Privacy Policy

1. Data Controller

A.d.E - Around. Discover. Engage

Registered Office: Via Marie Curie 17, 39100 Bolzano (BZ) — Italy

VAT/Tax code: 03062850999

REA: GE — 531489

Certified email (PEC): arabellgroupsrls@legalmail.it

Privacy Email: privacy@ade-app.com

2. Data Collected

We collect the following data:

• Registration data: name, email, password (encrypted), country, username
• Profile data: profile picture, cover, bio, age, city
• Geolocation data: GPS coordinates (only with explicit consent)
• Generated content: photos, comments, messages, stories
• Usage data: connections, likes, gifts, ADE Coins transactions

3. Legal Basis (Art. 6 GDPR)

• Explicit consent (Art. 6.1.a): geolocation, marketing communications
• Performance of the contract (Art. 6.1.b): app operation, account management
• Legitimate interest (Art. 6.1.f): security, abuse prevention

4. Purposes of Processing

• Provide the proximity-based social networking service
• Display nearby users via GPS
• Manage connections, messages and content
• Process ADE Coins transactions and gifts
• Send push notifications (with consent)
• Marketing communications (with consent only)

5. Data Retention

• Account data: until the account is deleted
• GPS location: last 24 hours of history, then automatically deleted
• Stories: 24 hours, then automatically deleted
• Messages: until the account is deleted
• Payment data: handled by Stripe (PCI-DSS compliant)

6. Your Rights (Art. 15-22 GDPR)

You have the right to:

• Access (Art. 15): view all your data
• Rectification (Art. 16): correct your data
• Erasure (Art. 17): delete your account and all data
• Portability (Art. 20): export your data in a readable format
• Withdraw consent (Art. 7.3): withdraw any consent at any time
• Object (Art. 21): object to processing for marketing

To exercise your rights: privacy@ade-app.com

Or directly in the app: Settings → Security → Export/Delete Data

7. Sharing with Third Parties

• Stripe: payment processing (transaction data only)
• Google: OAuth authentication (email and name only)
• We do not sell your data to third parties
• We do not share geolocation data with third parties

8. Security

We protect your data with:

• Password encryption (bcrypt)
• HTTPS/TLS communications
• JWT tokens with expiration
• API rate limiting

9. Minimum Age

The app is intended for users at least 16 years old (Art. 8 GDPR). By registering, you declare that you are at least 16 years old.

10. Complaints

If you believe that the processing of your data infringes the GDPR, you may lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

11. Cookies

ADE uses only technical cookies necessary for the app to operate (authentication session). We do not use profiling or third-party cookies for marketing purposes.

12. ADE Coins

ADE Coins are internal platform credits usable exclusively within the ADE ecosystem. They do not constitute:

• Electronic money, cryptocurrency, bank currency or a financial instrument
• An investment with an expectation of return
• A bank deposit, current account or financial product

ADE Coins are not convertible into money, bear no interest, are not withdrawable and are not tradable on external markets. Their use is limited to purchasing Gifts and digital content within the ADE platform.