Updated as of 24 October 2022
For any queries regarding your personal data, please contact us at the following address: firstname.lastname@example.org.
User (“you”, “your”) – an individual over 18 years old who can be identified, directly or indirectly, in particular by reference to – an identifier such as a name, an identification number, location information, or an online identifier, or any relevant factors of the individual;
Privacy Notice – means the terms which set out how we will deal with confidential and personal information received from you via the Platform;
Personal Data – any content that can be linked or identified, directly or indirectly, with the User;
Services – means any kind of applications, products, and services that can be provided to the User on the Platform;
How We Process and Secure Your Personal Data
We only process your Personal Data if this is necessary to provide a functional Platform or to provide you with our content and services. The processing of personal data only takes place based on the appropriate legal basis and as permitted by law.
3. Legal Basis for Processing data
We are required to warn you about the legal basis on which we treat your Personal Data. We shall treat your personal data legitimately, fairly, and transparently. We only gather and process information about you when we have a legal basis to do so. These legal grounds depend on your use of the Platform, meaning we collect and use your information only when:
Performance of an agreement. It is required for the performance of an agreement to which you are a party or to take steps at your request prior to entering into such an agreement.
Legitimate interest. It serves a legitimate interest (that is not outweighed by your data protection interests), such as research and development, marketing and promotion of our activities, and protection of our legal rights and interests.
Consent. You give us permission to collect and use your personal data for a specific reason.
Legal obligation. The Company needs to process your personal data to comply with a legal obligation.
4. Duration of Processing
We only store your data for as long as necessary to serve the purpose of the processing and we delete Personal Data or block access to it as soon as such purpose ceases to apply.
Furthermore, Personal Data may be stored if this has been provided for by the applicable law (for example for bookkeeping or mandatory archiving purposes). The data will also be blocked or deleted if a storage period prescribed by the applicable law expires unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.
5. Disclosure of Personal Information to Third Parties
We use third-party services to provide our services and meet legal and regulatory requirements relevant to the Company, and such third-party services use your Personal Data in delivering their services to the Company or in complying with regulatory requirements.
The Company may share the information collected with service providers (e.g. the Partners) to retain personal information and help us analyze how people use our services to improve the Platform’s functions properly and securely. Our Partners are the following companies:
Aurora Labs Limited, that provides technical support for the Platform in general, with its registered headquarters at Gibraltar, Madison Building, GX11 1AA, Midtown, Queensway;
Onfido LLC, that provides the know-your-customer (”KYC”) process, with its registered headquarters at 3 Finsbury Avenue London EC2M 2PA United Kingdom.
The Company may be required to share collected Personal Data with supervisory authorities, law enforcement agencies, or government officials. We will only do this if we are required to do so by law or a formal request, if it is necessary to prevent physical injury or financial loss, or if we are required to report illegal activity.
6. Securing Your Personal Information
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. The Company uses physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and modification of personal information. The Company provides security such as data encryption and physical access controls to its servers. Certain personal data may be kept with service providers to be better secured and guarantee that it is used for the reasons specified by this Privacy Notice. All of our safeguards are designed to be by existing laws and regulations.
We maintain personal information to comply with relevant legislation, prevent fraud, resolve disputes, troubleshoot problems, and cooperate with any investigation and other legal actions. We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of this information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements when determining the appropriate retention period for personal information.
The Company is committed to doing its best effort in protecting the information we receive from you. However, the Company will not be liable for disclosures of your Personal Data due to errors in transmission or unauthorized acts of third parties. We have undertaken commercially reasonable efforts to prevent unauthorized Internet access to visitor data retained in our servers, however, due to the inherently open nature of the Internet, the Company cannot ensure or warrant the security of any information you provide us, and you do so at your own risk. Users must accept all risks associated with any data transmission, including the risk that their Personal Data may be intercepted in transit.
7. Personal Data We Collect
Automated Data Processing
Every time you visit our Platform, our system automatically collects data and information about the computer system you used to access our Platform.
The following data is collected:
how you use the Platform, such as the pages you visit;
your IP address;
the date, times, and frequency with which you access the Platform;
your operating system;
information about your browser;
The data is also stored in the log files of our system. The data is stored to ensure the Platform’s proper operation and for analytical purposes. In addition, the data serves us to optimize the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
For you, these purposes are our legitimate interest. The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected.
Cookies, tracking, and technologies relating to the use of our Platform
In addition, we also use temporary cookies that are stored on your end device to optimize user-friendliness. If you visit our platform again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.
The data processed by cookies for the aforementioned purposes is justified to protect our legitimate interests and those of third parties.
Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all functions of our Platform.
We use Google Analytics on our Platform. These are services provided by third parties, which may be located in any country (Google LLC is based in the US but Google Ireland Ltd. is the data controller for customers based in the EU, for more information visit https://policies.google.com/?hl=en) and allow us to measure and evaluate the use of our Platform (without identifying individuals). Permanent cookies, which are placed by the service provider, are also used for this purpose. Although such service providers do not receive personal data from us (and do not retain any IP addresses), they may track your use of the Platform, combine this information with data from other websites you have visited, which are also tracked by service providers, and use this information for their own purposes (e.g. to manage to advertise). If you have registered with the service provider concerned, the service provider will also know your identity. The service provider concerned will then be responsible for processing your personal data by the applicable data protection provisions. Service providers only provide information on how a particular website is used (but not any personal details).
We also use plugins from social networks such as Facebook, Twitter, YouTube, Google+, and LinkedIn on our Platform. This will be evident to you, as the relevant symbol will typically be displayed. We have configured these elements to be disabled by default. If you enable these (by clicking on them), the social network operators may register that you are on our website and where you are on our website and may use this information for their purposes. The operator concerned will then be responsible for processing your personal data by the applicable data protection provisions. We will not receive any information regarding you from the operator concerned.
8. Your Rights
You have the following rights under the applicable data protection laws:
Right of Information
You can request us to confirm whether Personal Data concerning you is being processed by us.
If such processing has taken place, you can request the following information from us:
the purposes for which the Personal Data are processed;
the categories of Personal Data being processed;
the recipients or categories of recipients to whom the Personal Data concerning you have been or is still being disclosed;
the planned duration of the storage of the Personal Data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
the existence of a right to rectification or deletion of Personal Data concerning you, a right to limitation of processing by the controller, or a right to object to such processing;
the existence of a right of appeal to a supervisory authority;
any available information on the origin of the data if the Personal Data is not collected from you.
As a data subject, you have the right to obtain from us free information about your Personal Data being processed at any time and request a copy of this information. You have the right to request information as to whether your Personal Data is transferred to a third country or an international organization. In this context, you may request to be informed of the appropriate guarantees in connection with the transmission.
Right to Rectification
You have a right to request the rectification and/or completion if the Personal Data processed concerning you is incorrect or incomplete. We shall correct it without delay.
Right of Restriction
Under the following conditions, you may request that the processing of your Personal Data be restricted:
if you dispute the accuracy of the Personal Data concerning you for a period that enables us to verify the accuracy of the Personal Data;
the processing is unlawful and you refuse to delete the Personal Data and instead request that the use of the Personal Data be restricted;
we no longer need the Personal Data for the purposes of the processing, but you do need them to assert, exercise, or defend legal claims; or
if you have filed an objection to the processing and it has not yet been determined whether the legitimate reasons of the person responsible outweigh your reasons.
if the processing of your Personal Data has been restricted, such data may only be processed – apart from being stored – with your consent or to assert, exercise, or defend rights or protect the rights of another natural or legal person or on grounds of important public interest.
Right to Deletion
a) Obligation to Delete Personal Data
You may request us to delete your Personal Data without delay and we are obliged to delete this data without delay if one of the following reasons applies:
Your Personal Data is no longer necessary for the purposes for which they were collected or otherwise processed.
You revoke your consent, on which the processing was based, and there is no other legal basis for the processing.
You file an objection against the processing and there are no overriding legitimate reasons for the processing, or you file an objection against the processing.
Your Personal Data has been processed unlawfully.
The deletion of your Personal Data is necessary to fulfill a legal obligation to which we are subject.
Your Personal Data was collected by information society services.
If we have made your Personal Data public and are obliged to delete it, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform those responsible for data processing that you as the data subject have requested the deletion of all links to this Personal Data or of copies or replications of this Personal Data.
The right to deletion does not exist insofar: (i) as the processing is necessary to exercise freedom of expression and information; (ii) for the performance of a legal obligation required for processing under the applicable law or the performance of a task in the public interest or the exercise of official authority conferred on the controller; (iii) for reasons of public interest in the field of public health; (iv) for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes, insofar as the right mentioned under i) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or (v) to assert, exercise, or defend legal claims.
Right to Notification
If you have exercised your right to have us correct, delete or limit the processing, we are obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.
You have the right to receive your Personal Data that you have provided to us in a structured, common, and machine-readable format. In addition, you have the right to pass this data on to another person in charge without obstruction by us, provided that processing is based on consent or on a contract and processing is carried out using automated methods.
In exercising this right, you also have the right to request that the Personal Data concerning you be transferred directly from us to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
Right to Objection
You have the right to object at any time, for reasons arising from your particular situation, to the processing of your Personal Data. This also applies to profiling based on these provisions.
In such a case, we shall no longer process your Personal Data, unless we can prove compelling reasons worthy of protection for the processing, which outweighs your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.
If your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of your Personal Data for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, your Personal Data will no longer be processed for these purposes.
Right to Withdraw Consent
You have the right to revoke your declaration of consent at any time. The revocation of consent shall not affect the legality of the processing carried out based on the consent until revocation.
Right of Appeal to Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to appeal to a supervisory authority, if you believe that the processing of your Personal Data is contrary to the applicable law.
9. Third-party intervention
You are aware of links contained on the Platform which belong to third parties and not to the Company. We are not responsible or liable for third-party policies and terms of processing your Personal Data.
10. Amendments to this Privacy Notice
We may amend this Privacy Notice at any time by posting the amended version on the Platform including the effective date of the amended version. The current version of the Privacy Notice, as published on the Platform, is applicable.