# Privacy Policy
# General information
Golem Stiftung, a Swiss Stiftung, located at Grafenauweg 8, 6300 Zug, Switzerland (the “Foundation”, “we”, or “us”), is the operator of any Website published by the Foundation, including, but not limited to, octant.app and octant.build (the “Websites”).
As the operator of the Websites, we take the protection of your personal data very seriously. We collect, process, and use your personal data in accordance with this privacy policy and in compliance with the Swiss Federal Act on Data Protection (“FADP”), the Swiss Ordinance to the Federal Act on Data Protection (“OFADP”), and the General European Data Protection Regulation (“GDPR”).
This privacy policy (“Privacy Policy”) provides you with information about the collection, processing, and use of your personal data when using the Websites.
Responsible Person
For any matters, relating to data protection you may contact [email protected] in writing by e-mail or letter to the following address: Golem Stiftung, Grafenauweg 8, 6300 Zug, Switzerland.
# Data processing in connection with the Websites
Matomo Analytics
The Websites may use Matomo (opens new window), an open source web analytics platform ("Matomo Analytics"). We may receive the following information because of Matomo Analytics:
- Behavioral Analytics
- How much time are users spending on each page / feature (e.g. where are users spending the most time
- Where are the users exiting the app? (drop off point)
- Which journeys/paths through the app are most/least utilized
- Heat Maps
- Time Per view
- Button clicks (e.g. which buttons are being clicked the most)
- Which pages/features are not being used
- User Journey Analytics
- Conversion rate across individual Websites
- Conversion/Entry from various social channels and campaigns
- Visitors Per Day/Week/Month
- Content Analytics
- Which links and campaigns users are most effectively converting from
We may use this technical data to analyze your use of the Websites by compiling reports on Website activity for the understanding and/or optimizing of our Websites and/or for internal statistical purposes. We do not use the information and personal data collected by Matomo to identify individuals unless we become aware of specific indications of illegal use.
Any processing of this technical personal data helps us to identify what is working and what is not on our Websites and how we may improve our Websites. Without any data thus received, we may not be able to provide you the service we are currently offering to you. Your data will be used only to improve the user experience on our Websites and help you find the information you are looking for. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.
You may set your Internet browser to disable the tracking of you as a user (the 'Do not track' signal). If we receive this signal, we will not collect any data, and the analytics tool will ignore your visits to our Websites. You may use the links below to find out how to set the 'Do not track' signal in your browser: Mozilla Firefox (opens new window), Google Chrome (opens new window), Opera (opens new window), Safari (opens new window).
Coookies
The octant.app website uses two third-party, non-tracking cookies set for every visitor. One is set by Cloudflare and the other by WalletConnect, both of which help protect the website against bots (opens new window). Additionally, users who have enabled the "Show help videos" setting will receive four cross-site cookies from Vimeo, where our video explainers are hosted. We have applied the Do Not Track parameter to the video player. The cookies set by Vimeo are also used exclusively for bot prevention, and no user is identified or tracked across the web (opens new window).
Contact possibility via the Websites
You may contact us by e-mail to the following e-mail address: [email protected]. We use the data you provide, such as contact details, which you may give voluntarily, only in order to answer your contact question or to reply to your e-mail in the best possible manner. Therefore, the processing of this data is in our legitimate interest in accordance with Art. 6 Par. 1 lit. f GDPR and you have provided consent in accordance with Art. 6 Par. 1 lit. a GDPR.
Registration for our newsletter
The receipt of our newsletter requires registration. For this you must provide your e-mail address. By registering, you give us your consent to process the given data in order to periodically send the newsletter to the address you have given. This consent constitutes the legal basis for our processing of your e-mail address in the sense of Art. 6 Par. 1 lit. a GDPR. All information gathered this way will never be passed on or sold to any third party.
At the end of each newsletter a link is provided by means of which you can unsubscribe at any time. After unsubscribing your personal data will be deleted.
Wallet addresses and on-chain data
Some of the use of the Websites involves interactions with the underlying blockchain smart contracts with your crypto wallet. By nature of blockchain technologies, your wallet address and transaction data and history, are permanently recorded and publicly available on the blockchain. This data generally cannot be altered or erased by any party once it is published. If maintaining complete privacy is a concern, blockchain transactions may not fully protect such rights due to the inherent properties of the technology. We may use the on-chain data, including wallet addresses, for the purpose of providing and maintaining the functionality of our Websites. This is our legitimate interest in the sense of Art. 6 Par. 1 lit f GDPR.
Other parties who have access to information we collect
With the exception of the provider(s) of our Websites, 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.
Personal data collected via the Websites may be passed on to and/or accessed by the Website service provider(s). The Websites may be hosted on servers in the US. The transfer of data is for the purpose of providing and maintaining the functionality of our Websites. This is our legitimate interest in the sense of Art. 6 Par. 1 lit f GDPR.
International transfer of personal data
We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing described in this Privacy Policy. This concerns especially our Websites service providers.
They are obliged to protect data privacy to the same extent as we ourselves. If the level of data protection in a given country 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 and complying with the GDPR.
Data security
We use appropriate technical and organizational security measures to protect your stored personal data against manipulation, partial or complete loss, and unauthorized access by third parties.
Please note that any data transmission on the Internet (e.g. communication by e-mail) is generally not secure and we accept no liability for data transmitted to us via the Internet. Unfortunately, absolute protection is not technically possible.
This information does not apply to the Websites of third parties and the corresponding links given on our Websites. The Foundation assumes no responsibility and liability for these.
# Your Rights regarding your data
Right to confirmation
You have the right to obtain confirmation from the Foundation as to whether or not personal data concerning you is being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact the responsible person as stated above.
Right to access
You have the right to obtain from the Foundation 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 or international organizations;
- 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 the Foundation 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.
If you wish to avail yourself of this right of access, you may at any time contact the responsible person as stated above.
Right to rectification
You have the right to obtain from the Foundation, 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. If you wish to exercise this right to rectification, you may, at any time, contact the responsible person as stated in above.
Right to erasure (right to be forgotten)
You have the right to obtain from the Foundation the erasure of personal data concerning you as soon as possible, and the Foundation 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 the Foundation 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.
If any one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by the Foundation, you may at any time contact the responsible person as stated above. The responsible person at the Foundation shall promptly ensure that the erasure request is complied with as soon as possible.
Right to restriction of processing
You have the right to obtain from the Foundation restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by you, for a period enabling the Foundation 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;
- the Foundation 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 the Foundation 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 the Foundation, you may at any time contact the Foundation's responsible person. The responsible person will arrange the restriction of the processing.
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.
The Foundation shall no longer process the personal data in the event of the objection, unless the Foundation 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.
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 the Foundation, 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 the Foundation, or (2) it is based on your explicit consent, the Foundation 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.
Please note that the Foundation does not use automatic decision-making but we may use profiling according to these Privacy Policy rules.
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 above.
Duration of the storage
The Foundation will process and store the personal data of the data subject 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, or if a storage period prescribed by the applicable laws expires, the personal data is routinely erased in accordance with the legal requirements.
Minors
The Foundation does not knowingly collect or use any personal data from minors. A minor may be able to willingly share personal information with others, depending on the products and/or media channels used. If a minor provides us with their information without the consent of their parent or guardian, we will ask the parent or guardian to contact us for the purpose of deleting that information.
Updates to our Privacy Policy
The Foundation may update this Privacy Policy from time to time and inform you on the Websites that the policy has been amended. The current version of the Privacy Policy, as published on our Website, is applicable. With each update to our policies, we will note which sections have been updated.
Please do not hesitate to contact us if you have any questions regarding this Privacy Policy by contacting us at [email protected].
Last updated: October 30, 2024.