Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Nevermined AG, Industriestrasse 47, 6300 Zug, Switzerland.
For the purpose of the GDPR, the Company is the Data Controller.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Switzerland.
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Nevermined, accessible from www.nevermined.io.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can 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 parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies: Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read here.
Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to count users who have visited those pages or opened an email and for other related website statistics (e.g., recording the popularity of a section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as push notifications from mobile applications regarding updates or informative communications related to functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that You have already purchased or enquired about, unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing, and Your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions: If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other legal requirements: The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data: The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR: We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR: The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data: The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data: You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data: This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data: You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data: We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent: You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Children's Privacy: Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites: Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy: We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

By email: dataprivacy@nevermined.io

Privacy Policy Declaration

I. Name and Address of the Data Controller:

The data controller within the meaning of the EU General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:

Nevermined AG
Industriestrasse 47
6300 Zug, Switzerland
info@nevermined.io
www.nevermined.io

II. Name and Address of the Data Protection Officer:

The data protection officer of the data controller is:

A. Argomaniz
Nevermined AG
Industriestrasse 47
6300 Zug, Switzerland
dataprivacy@nevermined.io
www.nevermined.io

III. General Information on Data Processing

1. Scope of the Processing of Personal Data

The protection of your personal data is important to us. We only process personal data of our users if this is necessary to provide a functioning website as well as our contents and services. The processing of your personal data takes place usually only after your consent. An exception applies in those cases where prior consent cannot be obtained for factual reasons and processing of the data is permitted by law.

2. Legal Basis for the Processing of Personal Data

Insofar as we obtain the consent of the data subject for the processing of personal data, art. 6(1)(a) GDPR serves as the legal basis.
In the processing of personal data required for the performance of a contract to which the data subject is a party, art. 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
Insofar as the processing of personal data is required to fulfill a legal obligation to which our company is subject, art. 6(1)(c) GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, art. 6(1)(f) GDPR serves as the legal basis for processing.

3. Data Erasure and Storage Time

The personal data of the person concerned will be deleted or blocked as soon as the purpose of storage is no longer valid. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the data controller is subject. The data will also be blocked or deleted 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 fulfillment of a contract.

IV. Provision of the Website and Creation of Log Files

1. Scope, Purpose and Legal Basis of Data Processing

Every time you visit our website, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

Information about the browser type and version used
The user's operating system
The Internet service provider of the user
The IP address of the user
Date and time of access
Websites from which the user's system reaches our website
Websites accessed by the user's system via our website

The data is also stored in the log files of our system. This data is not stored together with other of your personal data. The legal basis for the temporary storage of data and log files is art. 6(1)(f) GDPR. The 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.

2. Duration of Storage, Possibility of Objection and Deletion

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on your part.

V. Use of Cookies

1. Scope, Purpose and Legal Basis of Data Processing

Cookies are small text files that are stored on your device with the help of your browser. The cookies do not damage your device.

Technically necessary cookies:

We use cookies to make our website user-friendly. Some functions of our website cannot be offered without the use of cookies. For this it is necessary that the browser is recognized even after a page change. Some cookies therefore remain stored on your device until you delete them. Your data collected by technically necessary cookies are not used to create user profiles.

The following data is stored and transmitted in the cookies:

Language settings
Log-in information

The legal basis for the processing of personal data using cookies is art. 6(1)(f) GDPR.

Technically unnecessary cookies:

We also use cookies on our website which enable an analysis of your surfing behavior. These cookies are used to improve the quality of our website and its content. Through such cookies we learn how the website is used and can thus continuously optimize our offer.

In this way, the following data can be transmitted:

Entered search terms
Frequency of page views
Use of website functions

When accessing our website, you are informed about the use of cookies for analytical purposes and your consent to the processing of personal data used in this context is obtained. In this context, reference is also made to this data protection declaration. The legal basis for the processing of personal data using cookies for analytical purposes is, with your consent, art. 6(1)(a) GDPR.

Third-party Cookies:

We also use cookies from third party companies with whom we cooperate for the purpose of advertising, analysis or the functionalities of our Internet presence. Please refer to Section VIII. Web Analysis for details, in particular for the purposes and the legal basis of the processing of such third-party cookies. When you visit our website, you will be informed about the use of third-party cookies and your consent to the processing of personal data used in this context will be obtained. In this context, reference is also made to this data protection declaration.

2. Duration of Operation, Storage, Possibility of Objection and Deletion

Cookies are stored on your computer and transmitted to our site. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

The permanent cookies we hold on our servers have an expiry date of 12 months. This is in compliance with the GDPR on Cookies meaning that any log-in or contact information our Cookie files hold are automatically deleted after 12 months.

VI. Social Media Plugins (using the Shariff solution)

On our website social plugins of social networks ("plugins") are used. In order to increase the protection of your data when visiting our website, the plugins are not unrestricted, but only integrated into the page using an HTML link (so-called "Shariff solution"). This integration ensures that no connection is established with the servers of the provider of the respective social network when a page of our website containing such plug-ins is called up.

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. 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 relevant rights and setting options for the protection of your privacy can be found in the data protection information of the providers:

VII. Contact Form

1. Scope, Purpose and Legal Basis of Data Processing

There is a contact form on our website which can be used for electronic contact. If you take advantage of this possibility, the data entered in the entry mask will be transmitted to us and stored. This data is:

Name
Email
Company Name
Services
Area of Interest
Free-form Text

At the time the message is sent, the following data is also stored:

The IP address of the user
Date and time of registration

Your consent is obtained for the processing of the data and reference is made to this data protection declaration. In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation. The legal basis for the processing of data is art. 6(1)(a) GDPR if you have given your consent. The processing of the personal data from the entry mask serves us only for the establishment of contact. 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.

2. Duration of Storage, Possibility of Objection and Deletion

You have the possibility to revoke your consent to the processing of personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time. In such a case, the conversation cannot be continued.

In order to revoke access, please email dataprivacy@nevermined.io with the title "Revocation of Consent" along with pertinent Contact Form information and an explicit request for revocation. All personal data stored in this context will be deleted in this case.

VIII. Web Analysis

1. Scope, Purpose and Legal Basis of Data Processing

Scope

Our website uses functions of Google Analytics (Google LLC, 1600 Amphitheatre Parkway, Mountain View CA, USA, 94043) to analyze your surfing behavior. The software places a cookie on your computer (see above for cookies).

If individual pages of our website are accessed, the following data is stored:

Two bytes of the IP address of the user's calling system
The accessed website
The website from which the user has accessed the website
The sub-pages accessed from the website
The time spent on the website
The frequency of accessing the website

The information generated in this way is transferred to the provider's server and stored there. Your IP address is thus recorded, but immediately pseudonymised - Analytics removes the last octet of the user's IP address prior to its use and storage. This means that only a rough localization is possible.

Contract with Providers

We have concluded a corresponding contract for order data processing with the following provider(s):

Google Analytics (https://support.google.com/analytics/answer/4597324?hl=en)

The relationship with the web analytics provider is based on Privacy Shield (https://www.privacyshield.gov/welcome).

Legal Basis

Data processing is carried out on the basis of the legal provisions of art. 6(1)(a) (consent) and/or (f) (legitimate interest) of the GDPR.

Purpose

The processing of your personal data enables us to analyze your surfing behavior. By evaluating the data obtained we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. For these purposes, it is also in our legitimate interest to process the data in accordance with art. 6(1)(f) GDPR. By anonymizing the IP address, your interest in protection of your personal data is sufficiently taken into account.

2. Duration of Storage, Possibility of Objection and Deletion

The data will be deleted as soon as they are no longer needed for our recording purposes. Your data will be kept for the period of fourteen (14) months. Please see: https://support.google.com/analytics/answer/7667196.

IX. Rights of the Data Subject

If your personal data is processed, you are affected within the meaning of the GDPR and you have the following rights:

Right of access according to art. 15 GDPR. You can ask us to confirm whether personal data concerning you will be processed by us. If such processing has taken place, you may request information from us pursuant to art. 15 GDPR.
Right to rectification in accordance with art. 16 GDPR. You have a right of rectification and/or completion if the personal data processed concerning you are incorrect or incomplete.
Right to restriction of processing according to art. 18 GDPR. If processing has been restricted, you will be informed by us before the restriction is removed.
Right to erasure in accordance with art. 17 GDPR. You can demand that the personal data concerning you must be deleted without delay, and we are obliged to delete this data without delay, if one of the reasons specified in art. 17(1) GDPR applies. For all other information see art. 17 GDPR.
Right to information in accordance with art. 19 GDPR. If you have exercised your right to rectify, delete or limit the data processing, we are obliged to notify all recipients to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
Right to data portability in accordance with art. 20 GDPR. You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (provided that the conditions are met). For all other information see art. 20 GDPR.
Right to object according to art. 21 GDPR. You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you under Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. For all other information see Articles 21 and 22 of the GDPR.
Automated individual decision-making, including profiling. According to art. 22 GDPR you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. For all other information see art. 22 GDPR.
The right to withdraw the consent according to art. 7(3) GDPR. You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint with a supervisory authority according to art. 77 GDPR. Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

The way your application accesses, uses, stores, or shares Google user data

The files, pictures, etc associated to a new asset in Nevermined are stored in Google Cloud storage.

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