This privacy policy (“Privacy Policy”) provides an extensive insight into how Aragon X AG (“Aragon”, the “Company”, “We”, “us”, “our”) and all platforms affiliated with Aragon, including but not limited to the Aragon websites, all their subdomains and affiliated applications [www.app.aragon.orgwww.aragon.org; www.mainnet.aragon.org; forum.aragon.org;wiki.aragon.org; anj.aragon.org; transparency.aragon.org; conviction.aragon.org, vocdoni.app], its application [client.aragon.org], Twitter [twitter.com/AragonProject], Reddit [reddit.com/r/aragonproject/], Telegram [t.me/aragonproject] and Discord [https://discord.gg/aragonorg] (collectively “Platforms”) collect, share or use data about you (“user(s)”, “You”, “Yours”, “Data Subject”) in connection with the Platforms whose personal data is collected by us when You act as user of our Platforms or provide us Your information as explained below.
This Privacy Policy is based on the Swiss Federal Act on Data Protection (“Data Protection Act” or “FADP”) of 25 September 2020 (Status as of 1 September 2023) as amended.
The Company is authorized to process personal data pursuant to those laws and regulations and by the Swiss Federal Data Protection and Information Commissioner.
Under the FADP personal data is defined as “all information relating to an identified or identifiable individual”.Under the FADP a data controller is the private person or federal body that decides on the purpose and content of a data file. Aragon is the data controller as defined by FADP (the “Data Controller”).
This Privacy Policy, together with our Terms of Use (“Terms”) [https://aragon.org/terms-and-conditions] governs the collection and processing of Your personal data and is applicable to all the information collected through the Platforms, upon the use of such Platforms, any related services, marketing, events and/or any other locations that are in any way linked to this Privacy Policy (collectively, the “Services”).
Please read this Privacy Policy and our Terms carefully. By accessing our Platforms, You are consenting to the information collection and use practices described in this Privacy Policy. If You do not agree to this Privacy Policy, You should immediately cease to continue the use of the Services.
1. COLLECTION OF INFORMATION 1.1. What information is collected? - When You use our Services, our servers may automatically log technical data provided by the browser in use and may include but is not limited to, Internet Protocol (IP) address, browser type and version, geolocation data, username, email, crypto wallet addresses, voting history, metadata, and DAO addresses You subscribe to. - When you access our Platforms you can choose to subscribe to our newsletter. In this case, we will collect your email address. - In certain cases, Your consent to use personal data may be required, which may be withdrawn at any time, by reaching out to us via the contact details provided in this Privacy Policy or our Platforms. We shall get in touch with You every time consent to process any data is required. - We may need to collect and process additional personal data in order to provide the Services, perform any contractual obligations, or form any/all legal compliance. In such cases, we shall get in contact with You. - We may also collect data, including but not limited to, data from Aragon Forum, Rocketchat (email, chat conversations, cookies), Helpscout (email, browser fingerprint, IP address), Aragon Client notification system (using third party service providers), Zoho and Google. To provide the Services we may collect the following information: - the time and date of Your visit; - domain name; - operating system; - Your computer or mobile used to access our services; - browser version number; - search terms entered on the Platforms; - pages and links used to access the Platforms; - the pages of our Platforms that You access; - IP Address; - the content viewed and features accessed on our Platforms; - metadata and events related to smart contracts; - the web pages and the search terms entered on Aragon websites; and - Surveys/Forms, Surveymonkey, Earn.com, Typeform, Gmail, Mailchimp and Keybase or any other similar third party applications.
1.2. How is personal data collected? We process personal data that the user provides directly through various channels: - signing up at any of the Platforms: when You register at any Platform, sign up for news, events or newsletters, obtain our Services from Aragon, contact us with any queries or respond to our communications; - there are several ways in which we collect Your personal data directly from You: (i) that You provide to us; (ii) that You made public. - we also automatically collect information from Your computer or mobile device when You browse through our Platforms; and - we may use third-party service providers which may receive or independently obtain Your personal data from publicly available sources. For these purposes, we may share the information collected with blockchain analytics providers. We share information with these service providers only so that they can help us promote the safety, security, and integrity of the Platforms.
2. USE OF INFORMATION 2.1. We may use the personal data collected for the following purposes:
- providing Services to You; - marketing and business activities in relation to our Services, including but not limited to newsletters sending, updates, marketing communications and other information that may be of interest to You. We shall ask your express consent for this; - complying with legal and regulatory obligations such as FADP or AML/CTF regulations; - exercising or defending any legal rights; - monitoring the use of Platforms and operating it only for business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports, customer support and marketing; - for legitimate business interests, such as business research services and analysis, managing our Platforms and Services; - looking into any complaints or queries; - preventing and responding to actual or potential fraud or illegal activities; - reviewing and processing any job application in case any user has applied for a job position; - cookies used are strictly necessary for the smooth functioning of the Platforms and Services; and - operating, managing and improving the Services; performing the Services requested by You such as responding to Your comments, questions, and requests, and providing information support; sending You technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; detecting, preventing, and addressing fraud, breach of Terms, threats, or harm; compliance with legal and regulatory requirements, and more generally protecting the security and integrity of the Services. 2.2. Other information, such as, for example, information concerning the use of the Services (in particular: IP address of the user's device, unique identifiers of the user's mobile device, services used, links and messages activated, etc.) is analyzed, in an automated and anonymized manner, exclusively to evaluate the introduction of new features, to improve the quality of the Services offered and to optimize the usability of the Services. We do not process, or broadcast content or advertisements designed based on online behavior, profile users, or monitor the use of web resources or e-mail. We do not sell, rent, trade, and/or lend personal data to third parties. 2.3. For suppliers receiving funds from us, we may use the data included in the supplier registration form (“Supplier Registration Form”). 3. SHARING AND DISCLOSURE OF INFORMATION 3.1. We share personal data and other information with our affiliates and third-party service providers that assist us in providing Services. This may include, but is not limited to, sharing information with third-party contractors, bound by obligations of confidentiality, in connection with the processing of Your personal data for the purposes described in this Privacy Policy, such as but not limited to, information technology and communications (ITC) service providers, third parties relevant to the Services that we provide including regulators, authorities and governmental institutions. 3.2. Data may be transferred to third party providers and processed by them out of the European Economic Area (“EEA”) and the United Kingdom (“UK”). However, Aragon has been instructed and stipulated data processing agreements with such third party providers based out of the EEA. If we send personal data to a country that does not have appropriate data protection legislation, nor is deemed as an adequate country under the adequacy rating of Switzerland or the European Commission, we will ensure an appropriate level of protection by employing contracts accordingly, or we will act on the basis of the following statutory requirements, consent, performance of the contract, execution or enforcement of legal claims, in accordance with the requirements imposed by FADP. We may also use the binding corporate rules, standard contractual clauses or ad hoc contractual clauses that stipulate that the data will be processed in accordance with the FADP. At any time, You have the right to request information about the contractual guarantees mentioned. However, we reserve the right to censor copies, or to supply them only in part to protect the privacy of any third parties mentioned or to protect our confidentiality duty. 3.3. You acknowledge that the information included in the Supplier Registration Form may be disclosed at any time as it is a public information, thus freely accessible to the public. We believe that this does not preclude the exercise of Your rights under this Privacy Policy and any data privacy laws and regulations applicable to You. 3.4. Payment for the Services provided may be executed throughout the blockchain, and You acknowledge that the information included in the Supplier Registration Form will be registered and public, without any technical possibility of reversing this process or eliminating the data if no special request for anonymization or exclusion of the data is made previously.
4. SECURITY AND STORAGE OF PERSONAL DATA
4.1.We ensure that Your personal data is collected by us is subject to appropriate security measures.
4.2. We may share personal data for audits and legal compliances with our professional advisors.
4.3. Personal data and other information stored by us is shared with public officials for legal compliance enforcement and security concerns.
4.4. We store Your personal data in accordance with our internal data retention policy. This policy is reviewed and updated internally to ensure we do not store Your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely. We process and store Your personal data to the extent that it is required to fulfil our contractual and legal obligations or for the purposes pursued by the processing, which means, for example, for the entire duration of the business relationship (from the initiation and performance of a contract to its conclusion) and beyond that in accordance with legal obligations for storage and documentation. In any case we store Your personal data for a period equal to 10 years after the provision of our Services, except in cases where storage for a later period is necessary (e.g. for possible litigation, requests of the competent authorities or pursuant to the applicable legislation). Only with respect to commercial communication via e-mail and marketing operation Your personal data could be stored for more than 10 years, if You do not wish to have Your personal data used by us to promote or market our Services to You, at any time You can opt-out by clicking the “unsubscribe” link on any e-mail You receive from us or by writing us at privacy@aragon.org.
4.5. We may share Your information with You with Your consent at Your request or direction.
4.6. Notwithstanding the above, we may share other information that does not identify You (including information that has been aggregated or de-identified) except as prohibited by applicable law.
5. USE OF COOKIES
5.1.Cookies could be sent to Your device. Tracking Technologies such as beacons, tags, and scripts are used to collect and track information and to improve and analyses our Services.
5.2. We may use and integrate third-party applications with our Platforms to improve the user experience. Cookies by such a third party may be placed on Your browsing device, and they can be managed by checking the third party’s website for more information about cookie management and how to "opt-out" of receiving cookies from them.
5.3. You may instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some portions of our Services.
6. DATA PROTECTION RIGHTS
6.1. You are entitled to a certain number of legal rights concerning the personal data we may hold about You. These rights can be exercised at any time by contacting us.
6.2.The following rights apply regarding the collection of Your personal data:
- Right to Access: You have the right to access Your personal data stored with us, how we use it, and who we share it with.
- Right of Portability: You have the right to receive a copy of all Your personal data stored by us in a structured, commonly used and machine-readable format and/or request transfer of the same to a third party, in certain circumstances and with certain exceptions.
- Right to Rectification: You have the right to correct any inaccurate personal data.
- Right to Erasure: in certain circumstances, You have the right to delete Your personal data stored with us. There may be circumstances where You ask us to erase personal data, but we are legally entitled to retain it; in such circumstances, the same shall not be erased.
- Right to restrict processing: You have the right to require us to stop processing the personal data we hold about You, other than for storage purposes, in certain circumstances.
- Right to Objection: You have the right to object to our processing of Your personal data. There may be circumstances where You object to or asks us to restrict the processing of personal data, but we are legally entitled to refuse that request.
- Objection to marketing: You can object to marketing at any time by opting out using the unsubscribe/opt-out function displayed in our communications to You.
- Withdrawal of consent: where we rely on consent to process Your personal data, You have the right to withdraw this consent at any time In certain circumstances it may be lawful for us to continue processing without consent if we have a legitimate reason (other than consent) for doing so.
- Right to lodge a complaint: You are entitled to lodge a complaint with a supervisory authority in the country (or in the member state if you are an EU citizen) where you have your habitual residence, where you work, or where the alleged infringement has occurred. This is without prejudice to any other administrative or judicial remedy (see section 7 for further information).The aforementioned rights are not absolute and may be limited by law.
6.3. If you wish to exercise the above-mentioned rights with regard to the protection of personal data you may address, at any time and free of charge, to us by sending an e-mail at the following address: privacy@aragon.org. When you contact us, please remember to include your name, e-mail address, postal address, and/or telephone number so that your request can be handled correctly.
7. REQUESTS AND COMPLAINTS
7.1. If You have complaints about how we process Your personal data, please contact us at privacy@aragon.org and we will respond to Your request as soon as possible.
7.2. As anticipated in section 6 of this Privacy Policy, if You think we have infringed data protection laws, You may file a claim with the data protection supervisory authority in Switzerland or within the EEA country of Your residence.
7.4. For further information on the collection, use, disclosure, transfer or processing of personal data or the exercise of any of the rights listed above, please contact Aragon by sending an email to privacy@aragon.org. 8. DISCLAIMER
8.1. Our data of any kind are never binding. We reserve the right to change or update the information on our websites at any time without notice. Aragon is not responsible for internet malfunctions, damage caused by third parties, data imports of any kind (viruses, worms, Trojan horses) nor for links from or other sites on the Web. We have no control over the content and form of external websites. We cannot guarantee the flawless operation of hardware and software. In no event shall our company be liable to You or any third party for any direct, indirect, special, or consequential damages of any kind whatsoever resulting from the use of our Platforms, or another website linked to it. Any liability for loss of income, business interruption, loss of programs or other data in Your computer systems is also excluded.
8.2. The transmission of communications, documents and other information by e-mail is considered less reliable, secure and confidential than by letter or fax. Against viruses and spam, we employ modern identification technologies. However, we recommend that You also employ a virus scanner, and we disclaim any liability for any damage resulting from e-mails or loss thereof. We reserve the right to reject e-mails with potentially dangerous attachments. In principle by visiting our Platforms You do not leave any personal data behind. However, in some cases we need Your name and address. For our part we are committed to protecting the confidentiality of Your personal data. On this site we make available to You through links (links) contents or services of other websites. Such other sites are not subject to our data protection guidelines. We recommend that You check each such site and ascertain how Your data is protected.
9. CHANGES TO THE PRIVACY POLICY
9.1. The Company reserves the right to vary this Privacy Policy from time to time. Such variations become effective when they are published on our websites. Your subsequent use of our websites or submission of personal data to Aragon will be deemed to signify Your acceptance to the Privacy Policy and its variations.
