1. DATA CONTROLLER

The Data Controller is Vechain Foundation San Marino s.r.l, with registered office at Via Consiglio dei Sessanta, 99 – Dogana – Republic of San Marino.

2. PURPOSE AND LEGAL BASIS OF THE PROCESSING

Vechain processes your personal data for the following purposes:

a) Promotion and sale of products and services of Vechain, including the performance of market research (so-called direct marketing). The legal basis that legitimizes the consequent processing is your consent, which you are free to give or not and that you can, however, withdraw at any time. The provision of data necessary for these purposes is not mandatory and the refusal to provide them does not determine any negative consequences, except the inability to receive commercial communications.

b) Need to perform a contract, to which you are a party or to perform pre-contractual activities at your request, including, for example, your request to acquire a Vechain wallet or to enter in the community: this includes all those activities of acquiring information prior to the conclusion of a contract and sending information and updates on it. These needs represent the legal basis that legitimizes the consequent processing. The provision of the data necessary for these purposes represents, depending on the case, a contractual obligation or a necessary requirement for the conclusion of the contract; without them, Vechain may be unable to establish the relationship or to execute it.

3. CATEGORIES OF PERSONAL DATA PROCESSED

Vechain processes personal data collected directly from you, which include, by way of example, anagraphic data (e.g. first name, last name, cell phone number, e mail).

4. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

Your data may be processed:

• • by natural persons and legal entities as appointed data processors or autonomous data controllers, e.g. partners and affiliates as necessary, or also third-parties service providers who assist Vechain with the running of websites, data hosting, marketing and other IT services;
  • and/or by natural persons as persons authorized to process personal data (with respect to the data necessary for the performance of the tasks assigned to them) belonging to the following categories: workers employed by Vechain or seconded to it, temporary workers, interns,
    consultants and employees of the external companies appointed as data processors.

In addition, Vechain may disclose personal information about you if it is under a duty to disclose or share them in order to comply with any legal obligation or
lawful government or public authority request.

5. RIGHTS OF THE DATA SUBJECTS

Privacy Regulations grant to you as data subject specific rights, including the right to know what personal data is held by Vechain and how it is used (right of access), to obtain the updating, rectification or, if interested, integration of such data, as well as their erasure, transformation into anonymous form or limitation, etc.

6. PERIOD OF DATA STORAGE AND RIGHT TO ERASURE (i.e. RIGHT TO BE FORGOTTEN)

Vechain processes and keeps your personal data for longer than is necessary for the purposes for which they were collected and processed.
At the end of the applicable retention period, personal data relating to data subjects will be deleted or stored in a form that does not permit identification of the data subject (e.g., irreversible anonymization), and will be retained in a form that does not permit identification, unless their further processing is necessary for one or more of the following purposes: i) resolution of pre-litigation and/or litigation initiated before the expiry of the retention period; ii) to follow up investigations/inspections by internal control functions and/or external authorities initiated before the expiry of the retention period; iii) to follow up requests
from San Marino and/or foreign public authorities received/notified to Vechain before the expiry of the retention period.

7. METHODS OF EXERCISING RIGHTS

In order to exercise the rights set forth in paragraphs 5 and 6, you may apply to: VeChain Fondation S.r.l. Data Controller for San Marino info-sanmarino@vechain.org, Via Consiglio dei Sessanta, 99 – Dogana – Republic of San Marino.
The deadline for the reply is one (1) month, which may be extended by two (2) months in particularly complex cases; in these cases, the Controller will provide
at least one interim communication within one (1) month. The exercise of the rights is, in principle, free of charge; the Controller reserves the right to charge a
fee in the event of manifestly unfounded or excessive requests (including repetitive ones).

8. COMPLAINT OR REPORT TO THE PERSONAL DATA PROTECTION AUTHORITY

Vechain informs you that you have the right to file a complaint or a report to the San Marino Data Protection Authority or alternatively to appeal to the judicial authority.

This information notice was updated on October 2023