OnchainLabs attaches great importance to the protection of personal data and collects, processes and uses personal and/or company data solely in accordance with the principles described below and in compliance with the applicable data protection provisions. OnchainLabs is based in Switzerland and complies primarily 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 on 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, which includes, for example, user’s name as well as user’s postal and email addresses.
Blockchains, also known as distributed ledger technology (or simply ‘DLT’), are made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very 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 (‘right to be forgotten’), or your rights to object or restrict 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, in order to comply with our contractual obligations to you (such as delivery of Tokens) it will be necessary to write certain personal data, such as your Wallet address, onto the Blockchain; this is done through a smart contract and requires you to execute such transactions using your Wallet’s Private Key.
In most cases, ultimate decisions to (i) transact on the Blockchain using your Wallet, as well as (ii) share the Public Key relating to your Wallet with anyone (including us) rests with you.
1. Data controller for the operation of OnchainLabs
Onchain Technologies AG (CHE-295.245.185), Mühlebachstrasse 84, CH-8008 Zurich, Switzerland ("OnchainLabs") operates OnchainLabs website as well as 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 for the implementation of this program.
Users can contact OnchainLabs regarding questions about this privacy policy or OnchainLabs privacy practices using the following contact details:
Onchain Technologies AG, Mühlebachstrasse 84, CH-8008 Zurich, 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 have the right to 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 approach the supervisory authority so please contact us in the first instance.
2. Data collection in connection with 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 messages or communicates with others, including OnchainLabs itself (support or any artificial intelligence tool integrated in OnchainLabs platform), users may give OnchainLabs information. This personal and/or company data is including, but 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. In some cases, 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 details of how OnchainLabs Web3 SaaS is used, such as the date and time a message was sent, the account the users were messaging with, and the user’s internet protocol address, as well as third-party websites or services the users used.
- Friend information: If users use the chat option of OnchainLabs Web3 SaaS, OnchainLabs may use the information from the user’s mobile device’s address book to connect the users with friends and to allow other friends who have the user in their address book to find the user. In addition, OnchainLabs stores information of the user’s friends in OnchainLabs Web3 SaaS.
- Bot chats: If the user chats with bots made or used by OnchainLabs, OnchainLabs collects the contents of the conversation 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 ID’s and similar technologies: OnchainLabs or its service providers (such as tracking ID and analytics providers) may collect, store or recognize some 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 provided by Google, Inc. (“Google”). 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 as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of OnchainLabs, Google will use this information for the purpose of evaluating 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 not be able 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 his account.
Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms or 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 your personal and/or company information such as your username and others in connection with the Web3 SaaS. OnchainLabs may send you notifications related to actions on the Web3 SaaS and will use the user’s contact information to enable the third-party provider to get in touch with the user.
(2) OnchainLabs uses the collected information to deliver and enhance its services and to improve OnchainLabs Web3 SaaS and to make suggestions to the users. 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 profile of the user. 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 based on the performance of a contract.
(3) Show and measure ads and Services
OnchainLabs might use information for suggestions and to improve its services and measurement systems so that OnchainLabs can show the user relevant services on OnchainLabs Web3 SaaS and measure the effectiveness and reach of the ads and services.
Promote Safety and Security: OnchainLabs may use the user’s information, including date of birth, to verify identity, to determine eligibility to use OnchainLabs Web3 SaaS, and to recommend appropriate services. OnchainLabs may also use information for loss prevention and anti-fraud purposes and to enforce its Terms and Conditions.
(4) Further Information
If a user has given OnchainLabs his or her relevant consent, OnchainLabs may send the user further information about OnchainLabs’, product information 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 particularly receives, where possible, information which 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, as well as 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 for the purposes of compliance 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) as well as beyond this duration in accordance with 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 above-mentioned purposes, they will be deleted or anonymized, to the extent possible. OnchainLabs may delete or terminate accounts that are inactive (i.e., not logged into) for 180 Days.
5. Data Security
OnchainLabs has put in place appropriate technical and organizational security procedures to prevent personal and/or company data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, OnchainLabs limits access to user’s 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 on OnchainLabs instructions, and they are subject to a duty of confidentiality. 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 give any guarantee for the security of data that are 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 in accordance with 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 on those links or enabling those connections may allow third parties to collect or share data about you. 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 in relation to 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 certain 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, he/she 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 contacting email or for Newsletter by clicking on the unsubscribe button.
10. Corporate Mergers
In the event that OnchainLabs merges, acquires, restructures, sells, becomes bankrupt or involved in any such transaction, OnchainLabs may sell, transfer or transfer assets, including user information, in connection with such transaction or in consideration of such transaction (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 certain personal and/or company data accessible to an interested party. If personal and/or company data from users 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 makes use of such a right, OnchainLabs cannot guarantee that a user will be able to continue and to make full use of 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 makes changes to 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 does not agree with the amended privacy policy, he/she may terminate the account immediately and free of charge.
