Privacy policy of Scale Network GmbH

1. Scope and general principles

This privacy policy applies only to the website www.scale-network.org (hereinafter “platform“). We, Scale Network LLC (hereinafter “Scale“), are the owners and operators of this platform and are responsible for it, as defined by the applicable data protection laws. 

Your trust and the protection of your privacy is of great importance to us. We, therefore, take the protection and security of your personal data very seriously. Your data will therefore only be collected, processed, used and stored in compliance with the applicable laws on data protection and data security.

In this privacy policy, we would like to inform you about the type, scope, and purpose of the personal data we collect, use and process. Furthermore, you will be informed about your rights in this privacy policy. 

2. Data transmission via the internet

The internet is an open network which is available to everyone and does not, therefore, represent a secure environment. Although each data package is always transmitted in an encrypted form, this does not apply to the sender or recipient. Moreover, it is possible for data to be transmitted abroad and thus possibly to a country with a lower standard of data protection than Switzerland, even if the sender and recipient are located in Switzerland. Scale accepts no liability for the security of data transmitted via the internet.

3. Collection of personal data 

We collect personal data (any information that concerns an identified or identifiable person) to facilitate your usage and offer you the best possible service. The extent and type of data collection depend on (i) whether you visit our platform only to access information or (ii) whether you make use of services we offer.

(i) Use of our platform to access information

If you use our platform purely for information purposes, you need not supply any personal data. We only collect and use the data concerning you which your internet browser automatically transmits, such as the pages accessed, the IP address, the internet browser used, the language and version of the internet browser used, the date and time of access, etc. 

When you visit our website for information purposes, we collect and use this data only in an anonymized form to enable you to visit our platform, for statistical purposes and to improve our services. By using our platform, you consent to our processing this data. 

(ii) Personal data which you supply to us and information which we receive through your use of the website

We collect such personal data and information to the extent that you provide it (e.g. when you upload your whitepaper on the platform, when receiving contact requests and when using the upload form, where the name, project name, email address, your occupational interest in cryptocurrency and the state of your project. In these cases, various personal data may be collected such as name, address, email, based area, telephone number, pictures, etc. By sending us such data, you consent to our processing this data. Uploaded whitepapers and reports that result out of the analysis will be stored in the Google Cloud.

When you select a payment provider on our site for payment, this provider also receives certain personal data such as your name, address and account details. It is also possible that your credit card provider will carry out a credit check. Your payment provider will supply you with further details.

Furthermore, we collect information about the uploaded file and its complete content, which is being processed using several providers, such as Google Cloud, Novatrend.ch and Gmail to send a confirmation email with the findings of the analysis. For all third-party providers, their respective terms of use, privacy policy, and disclaimer come in place. By sending us such data, you consent to our processing this data. 

All of this data is treated as strictly confidential and only stored for as long as is necessary to process the contract and order. Moreover, we carry out all data processing procedures (e.g. collection, processing, and transmission) in accordance with the statutory requirements. 

4. How we use and process personal data

We store, process and use the information and personal data collected as per Section 3 above for the provision, maintenance, protection and improvement of the platform, i.e. to process our whitepaper tool, to use other services on the platform, for customer support or to fulfill legal and contractual obligations.

We may also process and use your address and contact information for marketing and market research purposes. In particular, we evaluate the information and personal data collected as per Section 3 above in-house and determine where our clients come from, etc. For third-party marketing purposes, data is only passed on where this is permitted under the law. 

5. Newsletter

On our platform, we offer you the chance to subscribe to our newsletter for free. For this, apart from your declaration of consent, we require your email address. By sending your subscription to the newsletter you agree to our processing your data within the scope of this privacy policy. 

You can unsubscribe from our newsletter at any time. You will find the link for this at the end of each newsletter. By doing so, you revoke your consent or object to continued use of your data for the purpose of dispatch of the newsletter. 

6. Personal data forwarded by us

For the processing of our services, in particular, our whitepaper tool, the data relevant for these services is forwarded to www.scale-network.org / www.google.com / www.novatrend.ch / www.gmail.com (within the scope of a purpose which is permissible according to this privacy policy). You hereby expressly consent to this forwarding of data.

Furthermore, you agree that based on the data provided through the upload and filling out of the upload form, you consent to allow us to contact you and allow us to use the data necessary for conclusion and processing of the necessary service that may be transmitted, as listed but not limited on our website.

Your personal data will otherwise not be passed on to third parties, unless it is necessary to process the contractual relationship, or you have given your express consent. We reserve the right to disclose the data due to applicable laws, official orders, etc. or for other important reasons (e.g. investigation of possible violations of the terms of use, security deficiencies, serious technical problems, violation of third party rights, protection of property, etc.). The right is expressly reserved to any processing of data by third-party services, e.g. cookies or social plug-ins (cf. Section 7).

7. Web tracking and services of third-party providers

This platform uses services of third-party providers, in particular, Google Cloud, a web cloud storage service provider belonging to Google Inc., web hosting of NovaTrend Services GmbH and the email services provided by Gmail of Google Inc. (hereinafter third-party providers).

Such services collect information and can, in particular, use temporary or permanent “cookies”, i.e. small text files (e.g. HTML or flash cookies) which are stored on your computer (sometimes even after the end of the browser session), which may be retrieved on your next visit and which enable an analysis of the use of the platform and surfing behaviour and allow us to make our offer more user-friendly, effective and secure.

The information generated about your use of this platform (including your surfing behavior and IP address) may be transmitted to our servers or servers of third parties at home or abroad and stored and processed there and possibly attributed to you. Scale and the third-party providers may use this information for marketing purposes, in particular, to evaluate your use of the platform, to compile reports on platform activity for Scale and to render other services relating to platform and internet usage. This information may also be transmitted to other third parties at home and abroad. Abroad, adequate legal data protection might not exist. 

You can restrict or partly prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case, you might not be able to use all the functions of this platform to their full extent. Further information can be found in the browser’s instructions.

By using this platform, you consent to the processing of data collected about you in the manner and for the purposes set out above.

8. Data security

The scale takes appropriate technical and organizational security measures to protect personal data, especially against accidental or intentional manipulation, loss, destruction or attacks by unauthorized persons. Our security measures are continuously improved in line with technological developments.

9. User rights

You have the right at any time to demand confirmation from us as to whether personal data of yours is processed. 

If we process your personal data, you have a right to access, in particular with regard to the following information: (a) what data is processed; (b) the purpose for which it is processed; (c) the categories of personal data which we process; (d) the recipients or categories of recipients to whom your personal data has been disclosed; (e) if possible, the planned duration for which your personal data will be stored; (f) the existence of a right to rectification or erasure of personal data concerning you or to the restriction of processing by us or a right of objection to processing; (g) where the personal data was not collected directly from you, all available information about the source of the data; (h) the existence of automated decision-making. Furthermore, you have the right to know whether your personal data has been transmitted to a third country or an international organization. 

Furthermore, you have the right at any time to demand the immediate rectification, completion, restriction, blocking or erasure of the personal data stored about you. Should legal regulations not allow erasure, your personal data will be blocked instead. Moreover, you have the right to be informed by us of any rectification, completion, restriction, blocking or erasure of your data. In the event of any breach of the protection of personal data, we shall also inform you if this entails a high risk for personal rights and freedoms. 

The officer responsible for this can be reached via empower@scale-network.org or via Scale Network GmbH, c/o Jascha Krähenbühl, Kalchackerhof 11, 3047 Bremgarten b. Bern, Switzerland. The exercise of your above-mentioned rights is free of charge for you. 

If you do not agree to our data processing, you can also notify the Federal Data Protection and Information Commissioner (FDPIC) and/or the responsible supervisory authorities in the EU. 

10. Adaptation of the data privacy policy

Scale reserves the right to adopt this privacy policy at any time in line with legal requirements. The amendments shall be binding.

Bern, 11 May 2019