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AldexChem Kft. and its affiliated companies (collectively, the “Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our

website located athttps://www.aldexchem.com/, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively,

the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that

Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses

and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time

you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this

Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.  

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally

“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-

Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most

website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings,

may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the

user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not personally identifiable, it may be

possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as

other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how

the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of

content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate,

such as by publishing a report on trends in the usage of the Website.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides

to the website each time the user submits a query to the site. We use cookies on the Website to keep track of services you have used, to record your user

preferences, to keep you logged into the Website, and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during

each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-

Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web

Cookies, so as to help Company, its partners and others better understand how the Website is being used. WEBSITE USERS WHO DO NOT WISH TO HAVE WEB

COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING

THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES

ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has

viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed

emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use

to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a

page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered

ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline

Web Cookies on an individual basis.  

Analytics

We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the

DoubleClick cookie) together to provide analytics services, inform, optimize, and serve ads based on your past activity on our websites and applications, including

Google Analytics for Display Advertising. These vendors may use Web Cookies, Web Beacons and other technologies to collect information about your use of the

Website, our service and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This

information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to

your interests on our service and other websites and better understand your online activity. If you do not want any information to be collected and used by Google

Analytics, you can install an opt-out in your web browser () and/or opt out from Google Analytics for Display Advertising or the Google Display Network. You can do

so by using Google’s Ads Settings (www.google.com/settings/ads). For more information about interest-based ads, or to opt out in general of having your web

browsing information used for behavioral advertising purposes, please visit .

Legal basis (GDPR only) – Consent and Legitimate interest (e.g. essential cookies).

Aggregated and Non-Personally-Identifying Information

We share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We combine Non-Personally Identifying

Information we collect with additional Non-Personally Identifying Information collected from other sources. We also share aggregated information with third parties,

including advisors and investors, for the purpose of conducting general business analysis. This information does not contain any Personally-Identifying Information

and may be used to develop website content and services that we hope you and other users will find of interest.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect a range of

Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Company about users is information

provided by users themselves when:

(1) Participating in polls, surveys or other features of our service, or responding to offers or advertisements, for the purpose of process your answers and contact

you in case that you win the survey. The information collected includes  user’s name, address, email address, and telephone number, information about your

interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information provided/supplied

by you. Legal basis (GDPR only) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the

request of the data subject prior to entering into a contract and legitimate interest (e.g. process your answers in polls and surveys)

(2) Communicating with us, for the purpose of process and answer your questions, provide support (e.g., to solve problems or issues), and customize your

experience and provide a demo.  The information collected includes user’s name, address, email address, and telephone number, information about your interests

and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information provided/supplied by you.

Legal basis (GDPR only) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the

data subject prior to entering into a contract and legitimate interest (e.g. respond to an inquiry sent by you)

(3) Signing up to receive newsletters or other information, for the purpose of send you marketing communications. The information collected includes name and

email address. Legal basis (GDPR only) consent and legitimate interest (e.g. send marketing communications).

(4) Applying for job positions, for the purpose of process your job application and assess you as a candidate. The information collected includes full name, address,

email address, and telephone number, CV and other relevant information provided/supplied by you. Legal basis (GDPR only) Processing is necessary for the

performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and

legitimate interest (e.g. assess you as a candidate)

Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so

may prevent the user from using certain Website features.

BY USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE

AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Company Communications

We occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We

also send you service-related announcements from time to time through the general operation of the service.

Company Disclosures

Company will disclose Personally-Identifying Information under the following circumstances:

By Law or to Protect Rights. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity,

suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our Company, our users, our employees, or others; to comply with

applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar

investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to

defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

Marketing Communications. Company will email users about products and services that Company believes may be of interest to them, consistent with your consent.

If a user wishes to withdraw consent and stop receiving marketing materials from Company, user may do so by following the unsubscribe link in email

communications or contacting us using the contact information on the Website.

Third Party Service Providers. We share your Personally-Identifying Information, which includes your name and contact information (including email address) with our

authorized service providers that perform certain services on our behalf. These services includes fulfilling orders, providing customer service and marketing

assistance, performing business and sales analysis, supporting our website functionality, and supporting surveys and other features offered through our Website.

These service providers have access to personal information needed to perform their functions but are not permitted to share or use such information for any

other purpose e.g. AWS provide our Cloud services.

Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the

event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court,

the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of

that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however,

may be subject to a new privacy policy adopted by the successor organization.  

To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other

governmental agencies or if required to do so by court order;

Where you have provided your consent to us sharing the Personally- Identifying Information (e.g., where you provide us with marketing consents or opt-in to optional

additional services or functionality); and

If you want to receive the list of recipients of your Personally-Identifying Information, please make your request by contacting us on the contact information given on the website.

Finally, please note that some of the abovementioned Personally- Identifying Information will be used for fraud detection and prevention, and for security purposes.

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONALLY- IDENTIFYING INFORMATION

Storage: AWS – Ireland / Ohio

Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://

ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Companies of the group are

located in Israel and the UK.

External transfers:

Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual

commitments from them to protect your Personal Data.

Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of Personal Data transferred from within the

EU to the United States.

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

Changing Personally-Identifying Information

You may at any time review or change your Personally-Identifying Information by contacting us using the contact information on the Website.  Upon your request, we

will deactivate or delete your contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your

activity and accordance with our deactivation policy and applicable law. We will retain in our files some personal information to prevent fraud, to troubleshoot

problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not

expect that all your personal information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed

information to investigate suspected fraud.

General Use

We use the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website

to: deliver the products and services that you have requested, communicate with you by email, postal mail, telephone and/or mobile devices about products or

services that may be of interest to you either from us, our affiliate companies or other third parties, resolve disputes, troubleshoot problems, measure interest in

our services, inform you of updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our Terms of Use, and

as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. We may compare and review your

Personally-Identifying Information for accuracy and to detect errors and omissions. We use AWS as our Cloud provider.

PERIOD OF STORAGE OF COLLECTED INFORMATION

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Personally-Identifying Information. Your Personally-Identifying Information will be stored until we no longer need the information and proactively delete it or you send a

valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention

policy to ensure that we do not retain your Personally-Identifying Information perpetually.

Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through

your browser settings.  

SECURITY

We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft,

alteration, or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized

persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.

In addition, in some circumstances we may store your Personally-Identifying Information for longer periods of time, for example (i) where we are required to do so in

accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or

challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personally-Identifying Information or dealings.

YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected

by the GDPR):

You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an

appropriate administrative fee where permitted by applicable law;

You have the right to request that we rectify any Personally-Identifying Information we hold that it is inaccurate or misleading;

You have the right to request the erasure of the Personally-Identifying Information that relates to you. Please note that there may be circumstances in which we are

required to retain your data, for example for the establishment, exercise or defense of legal claims;

The right to object, to or to request restriction, of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;

The right to data portability. This means that you may have the right to receive your Personally-Identifying Information in a structured, commonly used and machine-

readable format, and that you have the right to transmit that data to another controller;

You have the right to object to profiling;

You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged

infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;

The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the

processing is required to meet our legal and regulatory obligations.

You also have a right to request details of the basis on which your Personally-Identifying Information is transferred outside the European Economic Area, but you

acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us on the contacts listed on the website. Subject to legal and other permissible considerations, we will make every reasonable effort to honor

your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional

information to confirm your identity and for security purposes, before disclosing the Personally-Identifying Information requested to you. We reserve the right to

charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if

we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in

accordance with applicable law.

LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Website enables you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that

are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please

be aware that Third Party Services can collect Personally-Identifying Information from you. Accordingly, we encourage you to read the terms and conditions and

privacy policy of each Third Party Service that you choose to use or interact with.

PRIVACY POLICY CHANGES

Company can, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and

the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we

have about you. Users should regularly check this page for any changes to its Privacy Policy. Company will always post new versions of the Privacy Policy on the

Website. However, if there will be any significant changes made to the use of your Personally-Identifying Information in a manner different from that stated at the

time of collection, we Company will, as determined in its discretion, notify users of changes made to this Privacy Policy via website, via email or otherwise.

Accordingly, it is important that users always maintain and update their contact information.

DO NOT TRACK POLICY

Our Website does not respond to “Do Not Track” signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our privacy officer using the contact information on the Website.

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