This Privacy Policy sets out how Adey Innovation, LLC (“Adey” or “we”) uses and protects any personal information (“Personal Information”) that you provide to Adey. Such Personal Information may be collected via our website located at adeyusa.com (“Website”), or by phone or paper based means. Adey is committed to ensuring that your privacy is protected. Should we ask you to provide certain Personal Information by which you may be identified, you may be assured that it will only be used in accordance with the statements set forth in this Privacy Policy. Adey may revise this Privacy Policy from time to time at its sole option and discretion, in which case a revised version will be placed on our Website with an updated effective date at the bottom of the revised version.

Information About Children Under 13

The Children's Online Privacy Protection Act imposes requirements on websites that collect personal information about children under 13. Our Website is not intended for or directed to children under the age of 13. Our policy is not to collect Personal Information on any person under 13. If you are under the age of 13 you should not provide us with any such information or use our products.

What Personal Information Do We Collect

We may collect the following Personal Information and other information from our customers and users of our Website:

• Name, address and job title

• Contact information including email address

• Company information - business users only

• Demographic information such as postcode, preferences and interests

• Product purchase and warranty information

• Other information relevant to customer surveys and/or offers or loyalty schemes

How We Use The Personal Information We Collect

We require and use the Personal Information and other information we collect in order to better understand your needs, fulfil our obligations and provide you with a better service, as well as for the following purposes:

• To fulfil any request made by you, as we consider appropriate

• Internal record keeping

• To improve our products and services

• To contact you by email, mail or phone/SMS/fax about new products or services, special offers or other information that we think you may find interesting based on the information you may have provided

• To contact you by email, mail or phone/SMS/fax with information regarding the servicing or maintenance of products

• To contact you for market research purposes. We may contact you by email, phone/SMS/fax or mail

In the event that you do not wish us to use the information you provided for marketing purposes, you may choose to opt-out of such use by contacting us at info@adeyusa.com

With Who Do We Share The Personal Information We Collect

We generally do not share your Personal Information with anyone outside of our organization. However:

• If your Personal Information is provided to us as part of an event that we host in partnership with a third party, we may then share your Personal Information with that third party and it will then be subject to the terms and conditions of their privacy policies.

• We may also share your Personal Information with our affiliates, including affiliates located outside of the U.S., as well as with agents of Adey who provide services for Adey solely in connection with the provision of such services, including but not limited to Manufacturers’ Representatives. In such cases, Adey will obtain assurances from its agents that they will safeguard personal information in a manner consistent with this Privacy Policy.

We will not sell, distribute or lease your Personal Information to third parties unless we have your permission or are required by law to do so. We will not use your Personal Information to send you promotional information about third parties unless you tell us that you wish this to happen.

Security

We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure, we have put in place commercially reasonable physical, technical and administrative procedures to safeguard and secure the Personal Information we collect. However, no security measures are full-proof and we cannot guarantee that your Personal Information will not be hacked or otherwise compromised by third parties.

Cookies Policy

At Adey we want to make sure that the Website we operate looks as good as possible but also is easy for you to use. To help us to do this, our Website uses cookies. A cookie is a small file of letters and numbers that we put on your computer.

Cookies allow us to recognize that you have visited our Website before and remember your preferences. Cookies help us to assess how you use our Website and also how we can improve our website. This means we have the information we need to regularly evaluate whether our Website really meets your needs. Some of the cookies we use improve the functionality of our Website, so if you choose to disable cookies on your browser, you might find that you can't access some aspects of our Website, or that parts of the Website don't function in the way that you might expect them to. Cookies can help us to remember your Website login so that you don't need to type it into the Website every time you return. Cookies also help us to collect information about the way you use our Website which helps us to ensure any advertising that you see is relevant and useful to you. Our Website uses: (i) analytical/performance cookies that allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it, which helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily; and (ii) strictly necessary cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website. Our Website also uses:

• Google Analytics: Collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Google's privacy policy is available here.

• ci_session: Also called a transient cookie, a cookie that is erased when the user closes the Web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed. Session cookies do not collect information from the user's computer. They typically will store information in the form of a session identification that does not personally identify the user.

• YouTube: Features for sharing videos via YouTube, and remembering what videos you've seen.

You may choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

Do Not Track

Currently, (i) other parties (e.g. third-party advertising networks and analytics providers) may not collect Personal Information about your online activities over time and across different websites when you use our Website, and (ii) we do not respond to, or take any specific action in connection with the receipt of, Do-Not-Track signals or other similar mechanisms regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services.

Links To Other Websites

Our Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Your California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information. If you are a California resident and want a copy of this notice, please submit a written request to the following address: Adey Innovation LLC, PO Box 38664, Pittsburgh, PA 15238, USA. In your request, please specify that you want a California Privacy Rights Notice. Please allow 30 days for a response.

Controlling Your Personal Information And Contact Details

If you have previously agreed to us using your Personal Information for marketing purposes, but now wish to change your mind, if you believe that any information we are holding on you is incorrect or incomplete, or if you have any additional questions regarding this Privacy Policy or any related issues, please contact us at info@adeyusa.com

EFFECTIVE DATE: This Privacy Policy is effective as of 18th October, 2016.