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ADA Pathfinder Technologies, Inc. is firmly committed to safeguarding the online privacy of its users. This document, in accordance with Article 13 of EU Regulation 2016/679 (“Regulation”), aims to inform you about our privacy policy, the handling of your personal information while using our site (“Site”), and, where applicable, to explicitly and knowingly seek your consent for processing your personal data. The information and data provided by you or acquired during the utilization of services such as purchasing, information requests, technical assistance, promotions, and commercial newsletters, as well as the qualification of the ADA Pathfinder Technologies, Inc. partner network, e.g., access to the site’s restricted area (collectively referred to as “Services”), will be processed according to the Regulation’s provisions and the confidentiality obligations guiding the activities of ADA Pathfinder Technologies, Inc..

The processing conducted by ADA Pathfinder Technologies, Inc., as per the Regulation’s guidelines, will adhere to principles of legality, fairness, transparency, purpose limitation, data minimization, accuracy, integrity, and confidentiality.

Table of Contents

1. Data Controller

The data processing entity responsible for actions on the Site is ADA Pathfinder Technologies, Inc. as defined earlier. For inquiries concerning personal data processing by ADA Pathfinder Technologies, Inc., including details about data processors handling information, contact us at: info@pathfinderada.com

2. Processed Personal Data

During Site navigation, ADA Pathfinder Technologies, Inc. may process personal data, potentially comprising identifiers like names, identification numbers, online IDs, or other elements linked to your physical, physiological, psychological, economic, cultural, or social identity that facilitate your identification or recognition (henceforth, “Personal Data”).

The Personal Data processed via the Site include:

1. Navigation Data:

As part of the Site’s regular operation, computer systems and software procedures collect specific personal data that are inherently transmitted when using internet communication protocols. Although not intended to link to identifiable users, this data could, in some circumstances, lead to identification when combined with information held by third parties. This data includes IP addresses, domain names of connecting computers, URIs of requested resources, request times, submission methods, server response sizes, and more. It is used to gather anonymous statistical website information and ensure proper functioning, and is deleted immediately after processing, unless needed for addressing potential computer crimes.

1. Special Categories of Personal Data:

While using the “Work with Us/Job Offers” section, you might input data falling under Article 9 of the Regulation. These are categories revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, union memberships, genetic data, biometric data, health information, sexual life, or sexual orientation. We encourage sharing this data only when necessary. Remember, for special categories of Personal Data, explicit consent is vital. In the absence of such consent, data like this shared without consent will be processed as per Article 9(1)(e) of the Regulation.

1. Voluntarily Provided Data:

In utilizing specific Site Services, you might transmit Personal Data to third parties via ADA Pathfinder Technologies, Inc.. In these cases, you are an independent data controller, assuming all related legal responsibilities. You ensure that any Personal Data processing adheres to a valid legal basis under Article 6 of the Regulation.

1. Cookies:

Cookies are small text files sent by visited sites to a user’s device for storage and future re-transmission. Cookies help sites remember user actions and preferences for enhanced user experience. Certain operations may be impossible without cookies. Technical cookies, necessary for site functionality, do not require explicit consent. Profiling cookies, used for creating user profiles and sending targeted ads, need prior user consent.

3. Purpose of Data Processing

The processing we intend to carry out, subject to your consent where required, serves the following purposes:

1. To facilitate requested Services, such as: i) accessing the restricted site area; ii) sending newsletters; iii) downloading documents or programs; iv) participating in promotions or contests; v) placing or processing online orders.
2. To respond to assistance or information requests.
3. To analyze CVs submitted via the “Work with Us” section and recontact applicants.
4. To fulfill legal, accounting, and tax obligations.
5. Legal Basis and Mandatory/Optional Nature of Processing

For purposes outlined in Section 3 (a-b-c), the legal basis for Personal Data processing is Article 6(1)(b) of the Regulation. Providing data for these purposes is optional, but non-provision will hinder activating Site Services, responding to queries, or evaluating CVs. For Section 3.c and the related analysis of freely available professional social profiles online, the legal basis is Article 6(1)(f), based on ADA Pathfinder Technologies, Inc.’s legitimate interest in assessing candidate suitability.

The purpose specified in Section 3.d represents legitimate processing per Article 6(1)(c) of the Regulation, necessary for fulfilling specific obligations under applicable law.

5. Recipient of Personal Data

Personal Data, for purposes in Section 3, may be shared with:

1. Data controllers, such as: i) parties offering professional advice to ADA Pathfinder Technologies, Inc.; ii) service providers for Services (e.g., hosting); iii) technicians for technical maintenance; collectively “Recipients.”
2. Entities required by law or authorities for data communication.
3. Persons authorized by ADA Pathfinder Technologies, Inc. for necessary activities related to Services.

Dissemination of data, as specified in Section 3.a.iv, might occur for the mentioned purposes.

6. Transfer of Personal Data

Some Personal Data may be shared with Recipients outside the European Economic Area. ADA Pathfinder Technologies, Inc. ensures compliance with Regulation when processing Personal Data by such Recipients. Transfers might occur via adequacy decisions, Standard Contractual Clauses, or other valid legal bases.

7. Data Retention

Personal Data, as per Section 3(a-b), are stored for the necessary time to fulfill the respective purposes. ADA Pathfinder Technologies, Inc. processes Personal Data up to the maximum duration allowed by English law to protect its interests. CVs shared via the “Work with Us” form (Section 3.c) are kept as long as the relevant position is available, or up to one year for spontaneous applications. Data for purpose in Section 3.d are retained for required timeframes according to legal obligations.

8. Rights of Data Subjects

Under Articles 15 and onwards of the Regulation, you can request access, correction, deletion, or objection to Personal Data processing. You can also ask for limited processing as per Article 18, or obtain your data in a structured, machine-readable format as per Article 20. If you believe Personal Data processing breaches the law, you can file a complaint with the competent Supervisory Authority (Data Protection Authority).

9. Changes

This privacy policy is effective from 05/25/2018. ADA Pathfinder Technologies, Inc. reserves the right to modify or update its content due to changes in applicable legislation. Any modifications will be communicated and will become binding upon publication on the Site. Regularly visit this section to stay informed about the most recent privacy policy version, data collection, and usage updates by ADA Pathfinder Technologies, Inc.