PRIVATE POLICY

Last updated: March 3, 2023

Acadai Material appreciates your interest in this Web site and other related or linked Acadai Material sites (collectively, “Site”). Your privacy is important to us and we want you to understand our practices with respect to the gathering and handling of your personal data. This Privacy Policy describes those practices. Acadai Material provides additional privacy notices for specific uses of certain personal data. For example, we provide additional notices to visitors to our facilities, to our suppliers, to job applicants, to users of specific mobile Apps, and to participants of our loyalty programs. The relevant Acadai Material affiliates will process the personal data in accordance with the privacy notices they provide for such specific uses. When these notices apply to you, we recommend that you read them carefully. To the extent the personal data is collected from individuals in the European Economic Area (EEA), Switzerland or UK through the Site, we refer you to the Privacy Statement of the relevant Country on our anding page. This Privacy Policy sets forth general Personal Data privacy principles that Acadai Material follows with respect to Personal Data being processed in our business operations. Our data privacy policies may vary among the countries in which we operate to reflect local practices and legal requirements. Where national Personal Data protection and privacy laws require a higher standard of protection for Personal Data than presented in this Privacy Policy, the requirements of applicable Personal Data protection law reflected in the relevant country privacy policy notice shall prevail. Therefore, Acadai Material encourages you to read in addition to this Privacy Policy our country privacy policy notices for further information on our Personal Data protection practices and your rights. You can find links to relevant notices and more information about AcadaiMaterial’s privacy program here. 1. INDIVIDUALS TO WHOM THIS PRIVACY POLICY IS ADDRESSED This Privacy Policy is addressed to: visitors of the Site; recipients of electronic or other communications which contain or refer to this Privacy Policy; Individuals with whom Acadai Material has business relationship, such as customers, representatives of customers, and external stakeholders and their representatives. Information from Children Acadai Material does not seek through the Site to gather personal data from or about minors (as this term is defined by applicable law), nor does Acadai Material sell or share the personal information of minors without affirmative authorization. 2.AcadaiMaterial'S COMPLIANCE WITH DATA PROTECTION LAWS Acadai Material is committed to collecting and using personal data in a lawful manner. Acadai Material will ensure that, when it collects or uses personal data, such collection or use is allowed under applicable data protection law, including, for example, the EU General Data Protection Regulation (GDPR), the Virginia Consumer Data Protection Act, or California Consumer Protection Act, where such laws govern. For more information on particular data processing activities, the purposes of this processing, and a description of the specific personal data, please review the table in Section 3. Individuals may object to the processing of their personal data and we will consider such objections carefully where required by law. For more information about your rights with respect to how we process your personal data, please refer to Section 8 and/or contact the Acadai Material Data Privacy Office via data.privacy.info@acadaimaterial.com. 3.COLLECTION OF PERSONAL DATA In this table we describe the categories of information that we gather via the Site and in connection with our business relationship with you. We also describe the purpose and legal basis, where applicable, for using and processing the information. When Acadai Material relies on its legitimate interest as a legal basis to process personal data, Acadai Material will ensure that these interests do not disproportionately and adversely impact an individual’s rights and freedoms. When Acadai Material relies on an individual’s consent as a legal basis to process personal data, individuals can withdraw their consent at any time. Visitors wishing to withdraw their consent should notify us at data.privacy.info@acadaimaterial.com and we will stop the processing of your personal data as soon as reasonably possible. 4. COOKIES AND TARGETED ADVERTISING Information placed on your computer when visiting the Site We use cookies and other local storage technologies or files such as pixels, tags, web beacons and Local Shared Objects (sometimes called “flash cookies”) which we store on your computer or mobile device when you visit the Site. The cookies and files stored on your computer or mobile device facilitate customizing your use of the Site and help to avoid the need to re-enter your details every time you visit. You can erase or block this information from your computer. Flash cookies may use parts of your device other than your browser, which means that you may not be able to control their use using browser tools and settings. For more information about managing Flash cookies, please visit the Adobe Flash Player website(note: you will be taken to a third-party website). To learn more about how to opt-out from cookies please click here (note: you will be taken to a third-party website). We use vendors to monitor usage of our site and to provide site usage analytics. These vendors may use such information for business purposes in accordance with our contracts with them. For more information about the use of analytics, and about the cookies and files we place on your computer or mobile device, and how to erase or block them or opt-out from processing them, see the “Your Privacy” or the relevant cookies section in the Privacy Centerin the footer link on the relevant Site. Note that some goods or services may not be available if you choose not to provide the necessary personal data. Targeted advertising, and our use of social media sites We may use the information we collect through the Site to help manage our on-line advertising. Our Site also provides links to others’ websites. This may include social plug-ins to Facebook, Twitter, YouTube and other social media. In case we receive certain statistical information regarding the click-through via these links or social plug-in, we will treat such statistical information in accordance with applicable laws. By clicking on such links or social plug-ins, an online connection will be established between your browser and the servers of the relevant websites and as a result certain personal data may be collected by these websites. Acadai Material does not own, control or maintain these websites. We recommend that you review the privacy policy of these other sites carefully and contact the operator if you have concerns or questions. Acadai Material is not responsible for the way others handle personal data and makes no representations or warranties about the privacy practices and accuracy of the content of those sites. Similarly, Acadai Material is not responsible for the policies and practices of any website from which you linked to our Site. We may use information collected through the Site to analyze links between your usage of the Site and your usage of other applications (e.g., our mobile payment App) across the different types of devices you use to access the Site or applications, in order to improve your cross-application experiences. In doing so, we use cookie files and other storage technologies on our Site in accordance with this Privacy Policy and the “Your Privacy” or the relevant cookies section in the Privacy Center in the footer link on the relevant site. In case you visit one of our websites and you wish to opt-out from targeted advertising via cookies, you can do so by following the cookie-banner instructions or by accessing the “Privacy center”/ “Privacy Center (Do not sell or share my personal data)” link at the bottom of our websites. Do-Not-Track Signals and Similar Mechanisms, such as Global Privacy Control on Acadai Material US websites: Some web browsers transmit "do-not-track" signals. We take action in response to these signals: If the browser has Do Not Track enabled, cookies in this group will be disabled until explicit consent is received. We detect and honour your Global Privacy Control signal if the website browser add-in or extension is enabled at your end. Please see further information about the Global Privacy Control mechanism here. 5. DISCLOSURE OF PERSONAL DATA TO EXTERNAL PARTIES We contract with other companies and persons to perform functions on our behalf. They have access to personal data needed to perform these business purposes, but may not use it for other purposes. For example, Acadai Material may share the personal data it collects automatically, directly from you, or from vendors or via social media with (other) vendors in order to allow Acadai Material to fulfill orders and make deliveries, to send postal mail, and e-mail, to manage customer lists, analyze data, provide marketing assistance, host websites, process card payments, and provide and improve customer service. Furthermore, communicating via the Internet and sending information, products, and services to you by other means necessarily involves your personal data passing through or being handled by third-parties. Before any personal data is shared with service providers, we enter into a written agreement which requires them: (1) not to make any unauthorized disclosures of the personal data; (2) to use the personal data only for the specified purposes and only according to the instructions received from Acadai Material; (3) to retain the personal data only as long as necessary or to protect company interests; and (4) to have in place adequate and appropriate security measures. In some circumstances. 6.INTERNATIONAL TRANSFERS OF PERSONAL DATA 1212 6.1 Transfers between affiliates The relevant Acadai Material affiliate who is the Data Controller may make personal data available to other Acadai Material affiliates and may transfer some or all of the personal data to Acadai Material servers located worldwide in accordance with applicable law. The transfer of personal data from the EEA, UK and Switzerland to recipients located outside such territories is subject to restrictions. Acadai Material has taken steps to ensure that personal data receives an adequate level of data protection at all Acadai Material locations. These steps include Acadai Material affiliates entering into Binding Corporate Rules (“BCR”) which were approved in accordance with the EU General Data Protection Regulation (please visit the link here to read our BCR) 6.2 Transfers to third parties When transferring personal data, Acadai Material puts in place safeguards to ensure that the recipient adequately protects the personal data. With respect to the transfer of personal data from the EEA, UK and Switzerland to outside such territories, Acadai Material relies on (1.) EU “Standard Contractual Clauses”, (2.) contractual safeguards imposed on the recipient which is contracted by Acadai Material affiliates outside of EEA, UK or Switzerland (so-called onward transfers),and (3.) protections available under local law for the recipient established in a country deemed adequate by the EU Commission. Where permitted, and as applicable, we will rely on the individual’s consent. For more information about specific transfer mechanisms, including information on existing safeguards implemented by Acadai Material, please contact info@acadaimaterial.com. 7.ACCURACY OF PERSONAL DATA Acadai Material endeavors to keep personal data that it collects accurate and complete. Acadai Material relies on the individuals to maintain the accuracy and completeness of the personal data. Please inform Acadai Material if your personal details change, including the context in which the personal data was provided, e.g., in connection with a specific product or service. 8.INDIVIDUAL'S RIGHTS Where it is permitted by applicable law you may have the right to request: Deletion of your personal data when such data is no longer necessary for the purposes for which it has been collected. Access to specific pieces of information Acadai Material has about you or more information about our data processing practices. Correction of any inaccurate personal data we maintain about you. Restrict the processing of your personal data under certain circumstances. Object to the processing operations, having regard to the given circumstances and for reasons related to their particular situation. Opt-out from sale or sharing your data for cross-context behavioral advertising, targeted advertising (US data subjects) by providing your choices related to cookies through the “Privacy Center - Do not sell or share my personal data” link of the relevant site or via the Global Privacy Control, which is operated by a third party (browser add on) and is explained here. Please note that because the Global Privacy Control is a browser-based mechanism, your opt-out preference will apply only to the browser from which you exercised that choice. Right to Opt-Out for the Purposes of Profiling: you may have the right to opt-out of processing of personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. In some circumstances in EU/EEA/UK, you also have a right to request a portable extract of your personal data, which will allow you to reuse your personal data for your own purposes. 9.RECORDS RETENTION Acadai Material retains personal data as long as necessary to meet the purposes for which the data was collected, to exercise its legal rights and to ensure compliance with applicable law. 10.QUESTIONS AND COMPLAINTS Acadai Materia is committed to protecting your personal data as described in this Privacy Policy and as required by applicable laws. If you have any questions about this notice or our handling of your personal data, or if you would like additional information, please contact: info@acadaimaterial.com The Data Privacy Office will ensure all data protection complaints are resolved in a timely manner as set out in the applicable Data Privacy laws and the Data Subject is informed when appropriate. 11.CHANGES TO THIS PRIVACY POLICY We reserve the right to change this Privacy Policy at any time without notice. When we make material changes to this Privacy Policy, we will post the changes on this page and update the revision date at the top of the Privacy Policy. We encourage you to review our Privacy Policy regularly for updates.