Kyon Limited
Privacy Policy
This notice informs you about the processing of your Personal Data by Adara according to EU-General Data Protection Regulation (GDPR). Which of your Personal Data we process in detail depends on the services you request.
General Regulations
  1. This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of purchaser’s Personal Data collection, processing, distribution, use and keeping by Kyon Limited, 136, St. Christopher Street, Valletta VLT 1436, Malta, with registration number C 89188, ("Adara“) (hereinafter: “Adara”).
  2. Throughout this Policy, Adara use the term “Personal Data” to describe information that can be associated with a specific person and can be used to identify that person.
  3. Adara does not consider Personal Data to include information that has been anonymized so that it does not identify a specific purchaser.
  4. This Policy is inalienable part of AAA Tokens Sale Agreement. In terms not regulated by this Policy, the AAA Tokens Sale Agreement shall apply to the relationships that arise hereunder.
  5. It is understood and presumed that by the fact of the website use and purchase of AAA Tokens or by providing Adara the Personal Data directly on its request, the purchaser has fully read, understood and accepted this Policy. If any purchaser does not agree with this Policy in general or any part of it, such purchaser should withhold from using our website and/or purchase of AAA Tokens.
  6. Your rights as a user and/or customer in relation to the protection of Personal Data according to GDPR remain unaffected.
Responsibility for Data Processing
Responsibility lies with:
Kyon Limited
136, St. Christopher Street, Valletta VLT 1436, Malta,
At this address, you can also contact the person responsible for data protection at Adara.
Processing of Personal Data
  1. We process Personal Data that we receive from you and/or other concerned parties in connection with our business relationship. Moreover, we process Personal Data legitimately obtained from publicly accessible sources or which have been legitimately transmitted to us from third parties, especially governmental institutions, to the extent necessary for rendering our services.
  2. Relevant Personal Data are personal details (name, address and other contact data, date and place of birth and nationality), legitimisation data (such as data from ID cards) and authentication data (such as a specimen signature). In addition, these may also be contract data (such as a payment order), data resulting from the performance of our contractual obligations, information about your financial status (such as data on credit standing, origin of assets), documentation data (such as a protocol on consultations) and other data comparable with the above-mentioned categories.
  3. According to legal requirements (Art. 6(1c) GDPR Adara can collect additional information from you, i.e. when additional verification by bank or compliance authority is needed according to governmental rules, anti-money laundering (AML) or “Know-Your-Customer” (KYC) policies. Such information provided by you at Adaras request in accordance with Adara AML/KYC Policy, available at Adaras website.
  4. Adara also processes Personal Data within the scope of the balancing of interests in accordance with to (Art. 6(1f) GDPR) for the following purposes:
    1. administer Adaras website and provide services
    2. develop new products and services
    3. personalize Adara Website for you
    4. send you technical notices and support and administrative messages
    5. communicate with you about products, services, promotions, events and other news and information Adara think will be of interest to you
    6. monitor and analyse trends, usage and activities in connection with Adaras website
    7. provide third parties with statistical information about Adaras purchasers (but those third parties will not be able to identify any individual purchaser from that information)
    8. detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Adara and others
    9. link or combine Personal Data Adara collect from or about you
    10. verify compliance with the terms and conditions governing the use of Adaras website (including monitoring private messages on legal safety sent through the website private messaging service)
  5. Adara reserves the right, to request Personal Date referred to in section D.2 and 3 of this Policy as well as in the Adara AML/KYC Policies prior to purchase of AAA Tokens and/or use of any services, available through the website.
  6. Adara may refuse the purchaser access to the website in case if Adara have grounded doubts as to validity, authenticity and genuineness of the Personal Data, provided by the purchaser. This refusal does not give rise to any claims for damages or other claims against Adara.
  7. Your Personal Data will only be processed if you have granted us your consent beforehand and we are entitled to process your Personal Data in accordance with Art. 6(1a) GDPR. You can give such express consent within our website and contracting formalities,. We will inform you of the purpose for which the personal data will be processed in the event of your consent, and how long we store this data.
  8. Consent once given may be revoked at any time. This also applies to the revocation of declarations of consent given to us before the effective date of the GDPR, i.e. before 25 May 2018. Revocation of consent has an effect only for the future and does not affect the legitimacy of the data processed until revocation.
Your Rights as Data Subject
  1. As data subject you have
    1. the right of Access pursuant to Art. 15 GDPR, in particular you may request information about the purposes of processing, the categories of Personal Data concerned, the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, the envisaged period as well as the source of your Personal Data, provided the data were not collected by you
    2. the right of rectification of inaccurate personal data or of having incompleted Personal Data completed pursuant to Art. 16 GDPR
    3. the right of erasure of your Personal Data stored at our company pursuant to Art. 17 GDPR unless other longer periods are required by law or contracts
    4. the right to restriction of processing pursuant to Art. 18 GDPR insofar as the accuracy of Personal Data is contested by you or the processing is unlawful, and you oppose the erasure of the Personal Data; the controller no longer needs your Personal Data, but you require them for the establishment, exercise or defence of legal claims or you have objected pursuant to Art. 21 GDPR to processing
    5. the right to data portability pursuant to Art. 20 GDPR, which means the right, to have selected, at Adara stored Personal Data in a commonly used and machine-readable format transferred, and the right to transmit those data to another controller
    6. the right to appeal to a competent data protection supervisory authority pursuant to Art. 77 GDPR
    7. You can assert the aforementioned rights to us under
    8. If Personal Data will be erased or the processing of Personal Data will be restricted, Adara reserves its rights, to suspend provision of any services to you referring to Adara projects and/or delete your account on the website without prior notice, not providing any compensations to you. This will not affect your rights pursuant to GDPR.
Right of Objection
  1. Subject to Art. 21(1 and 2) GDPR you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1e) GDPR (data processing in the public interest) and Art. 6(1f) GDPR (data-processing on the basis of the balancing of interest); this also applies for profiling as defined in Art. 4(4) GDPR.
  2. If you do object, we will no longer process your personal data unless we have compelling justified reasons for such processing that take precedence over your interests, rights and freedom or, alternatively, such processing serves to assert, exercise or defend legal claims.
Personal data protection and sharing
  1. Adara will not publish any Personal Data related to your purchase of AAA Tokens without your prior written consent.
  2. Adara stores and processes your Personal Data on Adara servers in various jurisdictions, where our facilities and/or Adara service providers are located. By submitting your Personal Data, you agree to this transfer, storing, or processing. Whenever we use external service providers for data processing purposes, we ensure compliance with Art. 26 GDPR.
  3. Adara will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. Adara protect your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.
  4. Some of the safeguards Adara use are firewalls and data encryption, physical access controls to our data centers and information access authorization controls. Adara also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations. Our service providers are also committed to these standards. Art. 26 GDPR shall apply.
  5. Adara is sometimes required to compare the Personal Data you provide to third party databases in order to verify its accuracy and confirm your identity. This allows Adara to comply with relevant anti-money laundering (AML) regulations and “Know Your Customer” (KYC) regulations.
  6. Adara reserve its rights, for the purpose of the legitimate interests pursuing to Art. 6 (1 f) to share your personal data with partners such as:
    1. Adara banking and brokerage partners
    2. Third party identification service providers for fraud prevention purposes
    3. Law enforcement, government officials, or other third parties when Adara is compelled to do so by a subpoena, court order, or similar legal procedure; or Adara believes in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Adaras policies
    4. Adaras Personal Data processing counterparties or agents, hired by or cooperating with us, who’s services are required by us from the practical point of view
    5. Companies that Adara plan to merge with or be acquired by (as this occurs, Adara will notify you immediately and will require that the newly combined entity follow these terms with respect to your Personal Data)
    6. Other third parties only with your prior consent or direction to do so
Data Storage
  1. We process and store your Personal Data as long as this is required to meet our contractual and statutory obligations as well as needed to provide services to purchasers of AAA Tokens.
  2. If the Personal Data are no longer required for the performance of contractual or statutory obligations, these will be erased on a regular basis unless –temporary– further processing is necessary for the following purposes:
    1. In compliance with legal obligations such as:
    2. Commercial Codes, Fiscal Codes, Banking Acts, Law on Money-Laundering and Law on Trading in Securities (Art. 17 (3 b) GDPR)
    3. Reservation of evidence under the statutory regulations regarding the statute of limitations
    4. Adara having a legitimate interest to retain data, for example for legal reasons
Log Files
  1. Adara makes use of log files. The information inside the log files includes Personal Data and time of access, name of file accessed, IP-addresse of the device, referrer-URL, the quantity of data transmitted, loading time, furthermore product and version information of the respectively used browser and the name of your access-provider.
  2. Specific legal basis for the processing of IP-addresses is Art. 6 (1 f) GDPR. Our legitimate interest derives from:
    1. to ensure a trouble-free connection,
    2. to ensure a comfortable usage of our website/application
    3. analysis to ensure system security and stability
  3. An analysis of the IP number do not allow any conclusion about your identity
  4. The Personal Data will be stored and automatically deleted after the above-mentioned purposes. The deletion period depends on the requirement of necessity.
  1. Cookies are used within the framework of our internet offer. Cookies are small data packages that the browser stores on the respective user's hard drive at the prompting of a web server. They support the control of the internet connection during your visit or a subsequent visit on our website and make the visit more convenient.
  2. Adara uses cookies in order to be able to recognize you as an already known user, to make the Adara website and advertisement more attractive, enable you to use certain functions and for statistical purposes; but also in order to minimise potential risks, to prevent fraud and promote trust and safety.
  3. Some browsers already permit cookies in their basic settings. If you do not wish to receive cookies, you can use the help menu of your browser to check current cookie settings and alter these as necessary. Please take corresponding information from the operating instructions of the browser manufacturer. If you decide against cookies, it may occur that you cannot use parts of our internet offer.
Adara use relevant electronic and procedural safeguards to protect the privacy of the information the purchaser provide to Adara from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that Adara is not liable for the security of any data purchasers are transmitting over the Internet, or third party content.
Third Party Liability
Adara services may from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which our website is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them, have their own privacy policies. Adara do not accept any responsibility or liability for their policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any Personal Data to these websites or before using these services.
Adara reserves the right to modify or amend this Policy at its own discretion. If we decide to modify or amend this Policy, we will post an information together with the alterations on our website. You maintain all legal rights, arising from this policy in the absence of any compelling legal requirements to the contrary.