Last updated: April 2, 2020
This website at https://velas.com/ (the “Website”) is operated by Velas Network AG, registered under the laws of Switzerland and having registered address at Dammstrasse 16, Zug 6300, Switzerland (“Velas”, “we”, “us”).
This Privacy Notice tells you how we use personal information collected from you when you access and use the Website. We will process your personal data in accordance with this Privacy Notice and in compliance with the applicable data protection legislation, including the Swiss Federal Act on Data Protection, the Swiss Ordinance to the Federal Act on Data Protection, and the General European Data Protection Regulation (the “Applicable Legislation”).
Regarding personal data we collected from you or you provided us with we are acting as a data controller.
1. CONTACT DETAILS
Company name: Velas Network AG
Address: Dammstrasse 16, Zug 6300, Switzerland
Contact email: email@example.com
2. HOW DO WE PROCESS YOUR PERSONAL DATA?
We collect your data when you:
- (1) visit the Website;
- (2) contact us via email or otherwise; or
- (3) subscribe to our newsletter.
There are analytical/performance cookies (that allow us to recognise and count the number of visitors, and to see how visitors move around our Website when they are using it), functionality cookies (that are used to recognise you when you return to the Website), and targeting cookies (that record your visit, the pages you have visited and the links you have followed).
The personal data collected by cookies may include your IP address, the time and date of your visit, browser type and version, the pages that you visit, and other statistical information.
We also use certain third-party cookies, such as DoubleClick, YouTube, and Vimeo; their privacy and/or cookie policies are available on their respective websites, as follows:
- 2.2. Contacting us via email or otherwise. You may contact Velas via email address indicated on the Website, and through other communication channels that may be indicated on the Website or otherwise made available by Velas. In such a case, we may process certain personal data such as your email address, name, subject, content of the message, and other data that you choose to provide us with.
We will process such information to reply to your messages and communicate with you. Legal basis for such processing is our legitimate interest to respond to your inquiries.
- 2.3. Subscribing to our newsletter. On the Website you may opt in to receive marketing emails regarding the Velas Project. In this case, we will be sending you our marketing materials on the basis of your consent.
You may withdraw your consent at any time and unsubscribe from receiving marketing emails by (i) following the “unsubscribe” link in the footer of any marketing email or (ii) contacting us at firstname.lastname@example.org with the description of the request.
3. HOW DO WE SHARE YOUR PERSONAL DATA?
We do not sell or rent out your personal data. However, we may share your personal data in accordance with this Privacy Notice, Applicable Legislation, or with your consent.
We may share your data with the following categories of recipients:
- (1) our affiliates, meaning the companies that we control, are controlled by, or under common control with Velas (based on our legitimate interest);
- (2) web services used to set up servers, such as Amazon Web Services (based on our legitimate interest);
- (3) business partners, suppliers, and contractors, including technical specialists, where this is necessary for performing any contract with you (based on performance of a contract with you), or maintaining security and stability of the Website (based on our legitimate interest);
- (4) third party service providers that store email addresses and automate mailing campaigns.
Your personal data may also be disclosed if:
- (1) we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- (2) all or substantially all of our assets are acquired by a third party, in which case our customers’ personal data may be one of the assets transferred;
- (3) we are under a duty to disclose or share your personal data in order to comply with any Applicable Legislation, to protect our rights or rights of third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and risk reduction.
Please note that if we share any portion of your personal data with third parties, we will do our best to secure such transfer using appropriate legal, organisational, and technical measures.
Sometimes we may transfer your personal data to countries that do not offer the same level of data protection as the laws of your country (such as, for example, the data protection legislation of Switzerland, the EU, EEA, or UK). In case we transfer your personal data to a country that does not maintain the “adequate” level of data protection, we will put in place suitable safeguards, which gives you more protection and control regarding your personal data. We may use the following safeguards:
- (1) Standard Contractual Clauses (special documents developed by the European Commission). Find out more about Standard Contractual Clauses at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en;
- (2) Transfer personal data to a company which is a member of the Swiss-U.S. Privacy Shield Frameworks and/or EU-U.S. Privacy Shield Framework. Find out more about the Frameworks at https://www.privacyshield.gov/welcome.
You may reach us at email@example.com to ask whether your personal data are subject to transfer to a third country.
4. SOCIAL NETWORKS
The Website contains social networks plug-ins such as LinkedIn, Telegram, Instagram, Twitter, Facebook, Medium, GitHub, Discord. When you click on them, the respective social network may record that you were redirected from the Website, and any such processing of your personal data is subject to the privacy rules of the respective social network. Velas is not responsible for data collected by these social networks.
5. SECURING YOUR PERSONAL DATA
Velas does its best to keep your data secure. We always review and update appropriate technical and organisational measures to keep your personal data secure, in accordance with our internal policies and procedures regarding the storage of, access to and disclosure of personal data.
Some of your personal information undergoes anonymisation, pseudonymisation, and encryption to ensure safe transfer and/or processing.
6. HOW LONG DO WE STORE YOUR PERSONAL DATA?
We will maintain records of your personal data for as long as:
- (1) you are subscribed to our mailing list;
- (2) it is necessary to provide our services to you (including the Website);
- (3) the data are necessary for other purposes described in this Privacy Notice.
When the processing of your personal data is no longer necessary, subject to this Privacy Notice and the requirements of the applicable law, we will either delete or anonymise such personal data.
If the processing of certain personal data is based on your consent and you have withdrawn it, we will stop processing of such data if we are not otherwise legally permitted or required to keep these data.
Please note that we may further process your personal data if it is required by the Applicable Legislation or is necessary to for the purposes of defending or making legal claims until the end of the period required by the relevant law or until the settlement of any such claims, as applicable.
7. YOUR DATA PROTECTION RIGHTS
Subject to certain limitations under the Applicable Legislation, you have the following rights:
- (1) right to withdraw your consent at any time (if we process your personal data on the basis of your consent);
- (2) right to access to your personal data (i.e. the right to receive certain information regarding your personal data processing and a copy of your personal data that undergoes processing);
- (3) right to correct your incorrect data and complete your incomplete data;
- (4) right to erase your personal data (right to be forgotten). This right may be used where (i) the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent, where the processing is based on your consent, and where there is no other legal ground for the processing; (iii) you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR; (iv) the personal data has been unlawfully processed; (v) the personal data must be erased for compliance with a legal obligation in accordance with the Applicable Legislation to which Velas is subject; and/or (vi) the personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR;
- (5) right to restrict use of your personal data. This right may be used where (i) the accuracy of the personal data is contested by you, for a period enabling Velas to verify the accuracy of the personal data; (ii) the processing is unlawful and you oppose the erasure of the personal data and request instead the restriction of its use; (iii) we no longer need the personal data for the purposes of the processing, but you require us process your data for the establishment, exercise, or defence of legal claims; and/or (iv) you object to processing pursuant to Article 21(1) of the GDPR pending the verification of whether our legitimate grounds override yours rights, interests, and freedoms;
- (6) right to data portability (if we process your data on the basis of your consent or performance of a contract with you);
- (7) right to submit a complaint with a supervisory authority.
You also have the right to object to the processing of your personal data for the direct marketing purposes, as well as the right to object to the processing based on our legitimate interest.
Velas does not make any automated decision-making regarding any of your personal data.
To exercise your rights please contact us at firstname.lastname@example.org with the description of your request. Please note that in this case we may request you to provide certain proofs to verify your identity.
8. CHILDREN’S PERSONAL DATA
We do not knowingly process any personal data of children, i.e. persons below 16 years old. In the case we realise that we process personal data of a child, we promptly delete such personal data.
9. CHANGES TO THIS PRIVACY NOTICE
Velas may unilaterally make changes to this Privacy Notice at any time, in its sole discretion. In such case, we will update the “Last updated” date above. Such changes will take effect as soon as they are posed unless otherwise is decided by Velas. Please check back frequently to see any updates or changes to this Privacy Notice.