Privacy Policy


Roadshow Data Protection Regulations – weeNexx AG

1. What is it about?

weeNexx AG processes personal data according to the regulations of the European General Data Protection Regulation (GDPR), the Swiss Federal Data Protection Act (DPA) and all other applicable legal data protection regulations.

This data protection statement serves to inform you that weeNexx AG is compliant with the relevant regulations and to educate you on the ways in which you can assert your rights according to the relevant data protection laws.

 

2. Who is the data controller?

Within the scope of the Roadshow Family & Friends Private Presales (‘event’), weeNexx AG, Burgstrasse 8, CH- 8280 Kreuzlingen (hereinafter also referred to as ‘weeNexx’, ‘we’, ‘us’) is selling options on weeTokens in the period between November and December 2018.

This data protection statement applies to the processing of personal data by us of persons participating in the event (‘participants’) in conjunction with

a.)   the events in question and

b.)   the sale of options on weeTokens.

Within the context of the Roadshow, the data controller, pursuant to the EU General Data Protection Regulations (‘GDPR’), is weeNexx AG.

 

3. What personal data is processed for what purpose and on what legal basis?

 

Personal data is information that relates to an identified or an identifiable person. This includes information that allows conclusions to be drawn as to your identity, such as your name, your telephone number, your address or your email address. Statistical data which we collect when you visit our website, for example, that is not directly related to your identity is not covered by the term personal data.

a.       Using the websites registration.weenexx.io and www.weecoin.io for informational purposes

Unless otherwise stipulated within the remainder of this data protection statement, we do not collect personal data if our website is being used for purely informational purposes, i.e. when participants are not actively providing data via the website, with the exception of data that is automatically provided by the browser of the participant in order to access the website. This includes e.g.:

 

-  the IP address of the requesting device;

-  date and time of access;

-  relevant transmitted data volume;

-  addresses of the visited website and the requesting website;

-  Information regarding the type of browser used and the operating system of the display device.

 

We are fundamentally not able to assign this data to a particular person. The only purpose of the aforementioned processing of data is to allow access to the website (establishing a connection).

 

Additional information on data processing in relation to the website can be found under figure 3.

 

b.       Data provided during registration and in the shop

aa. In order for you to be able to take part in the Roadshow, we ask that you provide us with the following personal data during the registration process: Gender, title, company, first name, last name, street, house number, post code, city, country, email address, telephone number, date of birth, place of birth, nationality.

bb. If you would like to be able to bid on WIT Token options, you are asked to disclose additional personal data at shop.weecoin.io for identification purposes (copy of passport) and a password.

 

The processing of data takes place so that we may (aa) provide services relating to the fulfilment of our contracts with event participants, and (bb) implement pre-contractual measures pertaining to a bid (e.g. identification of event participants and subsequent identity checks (KYC) with regard to WIT Token purchases/ orders).

The purpose of the data processing is predominantly related to the processing of bids on WIT Token options that have been placed with weeNexx AG via the Token Options Shop (shop.weecoin.io).

 

c. Processing in order to comply with a legal obligation

 

We have to comply with various legal obligations (e.g. The Anti-Money Laundering Act, tax legislation etc.). Data processing can be used to verify both your identity and your age, to prevent fraud and money laundering, to comply with tax-law-related control obligations and to navigate risks within weeNexx AG and its affiliated companies.

 

 

d.       Consent; Newsletter

If a participant has consented to receiving newsletters or comparable marketing information, for examplye, then we use the data that corresponds with said consent (e.g. the email address in order to send the newsletter), in order to supply the participant with the relevant information.

 

The relevant consent can be revoked with future effect at any time.

 

If a participant subscribes to a newsletter via the website, then they will receive a confirmation / authorisation email from us, which asks him to click the link contained in the email, thus confirming that they are in fact giving their consent to receiving the email. The participant will only receive the relevant newsletter once they have sent the confirmation. Once they have confirmed their email address, we save said email address, the time of registration and the IP address, which was used to register, until the time at which they cancel their subscription to the newsletter. The sole purpose of saving this data, is so that we can send the newsletter to the participants and verify their registration. The participant can cancel their subscription to the newsletter at any time. A relevant cancellation link is included in every newsletter. Sending a message via the contact details disclosed at the top or in the body of the newsletter (e.g. an email or letter) will, of course, also suffice. We only send newsletters in order to market our own products or services.

 

We use industry-standard technologies in our newsletters which can measure the interactions with the newsletter (e.g. opening the email, clicking on links). This data is used in its anonymised form for general statistical evaluations as well as optimising and developing our content and communications. This occurs with the help of small graphics, which are embedded in the newsletter (so-called pixels). The data is only collected anonymously and is also not connected to your additional personal data. The legal basis for this is our aforementioned, justifiable interest acc. to Art. 6 Para. 1 no. f GDPR. By means of our newsletters, we are looking to provide the participants with as relevant information as possible, whilst improving our understanding of what interests our readers. If you would like to opt out of this usage behaviour analysis, you can cancel the subscription to the newsletter or disable graphics by default in your email program.

 

 

e. Legal bases

          Legal basis for the processing (and transmitting) of personal data is based on

         

-       Figure 2.a (provided it relates to personal data) Art. 6 Para. 1 p. 1 no. f GDPR (legitimate interest; the legitimate interest results from the purpose as stated in figure 2.a);

 

-       Figure 2.b Art. 6 Para. 1 p. 1 no. b) GDPR (performance of a contract or pre-contractual measures);

 

-       Figure 2.c Art. 6 Para. 1 p. 1 no. c) GDPR (compliance with a legal obligation);

 

-       Figure 2.d Art. 6 Para. 1 p. 1 no. b) GDPR (giving consent);

 

 

4.  Are cookies and other tools used in conjunction with the services?

 

a.     Cookies

We use cookies on the website. Cookies are small text files that are saved in the browser memory for session management purposes. When accessing individual pages of the website, we use what are known as cookies to facilitate navigation. Fundamentally, these cookies expire once the session has finished.

 

It is possible to configure the browser in such a way, that no cookies are saved or that a notification appears before a new cookie is saved. However, disabling cookies can mean that it is no longer possible to (fully) use all functions of our website.

Legal basis for the processing of personal data, as described in figure 3.a (provided it concerns personal data in the first place), is Art. 6 Para. 1 p. 1 no. f GDPR (legitimate interest; the legitimate interest follows the aforementioned purpose (in particular the optimisation of the use of the website and the improvement of the user experience).)

 

b.    Google Analytics

 

The website uses Google Analytics, a web analysis service of Google Inc. (‘Google’). Google Analytics uses what are known as ‘cookies’, i.e. small pieces of data, that are saved on your computer and make it possible for us to analyse your use of our site. The information on your use of the website, as generated by the cookie, is usually sent to a Google server in the USA, where it is then saved. However, if the anonymisation of the IP address has been activated for the website, then Google will shorten your IP address within the European Union or other States party to the Agreement on the European Economic Area. Only in rare cases, the IP address will be transmitted to a Google server in full before being shortened there. Google will use this information to evaluate your use of the website, compile reports on the website activity, and in order to provide the website operator with additional services related to the website and internet use, on behalf of the website operator. The IP address that is transmitted from your browser within the scope of Google Analytics is not collated with other data from Google.

This website uses IP anonymisation in the aforementioned sense.

You can disable cookies using the relevant settings in your browser. We would like to make you aware that this may stop you from taking full advantage of all functions of the website. In addition, you can prevent the data that is generated by the cookie and is related to your use of the website (incl. your IP address) from being sent to Google and prevent Google from processing said data by downloading the browser plug-in via the following link and installing it: http://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser plug-in or if you are using a browser on a mobile device, please click on the following link to access an ‘opt-out’ cookie which will disable Google Analytics on the website in the future (this opt-out cookie is only active in this browser, and for this website. If you delete your cookies in your browser, you will have to click the link again):

Click here to be excluded from the Google Analytics evaluation process.

 

Further information on Google Analytics can be found here:

http://www.google.com/analytics/terms/de.html,  http://www.google.com/intl/de/analytics/learn/privacy.html,  http://www.google.de/intl/de/policies/privacy/

and at Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA.

To our knowledge, Google has committed to adhering to the EU-US Privacy Shield as published by the United States Department of Commerce, regarding the regulation of the collection, use and storage of personal data from member states of the EU. Google has certified that it will comply with the relevant Privacy Shield principles. The EU Commission trusts that the USA will ensure an appropriate level of protection of personal data, which is transferred to Privacy Shield-certified organisations within the USA from the EU. More information via the links below: https://www.privacyshield.gov/EU-US-Framework.

 

5. Is the personal data of participants shared with third parties?

We fundamentally do not share personal data of participants with third parties, unless otherwise stipulated within this data protection statement.

If necessary, we transmit (a limited amount of) data of participants to our affiliated companies within the wee Group, so that these companies may help us finalise and manage the relevant purchase agreements with the participants of the Roadshow. Legal basis for this processing of personal data is Art. 6 Para. 1 p. 1 no. f GDPR (legitimate interest, the legitimate interest follows the aforementioned purpose) and Art. 6 Para. 1 P. 1 no. b) GDPR (performance of a contract or pre-contractual measures).

We also employ (technical) service providers to process personal data on our account, if necessary (e.g. IT service providers). These service providers process the relevant personal data exclusively upon our instructions (processor). Legal basis for this type of data processing is Art. 28 GDPR (contract processing) and usually Art. 6 Para. 1 p. 1 no. b GDPR (Performance of a contract or pre-contractual measures).

If necessary, we transmit personal data of participants to third parties if we are legally obligated to do so (e.g. if requested by a court or a law enforcement agency). Legal basis for this type of data processing is Art. 6 Para. 1 sentence 1 no. c GDPR (legal obligation).

 

6. How long will the personal data of participants be saved?

Provided no other storage period is stipulated within this data protection statement, we save personal data of participants, as received during the event participation registration process, for the duration of the contractual relationship with the relevant participant and thereafter only to the extent and inasmuch as we are obligated to do so by legal record-keeping regulations. Should we no longer require the relevant participant’s data for the aforementioned purposes, then it will be saved for the duration of the retention period and not used for other purposes.

 

7. What are the rights of the participant?

Participants reserve the right to ask us for information regarding their personal data that we have saved at any time. Provided the legal requirements are fulfilled, participants shall also have the right to rectification, deletion and restriction of the processing of the relevant personal data, the right to object to the processing of their personal data by us, and the right to receive personal data they provided to us in a structured, commonly used and machine-readable format (participants may transfer this data or have this data transferred to other bodies).

 

If participants consent to the use of personal data, they can revoke this authorisation at any time for the future.

 

If participants are of the opinion that the processing of their personal data by us is in violation of the relevant data protection regulations, they can complain to the relevant regulatory body for data protection.

 

 

 

Information on your right to object pursuant to article 21 GDPR

 

You have the right to object to the processing of personal data, on grounds relating to your particular situation. Provided the processing is necessary for reasons of public interest or occur on the basis of a balancing of interests. In case of an objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. Or your personal data is being used for the establishment, exercise or defence of legal claims.

 

 

8. How can I get in touch? Whom do I contact?

Participants can contact us via the address listed under figure 1, and at [email protected] or by calling 071 688 86 63.

 

For any queries relating to data protection (including exercising rights according to figure 6) participants can contact our data protection officer directly. The contact details of the data protection officer are: Dipl.-Inform. Udo Wenzel, [email protected].

 

 

9. Amendments to this data protection statement

We may, occasionally, update this data protection statement, for example in case of a website update or should the legal or official regulations change.

 

 

10. What are we doing to protect participants’ personal data (from being accessed by third parties)?

We maintain up-to-date technical measures to ensure data security, in particular for the protection of the personal data of participants against dangers resulting from data transmissions and against third parties accessing said information. These are regularly updated to the latest state of the art.

 

 

Version: November 2018