OnchainLabs attaches great importance to protecting personal data and collects, processes, and uses personal and/or company data solely by the principles described below and in compliance with the applicable data protection provisions. Based in Switzerland, OnchainLabs primarily complies with the Swiss Data Protection Act (FADP).
If personal and/or company data is processed from people who have the right to rely on their own legal system – in particular the EU General Data Protection Regulation (GDPR) – OnchainLabs will also follow these rules, if applicable to OnchainLabs, and grant these persons and/or companies rights specific to their law.
Personal and/or company data is all information relating to an identified or identifiable natural person and/or company, including, for purposes of how the Service is used, such as the date and time a message was sent, the account the user was messaging with, the user’s internet protocol address, and any third-party websites or services the user uses, for example, a user’s name and postal and email address.
Blockchains, also known as distributed ledger technology (or simply ‘DLT’), are made up of digitally recorded data in a chain of packages called ‘blocks’. These blocks are linked chronologically, meaning that the data is difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.
Accordingly, by design, records of a Blockchain cannot be changed or deleted and are said to be ‘immutable’. This may affect your ability to exercise your rights, such as your right to erasure (the ‘right to be forgotten’) or your rights to object or restrict the processing of your personal data. Data on the Blockchain cannot be erased and cannot be changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.
In certain circumstances, to comply with our contractual obligations to you (such as delivering Tokens), we will need to write specific personal data, such as your Wallet address, onto the Blockchain. This is done through a smart contract, and you must execute such transactions using your Wallet’s Private Key.
In most cases, you make the ultimate decisions regarding (i) transacting on the Blockchain using your Wallet and (ii) sharing the Public Key related to your Wallet with anyone (including us).
1. Data controller for the operation of OnchainLabs
Onchain Technologies AG (CHE-295.245.185), Dammstrasse 16, 6300, Zug, SWITZERLAND ("OnchainLabs"), operates the OnchainLabs website and the software and platform OnchainLabs Web3 SaaS (together: “OnchainLabs Web3 SaaS”) and collects, processes, and uses personal and/or company data of users of OnchainLabs Web3 SaaS (“users”) solely to implement this program.
Users can contact OnchainLabs regarding questions about this privacy policy or OnchainLabs' privacy practices using the following contact details:
Onchain Technologies AG, Dammstrasse 16, 6300, Zug, SWITZERLAND
E-Mail: contact@onchainlabs.ch
Onchain Technologies AG representative in the EEA according to art. 27 GDPR is:
LITC - Jasmin Lieffering, Verdener Landstraße 4, DE-31623 Drakenburg,
E-Mail: info@litc.de
Users can make a complaint at any time to the Federal Data Protection and Information Commissioner, the Swiss supervisory authority for data protection issues (FDPIC). OnchainLabs would, however, appreciate the chance to deal with your concerns before you reach out to the supervisory authority, so please get in touch with us in the first instance.
2. Data collection in connection with the OnchainLabs Platform
For the operation of OnchainLabs Web3 SaaS, to communicate and provide you our services, OnchainLabs collects and saves the following personal and/or company data in a central customer database:
2.1 Data collected by OnchainLabs Platform
(1) Information given by the users
OnchainLabs collects content and personal and/or company data if the user uses OnchainLabs Web3 SaaS. For example, when a user signs up for an account or sends messages or communicates with others, including OnchainLabs itself (support or any artificial intelligence tool integrated into the OnchainLabs platform), users may give OnchainLabs information. This personal and/or company data includes, but is not limited to, the user’s name, username, email address, phone number, address, birth date, contact preferences, photos, and gender, plus any data provided voluntarily by the users of OnchainLabs Web3 SaaS.
(2) Information OnchainLabs gets from the use of OnchainLabs Web3 SaaS
OnchainLabs collects information to provide the users with the functionality of OnchainLabs Web3 SaaS, to improve the user’s experience using OnchainLabs Web3 SaaS, and to develop new functionalities and services in and to OnchainLabs Web3 SaaS. To do this, OnchainLabs collects information about how the users use OnchainLabs Web3 SaaS and other online products and services that might be available by OnchainLabs. Sometimes, this information will be associated with the user’s personal and/or other information. For example:
- Device information: OnchainLabs collects device-specific information such as the user’s hardware model, operating system version, unique device identifiers, and mobile network information, including phone number if applicable.
- Log information: When users use OnchainLabs Web3 SaaS, OnchainLabs automatically collects and stores certain information, including data used.
- Friend information: If users use OnchainLabs Web3 SaaS's chat option, OnchainLabs may use the information in their mobile device’s address book to connect them with friends and allow other friends who have the user in their address book to find them. In addition, OnchainLabs stores information about the user’s friends in OnchainLabs Web3 SaaS.
- Bot chats: If the user chats with bots made or used by OnchainLabs, OnchainLabs collects the conversation's contents to improve the user experience and OnchainLabs Web3 SaaS or to create new ones.
- Local storage: OnchainLabs may collect and store information locally on the user’s device using mechanisms such as browser web storage (including HTML 5) and application data caches.
- Tracking IDs and similar technologies: OnchainLabs or its service providers (such as tracking ID and analytics providers) may collect, store, or recognize information on the user’s device from technologies, including, but not limited to, cookies and web beacons.
(3) Google Analytics
OnchainLabs uses Google Analytics, a web analytics service that Google, Inc. (“Google”) provides. Google Analytics uses “cookies”, which are text files placed on the user's computer, to help the website analyze how the user uses the site. The information generated by the cookie about the use of the website (including the user's IP address) will be transmitted to and will be stored by Google on servers in the United States of America (“USA”). In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union and other parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to and shortened by Google servers in the USA. On behalf of OnchainLabs, Google will use this information to evaluate the user's use of OnchainLabs Web3 SaaS, compiling reports on OnchainLabs Web3 SaaS activity for OnchainLabs and providing other services relating to OnchainLabs Web3 SaaS activity and usage to OnchainLabs. Google will not associate the user's IP address with any other data held by Google. The user may refuse the use of cookies by selecting the appropriate settings within OnchainLabs Web3 SaaS. However, if this is done, the user may be unable to use the full functionality of OnchainLabs Web3 SaaS. Furthermore, the user can prevent Google’s collection and use of data by switching off the Google Analytics function in the settings of their account.
Further information concerning the terms and conditions of use and data privacy can be found at https://www.google.com/intl/analytics/policies/privacy/
3. Purpose of Data Processing and Legal Grounds
The data stated under Section 2 is used by OnchainLabs for the following purposes:
(1) Provide, improve and develop the Services and OnchainLabs Web3 SaaS
Including provide you with our Service, including, but not limited to, helping get clients onchain, use different plug-in’s such as creating and managing their NFT or token collections, interacting with customers, providing a client interface, connect directly with others to purchase, sell, or transfer assets on public blockchains.
OnchainLabs will use personal and/or company information, such as your username, in connection with the Web3 SaaS. It may also send you notifications related to actions on the Web3 SaaS and use the user’s contact information to enable the third-party provider to contact the user.
(2) OnchainLabs uses the collected information to deliver and enhance its services, improve OnchainLabs Web3 SaaS, and make user suggestions.
For example, OnchainLabs uses some registration information to (a) set up a profile page for the user and (b) help the user with suggestions within the Web3 SaaS for additional features that might fit the user's profile. OnchainLabs processes personal and/or company data for these purposes based on OnchainLabs' legitimate interest and based on the performance of a contract and to communicate with the users.
The information OnchainLabs collects lets OnchainLabs keep the user posted on OnchainLabs' latest announcements, software updates, and messages by OnchainLabs (opt-out function provided). OnchainLabs processes personal and/or company data for these purposes based on OnchainLabs' legitimate interest and contract performance.
(3) Show and measure ads and Services
OnchainLabs might use the information to make suggestions, improve its services, and measure the effectiveness and reach of its ads and services. This would allow OnchainLabs to show users relevant services on OnchainLabs Web3 SaaS.
Promote Safety and Security: OnchainLabs may use the user’s information, including date of birth, to verify identity, determine eligibility to use OnchainLabs Web3 SaaS, and recommend appropriate services. It may also use the information to prevent loss and fraud and enforce its Terms and Conditions.
(4) Further Information
Suppose a user has given OnchainLabs their relevant consent. In that case, OnchainLabs may send the user further information about OnchainLabs’ products and exclusive offers by email and/or by post. Consent can be revoked at any time. Based on the data collected, OnchainLabs may personalize the information sent to the user so that the user mainly receives, where possible, information that OnchainLabs deems interesting for the relevant user. For this purpose, OnchainLabs analyzes the data collected and, in particular, takes account of the saved information relating to age, sex, usage of the OnchainLabs Web3 SaaS, and other information that can be gleaned from the collected data. OnchainLabs processes personal and/or company data for these purposes based on OnchainLabs' legitimate interest.
4. Data Retention
OnchainLabs will only retain personal and/or company data for as long as reasonably necessary to fulfill the purposes we collected it for, including to comply with any legal, regulatory, tax, accounting, or reporting requirements. OnchainLabs will keep the necessary data for the duration of the entire business relationship (from the initiation, during the performance of the contract, until it is terminated) and beyond this duration by legal retention and documentation obligations under applicable laws.
As soon as the user’s personal and/or company data are no longer required for the abovementioned purposes, they will be deleted or anonymized to the extent possible. OnchainLabs may delete or terminate inactive accounts (i.e., accounts that are not logged in) for 180 Days.
5. Data Security
OnchainLabs has established appropriate technical and organizational security procedures to prevent personal and/or company data from being accidentally lost, used, accessed unauthorizedly, altered, or disclosed. In addition, OnchainLabs limits access to users’ personal and/or company data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process personal and/or company data according to OnchainLabs' instructions and are subject to a confidentiality duty. Furthermore, OnchainLabs has put in place procedures to deal with any suspected personal and/or company data breach and will notify you and any applicable regulator of a breach where OnchainLabs is legally required to do so. Nevertheless, a user should always be aware that the transmission of data over the Internet and other electronic means entails certain security risks and that OnchainLabs cannot guarantee the security of data transmitted in this way.
6. Data processing
The central database, in which all collected data described in Section 2 is saved, is operated on behalf of and by OnchainLabs' instructions. OnchainLabs is the controller under data protection law and ensures compliance with the provisions of data protection law and the requisite security measures in the context of contract data processing.
7. Third-party links
OnchainLabs Web3 SaaS may include links to third-party websites. Clicking or enabling those links may allow third parties to collect or share your data. OnchainLabs does not control these third-party websites and is not responsible for their privacy statements. When a user leaves the Platform or website, OnchainLabs encourages users to read the privacy policy of every website they visit.
8. Information on the user’s rights
Under certain circumstances, users have rights under applicable data protection laws about their personal and/or company data. Users may have the right to access, rectification, and erasure of their personal and/or company data, the right to restriction of processing, or to object to our data processing in addition to the right to receive specific personal and/or company data for transfer to another controller (data portability).
If a user wishes to exercise any of the rights set out above, they can contact OnchainLabs, as the controller, by using the contact information mentioned in Section 1.
9. Right of revocation
So far as the users of OnchainLabs Web3 SaaS have given their consent for their data to be used for advertising purposes, they may revoke this consent with future effect at any time and free of charge by email or for the Newsletter by clicking on the unsubscribe button.
10. Corporate Mergers
Suppose OnchainLabs merges, acquires, restructures, sells, becomes bankrupt, or is involved in any such transaction. In that case, OnchainLabs may sell, transfer, or transfer assets, including user information, in connection with or considering such transactions (e.g., due diligence). Within the scope of the examination (e.g., due diligence) of such a transaction, OnchainLabs has a legitimate interest in making specific personal and/or company data accessible to an interested party. If users' personal and/or company data is transferred to a new controller as part of such a transaction, OnchainLabs will inform the users in advance and grant them an opt-out right. If a user uses such a right, OnchainLabs cannot guarantee that a user will be able to continue and fully use OnchainLabs' services.
11. Changes to this Privacy Policy
OnchainLabs reserves the right to change this privacy policy at any time under this provision. If OnchainLabs changes the privacy statement, OnchainLabs will update the amended privacy statement on the website and in the OnchainLabs Web3 SaaS. OnchainLabs will notify users thirty days before the changes. If a user disagrees with the amended privacy policy, they may terminate the account immediately and free of charge.