. U.S.

6. Protecting your personal data

We are committed to ensuring that your personal data is secure.

To prevent unauthorized access to or disclosure of your personal data, we have put in place appropriate physical, electronic, and operational procedures to safeguard and protect your personal data. For example, we protect your personal data by implementing a secure socket layer (a security protocol) and high-standard encryption algorithms. We also ensure that we comply with the security standards imposed by law that are applicable to the operation of the ADA.

Help us help you: To help us protect your personal data, you must comply with our security policies and procedures which we may notify you about in our Terms from time to time.

7. Who we share your personal data with Suppliers, regulators and authorities

We will only share your personal data on a very limited basis. This will happen when (1) it is in our legitimate interest to do so in order to manage, grow, and develop our business, (2) you have consented to our sharing of the information so that we can provide you with the ADA product features you have requested. (3) if we are required to disclose it to comply with any legal obligation, or (4) to enforce or apply our Terms.

We may share your personal data with the following:

Our service providers (including their subcontractors). This may happen when they help us run our service or the technological systems necessary to operate our website, application and services. These are:

Supplier

Amazon Web Services

Create it

Objective

Data Storage Provider

Platform for technological support and development

Data Location

European Economic Area (Ireland), United States, United Kingdom.

Singapore, European Economic

Area.

Companies associated with ADA as sales representatives, distributors of ADA products or services, as part of overall corporate management, may submit ADA advertisements, complete behavioral analysis, or provide customer support in connection with ADA's promotion of their products or services.

Regulators in relation to their functions.

Data protection agencies and law enforcement agencies, where we need to help them do their jobs.

We will always ensure that third parties with whom we share your personal data are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

We may also disclose and use anonymized and aggregated reports and statistics about users of our apps and website for the purpose of informing third parties for industry analysis (and we may be paid for this) and for our marketing and promotional purposes (see the section on Communicating ADA Benefits for more information). None of these anonymized and aggregated reports or statistics will allow our users to be personally identified.

Except as expressly detailed above, we will never share, sell or rent any of your personal data to any third party without notifying you and, where necessary,

obtaining your consent. If you have consented to our use of your personal data in a particular way, but then change your mind, you must contact us and we will stop doing so.

8. How long do we keep your data?

We retain your personal data for no longer than is necessary for the purposes for which the personal data is processed. The length of time for which we retain personal data depends on the purposes for which we collect and use it and/or as necessary to comply with applicable laws and to establish, exercise or defend our legal right.

If you do not log in to the Applications for a significant period of time, we will close your ADA account and delete all data we have about you. We will always try to contact you first before doing this to give you the opportunity to request that your account remain open. If we delete your data, it means that if you wish to use the Apps after that time, you will need to register as a new user.

9. Using our algorithms

ADA is designed to process your personal data to measure your social-emotional skills, analyze your data, make reports, comparative charts, and make suggestions designed to help you better understand yourself through your data and achieve a lifetime of well-being. We store information about you in our systems to make decisions about which products and services to suggest to you using algorithms.

10. Communicate the benefits of ADA

We want to share the benefits that ADA can provide to all future users in the Americas, Europe, Asia, Oceania, and the rest of the world, so the data we collect could be used anonymously in communications such as:

Blog posts and infographics

emails

Social media posts 

Marketing campaigns.

All data we use to support the above is always anonymized and aggregated and can never be traced back to you personally.

11. Links to Other Websites

Our apps contain hyperlinks to and from the websites or apps of our partners and other third parties. All hyperlinks we provide are there to help you access our partners' services and are for your reference and convenience, or they may be used to understand the actions you have taken to enable us to improve the service we offer or fulfill the offers. When we provide hyperlinks to other websites, we are sometimes paid by the partner or third party. If we are paid when you use the hyperlink on our Apps to purchase a third-party product or service, this is clearly stated.

This Privacy Policy only applies to personal data that we collect or receive from third- party sources, and we are not responsible for personal data about you that is collected and stored by third parties. Third-party websites have their own terms and conditions and privacy policies, and you should read them carefully before submitting personal data to these websites. We do not accept any responsibility for the content of third-party websites or third-party terms and conditions or policies.

12. Prohibition for Minors

You must be 18 years of age or older to use our ADA service. Our website and apps are not directed to children under the age of 18 and we do not intentionally collect any personal data from visitors in this age group.

If you are under the age of 18 and we learn that we have inadvertently obtained your personal data from our website, apps, or any other source, we will delete that information as soon as possible.

Please contact us at legal@adaintelligence.com, if you know that we may have inadvertently collected personal data from a child under the age of 18.

13. Personalized advertising and cookies

We also use personalized online advertising to inform you about our Apps and our products and services. This means that you may see advertising for our Apps, products, and services when you are on other third-party websites, including social media platforms.

We use the Facebook pixel on our website and apps, which is triggered when you interact with one of our ads on Facebook. When you click on a Facebook ad and are redirected to our website or apps, the Facebook pixel tracks your behavior on our website or apps and if you take an action, the Facebook pixel will let us know. This allows us to measure the effectiveness of our Facebook ads for statistical and market research purposes and helps us target our ads.

When you use Facebook Pixel, the ads you see are personalized while you're using Facebook, through Facebook's Custom Audiences tool. When you browse our website and apps, information about your browsing session is sent to Facebook, along with a hashed version of your Facebook ID and the URL visited. When you use Facebook, you will be shown personalized ads based on your experience while using our website or app.

You can learn more about how Facebook processes your personal data in its Data Policy here: https://www.facebook.com/policy.php You can opt out of Facebook Pixel's collection of your personal data, or the use of your personal data for the purpose of displaying Facebook ads using Custom Audiences using this link.

We may use and support one or more Google tools, including Google Marketing Platform, Google Analytics (including Universal Analytics), Google AdWords (including Smart Pixel), Google Developer Console, Google Display Advertising, and Google Customer Match, which may include one or more of the following features:

remarketing

Google Display Network impression reports;

the integration of DoubleClick Campaign Manager

Google Analytics Demographics and Interest Reports.

We use these tools to better understand you and our other users, to deliver personalized online advertising to you and others like you on Google properties

(such as YouTube and Google Maps), and to measure the effectiveness of our Google ads for statistical and market research. purposes so that we can better target our ads. Some of these tools also use cookies, so please see our Cookie Policy below for more details.

You can opt out of receiving advertising from Google by visiting Google's ads settings page.

Cookies policy

What cookies does ADA use?

ADA uses third-party cookies (meaning that cookies are provided by third parties and are not owned by ADA) to keep track of when you visit our Apps or website and what you watch. By understanding which areas of our apps or website are the most popular and where visitors spend their time, we can improve performance for everyone.

We also use third-party cookies to enable us to:

Find out if our advertising encourages people to download or access our apps or visit our website.

Show you ADA-related advertising and content. For example, if you visit the Apps and see a page that provides information about how to be part of our beta release, but you do not register, we may use cookies to show you advertising in the future to remind you about ADA, such as the ADA. something that interests you.

The table below shows the third-party cookies that ADA uses and why we use them:

Tracking - third-party cookies

Who does it serve?

Google Analytics

Google Tag Manager

What's he doing

It allows us to remember that you visited our app and website so that we can provide you with relevant content in the future.

It allows us to manage tracking tags within the website.

Advertising - third-party cookies

Who You Serve

LinkedIn Ads

Google Adwords Conversion Google Dynamic Remarketing

Facebook, Facebook Connect, Instagram, WhatsApp Custom Audience

Tik Tok

What's he doing

It lets us know if you have visited our website from an ad we place on LinkedIn, so we can understand how effective our advertising is.

It allows us to track website visits from our ads displayed on Google and to show you content in the future that we think you may find relevant or

interesting.

It allows us to track website visits from our ads displayed on Facebook

platforms and to show you content in the future that we think you may find relevant or interesting.

It allows us to measure the performance of our social media advertising on TikTok.

In relation to our website and web application, we will ask you if you agree to our use of cookies when you use our website or web application for the first time. You can choose which specific cookies you accept. These preferences will be remembered for one year; However, you can disable or manage your cookie preferences at any time. You can also delete cookies if you wish by using the settings on your browser or mobile phone.

If you disable or delete cookies, you may still see ADA advertising, but these ads will be general and will not be tailored to you based on your visits to the Apps or website.

14. Data Anonymization Policy

Process of Anonymization and Privacy Protection

ADA recognizes the importance of protecting the privacy and confidentiality of user data. Therefore, we will implement a data anonymization process that complies with the following principles:

1) Objective of the Anonymization Process: The purpose of the anonymization process is to eliminate or minimize the risks of re-identification of anonymized data, maintaining the veracity of the results of the processing of the same. This means that anonymized data must ensure that any subsequent operation or processing does not distort the actual data.

2) Maintenance of Data Integrity: The anonymization process will be designed so that a massive analysis of anonymized data does not differ from the analysis that would be obtained with non-anonymized data.

3) Breaking the Chain of Identification: In the process of anonymization, there will be a break in the chain of identification of people, which is made up of microdata or direct identification data and indirect identification data. Microdata allows for the direct identification of individuals, while indirect identification data can enable the re-identification of individuals.

4) Prevention of Reidentification: The consequences of a possible re- identification of persons that could cause damage or reduction of their rights will be foreseen. In addition, measures will be taken to prevent a hypothetical loss of information due to staff negligence, lack of an adequate anonymization policy or intentional disclosure that may lead to the loss of the identification variables of individuals.

By using ADA software, users agree that their data may be anonymized in accordance with the principles and procedures set forth above to protect their privacy and confidentiality.

15. Policy Review and Update

Commitment to review and update the policy periodically to ensure that it remains effective and complies with legal requirements and privacy best practices.

We may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, when a material update is made, will be provided to you via email or other appropriate manner.

Regulatory Framework Applicable to Data Protection

Región

Europe

United States

Latin America and the

Caribbean

Regulatory Framework

GDPR General Data Protection Regulation

Health Insurance Portability and Accountability Act (HIPAA) California Consumer Privacy Act (CCPA):

Personal Data Protection Standards for Ibero-American States

Clause for Users in the European Union

Data Protection and Privacy

ADA Business Intelligence Corp. is committed to protecting the privacy and personal data of users in the European Union in accordance with the General Data Protection Regulation (GDPR).

Data Controller

ADA Business Intelligence Corp., located at [address], is the controller of your personal data.

Purpose of the Processing

Your personal data will be processed for the following purposes:

To provide and improve our services.

Comply with our contractual and legal obligations.

Send marketing communications and updates, provided we have your consent.

User Rights


As a user in the European Union, you have the following rights under the GDPR:

Right of access: You may request access to the personal data we hold about you.

Right to rectification: You can request the correction of inaccurate or incomplete personal data.

Right to erasure: You can request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected.

Right to restriction of processing: You may request the restriction of the processing of your data in certain circumstances.

Right to data portability: You can request to receive your personal data in a structured, commonly used and machine-readable format, and transmit it to another data controller.

Right to object: You can object to the processing of your personal data in certain circumstances.

Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing of your data, including profiling.

International Data Transfers

ADA Business Intelligence Corp. may transfer your personal data outside of the European Economic Area (EEA). When we do so, we will ensure that transfers are made in accordance with applicable data protection laws and appropriate safeguards are in place.

Contact to Exercise Your Rights

To exercise your rights or if you have any questions about our privacy policy, you can contact our Data Protection Officer at legal@adaintelligence.com

Governing Law and Jurisdiction

These terms and conditions, as well as any disputes arising in connection with them, shall be governed by the laws of "your country of residence in the EU", without regard to its conflict of law principles. Any disputes will be resolved by the competent courts of the country of your residence in the EU.

16. Our contact details and other resources

ADA is a registered trademark as: ADA Business Intelligence Corp. operator of the www.adaintelligence.com, website, ADA Business Intelligence Corp. is a general corporation of Delaware. Our address is 2055 Limestone Rd STE 200-C Wilmington, DE 19808. Our contact email address is legal@adaintelligence.com

If you have any questions about our privacy policy or our collection, use, or storage of your personal data, please email legal@adaintelligence.com

Learn about our Terms and Conditions

Learn about the ADA Privacy and Data Protection Complaint Questions, Complaints, Complaints, Procedures.

Learn about the ADA Privacy and Data Protection Complaint Questions, Complaints, Complaints, Procedures.

Valid July 2024.

Transform your data into professional development
ADA Take care of your Data

ADA Intelligence is designed exclusively for adults.

 
Disclaimer: The reports and metrics generated by ADA should not be interpreted or used as professional medical advice, consultation, or guidance. They do not replace the need for medical, psychological, psychiatric, clinical, mental, or emotional health counseling when necessary. ADA is not designed to assist in crises such as abuse, severe mental health conditions that may cause suicidal thoughts, self-harm, or any other medical emergency. ADA does not offer, nor will it offer, medical or clinical counseling.

You must be at least 18 years old to use ADA. Please read the Terms of Service and the Ethics and Privacy Policy to understand your rights and responsibilities as an adult user before using ADA. ADA is intended to be used only by responsible adults.

At ADA Intelligence, we believe that artificial intelligence has the potential to positively transform the world, and we are committed to ensuring that this potential is realized in an ethical, responsible manner, focused on human rights and well-being. The UNESCO principles for AI will guide our actions and decisions as we continue to advance the development of new applications for ADA Intelligence.