Partisia Blockchain Foundation Privacy Policy

Preamble

The protection of personal data is important to Partisia Blockchain Foundation (hereinafter referred to as “Partisia”, “we”, “us”, “our”).
Therefore, we process personal data exclusively on the basis of the Swiss Federal Act on Data Protection (“FADP”) and the EU General Data Protection Regulation (“GDPR”).
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indi-rectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physio-logical, genetic, mental, economic, cultural or social identity of that natural person (“Per-sonal Data”).
We are the operator of the website https://partisiablockchain.com, including all its subdomains (e.g., https://kyc.partisiablockchain.com) and subpages, (together “Website”).
This Privacy Policy governs the gathering, collection, processing, storage and use of your Personal Data. We inform you about the types of Personal Data we collect, how this data is used, to whom it is transferred and what options and rights you have in connection with our data processing. We describe the measures we take to ensure data security and how you, as data subject, can contact us if you have any questions about our data protection practice.
By “you”, “your” we mean you, visitor of our Website, as natural person, and generally, every natural person browsing our Website and making use of our services as further described in this Privacy Policy.

I. Name and Address of the Controller

Partisia is the controller within the meaning of the GDPR and FADP that determine the purposes and means of processing Personal Data. You can contact us as follows:

Partisia Blockchain Foundation
c/o Sielva Management SA
Gubelstrasse 11
6300 Zug

The data protection officer / data protection coordinator of the controller can be contacted at:
E-mail address: info@partisiablockchain.com

II. General Information regarding the Processing of Personal Data

1. Scope of processing of Personal Data

We only process Personal Data if this is necessary to provide a functional Website as well as our contents and services. The processing of your Personal Data is normally only carried out with your prior consent, except those cases where prior consent cannot be obtained for factual reasons, for the performance of a contract or the processing of Personal Data is permitted by law.

2. Legal basis for processing of Personal Data

If you give us your consent to the processing of Personal Data, art. 6 (1) (a) GDPR serves as the legal basis for the processing.
If the processing of Personal Data is necessary for the performance of a contract to which you are a party, art. 6 (1) (b) GDPR serves as the legal basis for the processing. This also applies to processing operations that are necessary to carry out pre-contractual measures.
If the processing of your Personal Data is necessary for compliance with legal obligation to which we are subject (e.g., KYC obligations), art. 6 (1) (c) GDPR serves as the legal basis for the processing.
If the processing of your Personal Data is necessary to protect the vital interests of the data subject or another natural person, art. 6 (1) (d) GDPR serves as the legal basis for the processing.
If the processing of Personal Data is necessary for the purposes of the legitimate interests pursued by us or a third party and where such interests are not overridden by the interests, fundamental rights and freedoms of the data subject which require protection of Personal Data, art. 6 (1) (f) GDPR serves as the legal basis for the processing.

3. The erasure and storage of Personal Data

Your Personal Data will be erased or blocked as soon as it is no longer necessary in relation of the purpose of storage. Furthermore, Personal Data may be stored if this has been required by regulations, laws or other provisions to which Partisia is subject. The Personal Data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

III. Provision of the Website and creation of log files

1. Description and scope of processing of Personal Data

Every time you visit our Website, our system automatically collects following data and information from the computer system of the calling computer:

• • Information relating to your browser type and version used
  • Your IP address
  • Date and time of access

The data is also stored in the log files of our system but is not linked to or stored together with other Personal Data of you.

2. Legal basis for processing

The legal basis for the temporary storage of Personal Data and log files is art. 6 (1) (f) GDPR.

3. Purposes of processing

The temporary storage of the IP address by the system is necessary to enable the Website to be delivered to your computer. For this, the IP address must remain stored for the duration of the session.
The Personal Data is stored in log files to ensure the functionality of the Website. In addition, the data serves us to optimize the Website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context.
These purposes represent also our legitimate interest in data processing within the meaning of art. 6 (1) (f) GDPR.

4. Period of storage

The Personal Data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the Website, the data will be deleted when the respective session has ended.
If the Personal Data is stored in log files, it will be deleted after seven days at the latest. Further storage is possible. In this case, the IP addresses of you are deleted or alienated so that the calling client can no longer be assigned.

5. Possibility of objection and erasure

The collection of Personal Data for the provision of our Website and the storage of Personal Data in log files is absolutely necessary for the operation of the Website. Consequently, there is no possibility of objection.

IV. Cookies

Our Website uses cookies. Cookies are text files which your web browser automatically saves on the hard disk of your computer when you visit our Website and webpages of our Website. If you visit our Website, a cookie may be stored on your operating system. This cookie contains a characteristic sequence of characters that enables a unique identification of the browser when the Website is called up again. For more information, please see our Cookie Policy.

V. Social Media Plugins

So-called social media plugins (“Plugins”), in particular the LinkedIn button of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA, may be integrated on certain web pages of our Website (“Social Media Platforms”).
Plugins from other Social Media Platforms may be used on our Website (e.g., when you use the community section on our Website).
When you call up a page of our Website that contains such a Plugin, your browser establishes a direct connection to the servers of the respective Social Media Platform. The content of the Plugin is transmitted directly to your browser and integrated into the page. Through this integration, the Social Media Platform operator receives the information that your browser has called up the corresponding page of our Website, even if you do not have a profile on the respective Social Media Platform or are not currently logged in. This information (including your IP address) is transmitted by your browser directly to a server of the platform operator, which may be located in the USA, and stored there.
If you are logged in to the respective Social Media Platform, your visit to our Website can be directly assigned to your profile on the Social Media Platform. If you interact with the Plugins, for example by clicking the LinkedIn button, this information is also transmitted directly to a server of the platform operator and stored there. If you wish to prevent this, please log out of your Social Media Accounts before visiting our Website.
We have no influence on the data that LinkedIn, Telegram, Twitter or Instagram and any other Social Media Platform operators collect on the basis of their Plugins. The purpose and scope of the data collection and the further processing and use of the data by LinkedIn, Telegram, Twitter and Instagram, as well as your rights and settings options in this regard to protect your privacy, can be found in the data protection notices of the respective providers:

Additional information on the LinkedIn Plugin can be found here.
Additional information on the Telegram Plugin can be found here.
Additional information on the LinkedIn Plugin can be found here.
Additional information on the Telegram Plugin can be found here.

In order to increase the protection of your data when visiting our Website, the Plugins are not integrated into the page without restriction, but only using an HTML link (so-called “Shariff solution” from c’t). This integration ensures that when you call up a page of our Website that contains such Plugins, no connection is established with the servers of the provider of the respective social network. If you click on one of the buttons, a new window of your browser opens and calls up the page of the respective service provider on which you can (if necessary after entering your login data) e.g. click on the Like or Share button. The purpose and scope of the data collection and the further processing and use of the data by the providers on their pages as well as your rights in this regard and setting options for protecting your privacy can be found in the data protection notices of the respective providers.
In addition, you can completely prevent the loading of the Plugins with add-ons for your browser, such as the script blocker “NoScript”, which can be downloaded here.

VI. Registration for Partisia Blockchain ITO

On our Website, we offer users the opportunity to register for the Partisia Blockchain ITO by providing Personal Data. The data entered into the input mask is transmitted to us and stored by us. The following data is collected during the registration process:

• Email address
• Copy of passport or identity document
• Transcription of passport or identity document information
• Name
• Pictures/photo of your passport or identification document
• Gender
• Date of Birth
• Country of Origin
• Picture / Selfie of you
• Nationality/Domicile
• Source of funds
• Registered Public key of Bitcoin/Ethereum/Partisia address
• Utility Bill
• Video recording of you for AML/KYC purposes

At the time of registration, the following data is stored:

• Date and time of registration

The registration for the Partisia Blockchain ITO and the processing of your Personal Data serves to perform a contract to which you are party or to implement pre-contractual measures pursuant to art. 6 (1) (b) GDPR. Your registration is necessary if you wish to be part of the Partisia Blockchain ITO, for the performance of a contract or for the implementation of pre-contractual measures and to fulfill legal obligations we are bound to (KYC, AML provisions).
We are further required to gather, collect, and process Personal Data for KYC/AML, legal obligations and further mandatory, regulatory purposes, such as prevention of fraud and money laundering, taxes, adherence to reporting and further obligations, etc. In the carrying out of the Partisia Blockchain ITO and our services, to reduce the risk of money-laundering, fraud or abuse of our services, we or our third-party providers, may use automated processing and profiling. Through this automated processing, we carry out an analysis of your identification, transactional and behavioural patterns.
The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. Consequently, the Personal Data collected during the registration process to perform a contract or to carry out pre-contractual measures are erased as soon as it is no longer required for the execution of the contract. Even after conclusion of the contract, it may still be necessary to store Personal Data of the contractual partner in order to meet contractual or legal obligations.
As the Personal Data is necessary to perform a contract or to carry out pre-contractual measures, an early erasure of the data is only possible if neither contractual nor legal obligations prevent a deletion. Generally, your Personal Data will be stored for a period of ten years after termination of the contractual relationship with us and closure of your registration or after the fulfillment of our legal and regulatory obligations and requirements (e.g., pursuant to KYC, AML obligations; archiving requirements).

VII. Contact Form and E-mail Contact

1. Description and scope of processing of Personal Data

There are various contact forms on our Website which can be used for different purposes,for example,electronic contact,subscriptions,registrations or marketing purposes. If you take advantage of any of these possibilities, the following data entered in the respective contact form will be transmitted to us and will be stored,depending on the specific contact form:

• • Your name
  • Your e-mail address
  • Telegram, Twitter handler
  • Company / Organization
  • City, Country

Your consent is obtained for the processing of the Personal Data within the scope of the sending process and reference is made to this Privacy Policy. Alternatively, you can contact us via the e-mail address provided kyc@partisiablockchain.com. In this case, your Personal Data transmitted by e-mail will be stored. In this context, the Personal Data will not be transmitted to third parties. The data is used exclusively for processing the conversation.

2. Legal basis for processing

The legal basis for the processing of data is art. 6 (1) (a) GDPR if the user has given his consent.
The legal basis for the processing of Personal Data transmitted in the course of sending an e-mail is art. 6 (1) (f) GDPR. If the e-mail contact aims at the conclusion of a contract, then the additional legal basis for the processing is art. 6 (1) (b) GDPR.

3. Purpose of processing

The processing of Personal Data from the contact forms serves us only for the treatment of the purpose related to the respective contact form(e.g establishment of contact, provision of further information, registration for events, marketing communication). The Personal Data collected in the course of sending an e-mail represent also our legitimate interest in processing of Personal Data. The other Personal Data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Period of storage

The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected.
Consequently, the Personal Data from the contact form or the Personal Data that is sent by e-mail will be erased as soon as the respective conversation with the user is finished. The conversation is terminated when it can be inferred from the circumstances that the facts in question have been finally clarified.
The additional Personal Data collected during the sending process will be deleted after a period of seven days at the latest.

5. Possibility of objection and erasure

You have the possibility to withdraw your consent to the processing of Personal Data concerning you at any time. If you contact us by e-mail, you can object to the storage of your Personal Data at any time. In this case, the conversation cannot be continued. All Personal Data stored in the course of contacting us will be deleted in this case unless we are bound by law or contract to longer storage obligations.

VIII. Registration and Use of Blog on Website

Partisia offers you the possibility to subscribe to a blog, leave individual comments on individual blog contributions on a blog. A blog is a web-based, publicly accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third parties. Partisia uses a third-party website for its blog (see: https://partisiampc.medium.com/) (“Blog”).
Please be aware that the registration, use, processing and storage of your Personal Data as well as the content of your posts, comments or blog contributions for and within the Blog is subject to the terms, regulations and privacy policy of Medium Corporation (“Medium”). If you decide to subscribe to the Blog or to the comments of Partisia, you have to open an account with Medium subject to their terms and conditions. When using features of the Blog, (e.g., the comment section, social media features, buttons to share or like parts of comments or blog contributions), certain Personal Data (incl. Cookies) or information about you may be collected by Medium and/or other third parties. Any Personal Data or information collected by Medium and/or third parties is subject to such third party’s privacy policy. We encourage you to carefully review such third-party privacy policies.
Further information about the data privacy of Medium can be found here: https://policy.medium.com/medium-privacy-policy-f03bf92035c9.