We can assure you that we comply with the Swiss Federal Act on Data Protection, the Swiss Ordinance to the Federal Act on Data Protection, and the European General Data Protection Regulation (hereinafter the “GDPR”) and that we process your Data lawfully, fairly and transparently.
If you are younger than 18 years old, you are not allowed to use our Website without the permission of your parents or legal guardian.
We take confidentiality and privacy issues very seriously. We therefore ensure that your personal information is secure; we communicate our privacy and security guidelines and practices to all our employees and service providers and strictly enforce privacy safeguards within our company.
1. DEFINITIONS AND INTERPRETATION
Personal Data: all information making you directly or indirectly identifiable (e.g. your name, first name, address, phone number or email address but also the IP address of your computer, for example, or the information relating to your browsing of our Website).
Data Controller: The processing of any personal data provided or collected on the Website is carried out under the supervision of ETA, Baarerstrasse 10, 6300 Zug, E-Mail: firstname.lastname@example.org, Website: www.devxdao.com.
GDPR: The “General Data Protection Regulation” (EU Regulation 2016/679), as well as any national legislation adopted in accordance therewith.
The singular includes the plural and vice versa;
References to sections, clauses, appendices refer to the sections, clauses, appendices
A reference to a person includes firms, companies, government entities, trusts, and
“Including” means “including but not limited to”;
A reference to any legislative provision includes all amendments thereto;
3. RESPONSIBLE PERSON / CONTACT DETAILS
Responsible for the Personal Data collected is our data protection officer with business address at Baarerstrasse 10, 6300 Zug, Switzerland (the “Responsible Person”). For any matters relating to data protection you may contact email@example.com by e-mail or by letter to the following address:
ETA Baarerstrasse 10 6300 Zug Switzerland
Representative in the EU according to article 27 GDPR is:
Timothy Lewis, with business address in Oderberger Strasse 43, 10435 Berlin, Germany. For any matters relating to data protection you may contact firstname.lastname@example.org by e-mail (please copy email@example.com) or by letter to the following address:
Timothy Lewis Oderberger Strasse 43 10435 Berlin
4. DATA PROCESSING IN CONNECTION WITH OUR WEBSITE
IP address (automatically collected);
Web browser type and version (automatically collected);
Operating system used by accessing the Website (automatically collected);
Your browsing history to and from the Website;
The date and time of access to the Website
The internet service provider of the accessing system
Any other similar data and information that may be used in the event of attackes on our
information technology systems
The collection and processing of this technical data is for the purpose of
enabling the use of our website:
developing our products, contents of our Website and services further;
Continuously improving our Website and offering you a more enjoyable and efficient
For internal statistical purposes
This is our legitimate interest in the processing of Data in the sense of Art. 6 Par. 1 lit. f. GDPR.
4.3. Contact Possibility via the Website
The Website may contain a contact form that enables a quick electronic contact to ETA, as well as direct communication with us, which also included a general address of the e-mail address. If you contact us by e-mail or via contact form, the personal data transmitted by you is automatically stored.
Such Personal Data transmitted on a voluntary basis by you to us is stored for purpose of processing or contacting you and to handle your request and provide you the service or support you requested. The legal basis for the data processing for these purposes lies in the fulfilment of an agreement in accordance with Art. 6 Par. 1 lit. b GDPR and you have provided consent in accordance with Art. 6 Par. 1 lit. a GDPR.
4.4. Use of Website Cookies:
Internet browser. For further information, visit https://www.allaboutcookies.org/.
You may prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, previously set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you deactivate the setting of cookies in the Internet Browser used, it may not be possible to use all the functions of our Website.
Two types of cookies may be used on the Website – “session cookies” and “persistent cookies”. Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).
The table below summarizes the different types of cookies we use on the Website, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).
Cookies used on the Website:
5. RETENTION OF PERSONAL DATA
The retention period of Personal Data processed by ETA may vary depending on common practice, and considered in accordance with the legal obligations and the applicable limitation rules. In any way, ETA will process and store the Personal Data only for the period necessary to achieve the purpose of storage or as far as this is granted by the applicable laws or regulations.
If the storage purpose is not applicable any more, or if the storage period prescribed by the applicable laws and regulations expires, the personal data are routinely erased in accordance with legal requirements.
6. PERSONAL DATA SECURITY
Personal Data security is of great importance to ETA. In order to protect your Personal Data, we have implemented appropriate physical, electronic and organizational procedures to safeguard and secure the Personal Data collected via our Website in order to ensure its integrity and confidentiality. Our security measures are continuously being improved in line with technical developments. All Personal Data is securely stored in accordance with industry standards and the Swiss Federal Act on Data Protection, the Swiss Ordinance to the Federal Act on Data Protection and the GDPR.
If a password is required to access certain sections of our Website, you are responsible for keeping this password confidential.
We endeavor to do all we can to protect your Personal Data. However, the transmission of information on the Internet is not fully secure and remains under your sole responsibility. We cannot ensure the security and accept no liability of the transmission of your Data to our Website.
7. OTHER PARTIES WHO HAVE ACCESS TO INFORMATION WE COLLECT
With the exceptions described in this section, we do not make your Personal Data available to third parties unless you have expressly consented to it, if we are legally obligated to, or if this is necessary to enforce our rights concerning a contractual relationship.
We transmit your Data only to our employees who are authorized to process them as part of their duties.
We may transmit some of your Data to the technical and logistic service provider of our Website located in Switzerland acting on our behalf, and we ensure that they provide for the necessary guarantees with respect to the Swiss Federal Act on Data Protection, the Swiss Ordinance to the Federal Act on Data Protection and the GDPR. The transfer of data is for purpose of providing and maintaining the functionality of our Website. This is our legitimate interest in the sense of Art. 6 Par.1 lit. b and lit f GDPR.
We process your Data in principle in Switzerland. In case it is necessary to transfer your Data to third parties outside Switzerland and the EU, the Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the Swiss and European standards.
If the level of data protection in a country where a service provider is located does not correspond to the Swiss and European data protection level, we contractually ensure that the protection of your personal data corresponds to that in Switzerland and the EU at all times by concluding agreements using the standard contractual clauses complying with the GDPR.
8. LINKS TO OTHER WEBSITES
9. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
a) Right to confirmation
b) Right to access
You have the right to obtain from ETA free information about your personal data stored at any time and a copy of this information. Furthermore, you will have access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be
disclosed, in particular recipients in third countries;
where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period;
the existence of the right to request from ETA rectification or erasure of personal data, or
restriction of processing of personal data concerning you, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected directly from you, any available information as
to their source; and
the existence of automated decision-making, including profiling, referred to in Article
22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
c) Right to rectification
You have the right to obtain from ETA, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
d) Right to erasure (right to be forgotten)
You have the right to obtain from ETA the erasure of personal data concerning you as soon as possible, and ETA shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR;
The personal data has been unlawfully processed;
The personal data must be erased for compliance with a legal obligation in accordance
with the applicable law to which ETA is subject; and/or
The personal data has been collected in relation to the offer of information society
services referred to in Article 8(1) of the GDPR.
e) Right to restriction of processing
You have the right to obtain from ETA restriction of processing where one of the following applies:
The accuracy of the personal data is contested by you, for a period enabling ETA to verify the accuracy of the personal data;
The processing is unlawful and you oppose the erasure of the personal data and requests instead the restriction of their use instead;
ETA no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; and/or
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of ETA override those of the data subject.
If any one of the aforementioned conditions is met, and you wish to request the restriction of the processing of Personal Data stored by ETA, you may at any time contact ETA’s Responsible Person. The Responsible Person will arrange the restriction of the processing.
f) Right to object
You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
ETA shall no longer process the personal data in the event of the objection, unless ETA can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defense of legal claims. In order to exercise the right to object, you may directly contact the Responsible Person.
g) Right to data portability
You have the right to receive the personal data concerning you, which was provided to ETA, in a structured, commonly used and machine-readable format. You shall have the right to transmit those data to another controller without hindrance from ETA to which the personal data has been provided, as long as the processing is based on consent pursuant to article 6 (1) GDPR or point (a) of article 9 (2) GDPR, or on a contract pursuant to point (b) of article 6 (1) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest.
Furthermore, in exercising your right to data portability pursuant to article 20 (1) GDPR, you shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, you may at any time contact the Responsible Person according to section 3.
h) Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between you and ETA, or (2) is not authorized by the applicable law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between you and ETA, or (2) it is based on your explicit consent, ETA shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.
i) Right to withdraw data protection consent
You have the right to withdraw your consent to processing of your Personal Data at any time.
If you wish to exercise the right to withdraw the consent, you may at any time directly contact the Responsible Person as stated in section 3.
Unless otherwise agreed, no delay, act or omission by a party in exercising a right or remedy will be deemed a waiver of such right, or of another right or remedy.
If our company is the subject of a corporate transaction such as an acquisition or merger with another company, your information may be transferred to the new owners so that we can continue to sell our products to you.
MORE INFORMATION ABOUT PRIVACY REGULATIONS
● EU General Data Protection Regulation https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ENG
● Swiss Federal Act on Data Protection https://www.admin.ch/opc/en/classified-compilation/19920153/index.html
● Swiss Ordinance to the Federal Act on Data Protection https://www.admin.ch/opc/en/classified-compilation/19930159/index.html
Last updated: 30 March 2021