vechain

Privacy
policy

PROTECTION OF PERSONAL DATA POLICY

In accordance with General Data Protection Regulation (EU Regulation 2016/679), Legislative Decree 06/30 /2003 n. 196 subsequent amendments and additions, Legislative Decree 101/2018 Directive 2009/136 / EC, implemented Legislative Decree of 05/28/2012 n. 69 (Italy), Law 171/2018 Republic San Marino.

Dear interested party, according to legislation indicated, our handlings will be based on the principles of correctness, lawfulness, transparency and protection of your privacy and your rights. Based on articles from no. 7 at no. 14 of GDPR 2016/679 we provide you thus with the following information.

By implementing the registration procedure, users voluntarily communicate to the company VeChain Foundation S.r.l., Data Controller, those data are mandatory to register for the services:

Furthermore, if inserted into the service by the user, the following data will also be saved:

CATEGORY

SOURCE

Identifiers (such as contact information or personal characteristics like name, email address or postal address, or social media handles)

You; our social media pages

Protected Classifications and Other Sensitive Data (such as date of birth or gender)

You

Commercial Information (such as transaction information, billing and payment records, or order history)

You

Internet or Electronic Network Activity Information (such as IP address, device identifier (e.g. Mac), cookie or tracking pixel information, browsing or search history, or diagnostic information)

You

Content of Communications (such as contents of phone calls, emails, text messages, or photos)

You

We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation

The user’s personal data sent by the users themselves through the registration procedures to our services will be processed in compliance with the principles of personal data protection established by the rules in the introduction to this policy;

The transfer of data is voluntary and not compulsory; however the insertion of some data is essential in order to allow registration to our services; failure to enter such data will prevent correct registration on the site and prevent the possibility of using the services of the portal reserved for registered users.

1) Personal data collected with this registration are processed in order to allow access to services provided by the portal and reserved for registered users.

2) Only in the event that the user has freely and unequivocally expressed his consent at the time of activating the service or they will express it subsequently and until its withdrawal, his personal data may be processed by VeChain Fondation S.r.l. to send advertising and commercial communications on their products and services.

3) Only in the event that user has freely and unequivocally expressed his consent at the time of activating the service or they will express it subsequently and until its withdrawal, their personal data may be processed by third-party companies, even with automated modes, for direct sales purposes, as well as to send market research and surveys.

4) Furthermore, in the event that user gives their consent freely and unequivocally, personal data may also be processed by VeChain Fondation S.r.l. for identify, even with electronic processing, specific consumer behavior and habits in order to improve the services provided and to direct commercial proposals of interest to the User and to offer third party advertisers the opportunity to optimize advertising campaigns.

5) VeChain Fondation S.r.l. reserves itself possibility to process aforementioned data in aggregate form, ensuring data pseudonymisation, in compliance with measures prescribed by the Guarantor for Data Protection and by virtue of specific exemption from consent provided by same Authority, for analysis and electronic processing (e.g. classification of all customers in homogeneous categories for levels of services, consumption, expenditure, etc.) aimed at periodically monitoring development and economic trend of VeChain Fondation S.r.l.‘s activities, to steer the relative industrial and commercial processes, improve services, design and implement commercial communication campaigns.

The personal data sent through registration procedures to our services are processed by VeChain Fondation S.r.l. with automated tools, for period of time which is strictly necessary to achieve purposes for which they were collected.

Specific security measures are observed by Data controller to prevent data loss, illegal or incorrect use and unauthorized access.

Personal data are recorded and stored on electronic databases owned by VeChain Fondation S.r.l. Data controller, as well as being stored on servers in territory of countries belonging to European Union (EU) or extra EU in compliance with legislation on protection personal data. Personal data are processed by VeChain Fondation S.r.l. by those appointed to manage its site and its marketing activities where consent is expressed.

The list of all data processors is available at request of site’s users.

TRANSFER OF DATA IN NON-EU COUNTRIES: data can be transferred to non-EU countries to a third party SUPPLIER only for purposes indicated above and in full compliance with handling expressed by the user. VeChain Fondation S.r.l. is based in a non-EU country as indicated in personal data site.

In order to safeguard right that the European Union considers fundamental, the data collected within European territory must be transferred to international organizations or non-EU countries according strict rules established by Chapter V Regulation: transfer must take place in compliance with principles underlying correct treatment and where there are sufficient and adequate guarantees to protect all concerned.

Data Controller VeChain Fondation S.r.l. guarantees, based on articles from n. 46 at no. 49 EU Regulation 2016/679, any transfer to a SUPPLIER Third party residing outside EU will take place in compliance with these rules and it will always and only concern those data relating to users who have explicitly consented to this transfer and will be processed in such a way as to guarantee adequate security according principles integrity and confidentiality. It will always be possible to withdraw such consent as required by art. 13 GDPR.

The user can exercise, at any time, rights referred to in art. 17 Law 171/2018 San Marino and Right to be forgotten in accordance with art. 17 EU Regulation 2016/679, including:

– right to access their data;

– right to obtain their data;

– right to withdraw or modify consent in accordance with art. 6 par. 1 GDPR 2016/679 if there is no other legal basis for the handling;

– right to object to the handling based on art. 21 GDPR 2016/679 for direct marketing purposes and/or to the handling with scientific, historical or statistical purposes in accordance with art. 89 par. 1 if their reasons are related to their particular condition.

– right to obtain the cancellation without undue delay if the data are no longer necessary with respect to the purposes for which they were collected, if data have been processed unlawfully, if their cancellation serves to fulfill a legal obligation of EU or of the Member State to which data controller is a subject, if data concern minors under 16 years of age and there is no parental consent.

Right to oppose the processing of one’s own data for the purpose of sending advertising materials, direct sales and commercial communications and to request the updated list of data processors, can be obtained by writing 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.

Cookie
policy

WHAT ARE COOKIES AND HOW WE USE THEM

A cookie is a text file that is stored on computers, tablets, mobile phones and on any device used to browse the Internet, capable of storing the user’s browsing information and preferences. Cookies can be used, as will be seen further below, to make navigation easier and personalize your experience on our websites and at the same time to tell us which parts of our sites are visited most and help us evaluate the effectiveness of advertising. , allowing us to improve our communications and products.

While browsing we may collect information relating to traffic flow and visits to the pages of our website. Any information obtained through cookies will be processed and stored securely.

The purpose of using cookies is to personalize access to the website, optimizing navigation and operation of the site, improve our services and provide content and/or advertising relating to user preferences, analyzing browsing habits.

Cookies can be classified into:

– Session cookies: which are removed when the user closes the browser and which, therefore, have a limited duration for your visit;

– Permanent cookies: which remain on the device used to browse the Internet for a specific time. These cookies have typical expiration dates and, therefore, their duration varies depending on the cookie used.

– Proprietary cookies and third-party cookies: depending on whether they belong to the owner of the website or to a third party.

For our websites and other online services we use the following categories of cookies:

Proprietary cookies/Third party cookies

Strictly necessary (technical) cookies

These cookies are essential for the correct functioning of our websites and to use and/or improve the various functions and services requested.

Without these cookies it would not be possible to manage and remember, by way of example, user authentication, access to the reserved area of the website, the contents of the cart for online purchases, electronic invoicing, the creation of the process of purchasing an order.

Since technical cookies are essential for the correct functioning of a website, they can also be used without the prior consent of the user, without prejudice to the obligation to provide information pursuant to art. 13 of the RSM Privacy Law and EU Regulation 679/2016.

  • Data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any products you viewed through the Site; and
  • IP address; browser type and operating system; geolocation; any other unique numbers assigned to a device.

Data collected via these cookies are used for the purposes of:

  • analyzing trends;
  • administering the Website;
  • to count users who have visited our Site and collect other types of information including insights about visitors’ browsing habits on the Websites;
  • gathering demographic information about our user base as a whole;
  • to learn what parts of our Website are most popular and what kind of features and functionalities our visitors like to see;
  • to help us understand the type of marketing content that is most likely to appeal to our visitors and Customers; and

• to help us with the selection of future product and service lines, website design and to remember your preferences.

https://www.freshworks.co.uk/privacy-policy#:~:text=All%20the%20information%20these%20cookies,improve%20how%20the%20Website%20works.&text=These%20cookies%20remember%20choices%20you,of%20cookies%20on%20your%20device

https://www.freshworks.com/list-of-cookies/

WHO WE COLLECT PERSONAL DATA ABOUT

We collect, process and store Personal Data about the following people:

  • Website visitors: If you browse our Website or contact us via our Website (Contact Sales) we will collect, process and store your Personal Data in connection with your interaction with us and our Website.
  • Users of our Services: If you use our Services, whether it is through our Website or our Mobile Applications, we will process your Personal Data for certain data analytics purposes and in order to offer, deliver and improve our Services.
  • Visitors to our Offices: If you visit our office, we may process Personal Data about you that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer Personal Data when signing in as a guest. CCTV footage may also be collected for security purposes.
  • Recipients of marketing communications from us: If you are a potential lead or existing customer, we may process Personal Data about you in order to send you marketing communications.
  • Event attendees: If you register for, attend or take part in our events, webinars or contests hosted by us we will process Personal Data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other documents relating to the event.
  • Personnel that work for our Customers, partners and suppliers (including subcontractors and personnel who work for us as freelancers or contractors). If you (or your organization) are:
  • in receipt of services from us;
  • supply products or services to us; or
  • otherwise partner with us;

WITH WHOM DO WE SHARE PERSONAL DATA?

We may share the categories of Identifiers, Geolocation Information (coarse location only), and Internet or Electronic Network Activity Information as described above with advertising partners.

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.

We may disclose personal information that we collect or that you provide as described in this privacy notice:

  • To our affiliates, subsidiaries, and other Freshworks companies.
  • To the following categories of service providers who are bound by law and contractual obligations to keep your personal information confidential. Service providers may use information that we share with them only for the purposes for which we disclose it to them and as otherwise permitted by law.
  • Payroll services providers that assist us in calculating and disbursing your salary and other compensation.
  • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
  • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
  • Recruitment vendors that assist with the application process, including assessing candidate qualifications and providing the platform through which candidates submit their candidacy.
  • Analytics services, including entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers.
  • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
  • IT vendors, such as entities that assist with website design, hosting and maintenance; data and software storage; and network operation.
  • To other external parties when required by law or to protect Freshworks or other persons, as described in this privacy notice.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Freshworks’ assets or capital stock, whether as a going concern or as part of bankruptcy, liquidation or a similar proceeding, in which personal information held by Freshworks about our employees, workers and contractors is among the assets transferred. If this happens, the recipient of the personal information will continue to honor the promises made in this privacy notice, or else provide you notice of any changes.

We process Personal Data in the countries in which we are established, including the United States, the United Kingdom and the European Economic Area (“EEA”) and in other countries where third parties that we may use are based.

You may refer to the Freshworks Data Hosting page herefor more information about the locations in which the Hosted Data (i.e., that which we process as a Processor during the provision of our Services) is stored.

When processing your Personal Data, we may need to share it with other third parties (including other entities within our Group of Companies), as set out below. This list is non-exhaustive and there may be circumstances where we need to share Personal Data with other third parties:

  • With third parties assisting Freshworks in providing our Customers with the Service(s) (“Sub-Processors” listed here). Our Sub-Processors are given access to Customers’ Account and Service Data only as reasonably necessary to provide the Service(s) and will be subject to confidentiality obligations in their service agreements;
  • With third party service providers providing us with services, such as research and analytics, anti-spamming and anti-phishing services, marketing and data enrichment or for them to reach out to you on our behalf;
  • For Freshinbox users: with third parties to permit such third parties to provide services that help us to provide our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Services
  • With third party payment processors who process your credit card and other payment information for Freshworks but who are otherwise not permitted to store, retain or use such information;
  • With third party partners for the purpose of assisting us in onboarding you and providing any further support needed to use our Services;
  • With sponsors of contests for which you register;
  • With third-party service providers that are assisting us with the operation and administration of events. If we are running an event in partnership with other organizations, we will share your Personal Data with such organizations for use in relation to the event;
  • With third-party social media networks, advertising networks and websites;
  • With external recruiters, and related organizations such as third-party providers that undertake employee background checks on our behalf and on behalf of other entities within our Group of Companies;
  • With auditors, lawyers, accountants and other professional advisers who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in;
  • Law enforcement or other government and regulatory agencies and bodies or other third parties as required by, and in accordance with, applicable law or regulation;
  • With Affiliates within Freshworks and companies that we will acquire in the future when they are made part of the Freshworks group – this may be for customer support, marketing, technical operations, account management or organizational purposes and to provide, enhance and improve the Services;
  • If we are involved in a merger, reorganization or other fundamental corporate change with a third party, or sell/buy a business unit to/from a third party, or if all or a portion of our business, assets or stock are acquired by a third party, with such third party including at the due diligence stage;
  • Other third parties – Occasionally, we may receive requests from third parties with authority to obtain disclosure of Personal Data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for Personal Data where we are permitted to do so in accordance with applicable law or regulation.
  • When you connect your Gmail mailbox with your Freshworks Account (see section 14 (Google API Disclosure) below).

Where necessary (such as when we transfer data to service providers) we put in place appropriate contractual arrangements and security mechanisms to protect the Personal Data shared and to comply with our data protection, confidentiality and security standards and obligations. Further details can be provided upon request.

The Website and our Services are made available by various companies in the Freshworks group of companies (each a “Group Company”).

Where this Privacy Notice refers to “Freshworks”, “we”, “us, “our”, this means one or more of the particular Group Companies that provide the particular Website, Mobile Application, Newsletter or Services to you, recruits you, uses testimonials from you, sends marketing communications to you, hosts an event you visit, or organizes a program in which you participate.

For the purposes of the GDPR and LGPD, the following Group Companies act as a data controller when the processing of your Personal Data is governed by the requirements of the GDPR or LGPD.

Location: United States

Freshworks Inc. (company no: 4861858) is a company established under the laws of Delaware with its registered office at 16192 Coastal Highway, Lewes, Delaware 19958, USA and its principal business address can be found here.

Location: Germany

Freshworks GmbH

(company no: HRB 176669 B) is a company established under the laws of Germany and its registered office address can be found here.

Location: Netherlands

Freshworks Technologies B.V. (company no: 73582166) is a company established under the laws of the Netherlands and its registered office address can be found here.

Location: France

Freshworks SAS (company no: 842815581) is a company established under the laws of France and its registered office address can be found here.

Location: United Kingdom

Freshworks Technologies UK Limited (company no: 09338697) is a company established under the laws of England and Wales and its registered office address can be found here.

Location: India

Freshworks Technologies Private Limited (company no: U72200TN2010PTC078458) is a company established under the laws of India with its registered office at Module – 1 & 2, 1st Floor, Block B, No 40, Global Infocity Park, MGR Salai, Perungudi Chennai – 600096, Tamil Nadu, India here.

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