Controller

ValleyDAO, a Swiss Association (Verein) having its address at Chamerstrasse 172, 6300 Zug, Switzerland (“ValleyDAO/we/us/our”) is the controller and responsible for your personal data. We have appointed a Data Protection Representative who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the Data Protection Representative using the details set out below. If we are a data processor in respect of other people’s information, other terms (including a data processing agreement that we have signed with you) will apply.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 20 August 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Representative at people@valleydao.bio.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name or similar identifier, title and job title.
• Contact Data includes company name, address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, the products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, methods used to browse away from the page.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Employment Data includes current and past employment, experience, qualifications, skills, interests and any other information disclosed by you.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; request marketing to be sent to you; enter a promotion or survey; or give us feedback or contact us, or apply for a  job with us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
• Third parties and publicly available sources. We may receive personal data from various third parties as set out below:

• identity and contact data from other individuals at your organisation
• information given to us by our clients and businesses that we work with
• technical data from analytics providers and/or search information providers; and
• employment, identity and contact data from recruitment agencies, previous employers, etc.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform the contract we are about to enter into or have entered into with you, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

• Purpose/Activity: To register you as a new customer
  Type of data: Identity and Contact
  Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
• Purpose/Activity: To manage our relationship with you which will include:
  (a) Notifying you about changes to our terms or privacy policy
  (b) Asking you to leave a review or take a survey
  Type of data: Identity, Contact, Profile  and Marketing and Communications
  Lawful basis for processing including basis of legitimate interest:
  (a) Performance of a contract with you
  (b) Necessary to comply with a legal obligation
  (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
• Purpose/Activity: To enable you to complete a survey
  Type of data: Identity, Contact, Profile, Usage  and Marketing and Communications
  Lawful basis for processing including basis of legitimate interest:
  (a) Performance of a contract with you
  (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
• Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  Type of data: Identity, Contact, and Technical
  Lawful basis for processing including basis of legitimate interest:
  (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  (b) Necessary to comply with a legal obligation
• Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  Type of data: Identity, Contact, Profile, Usage, Technical  and Marketing and Communications
  Lawful basis for processing including basis of legitimate interest:
  (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
  (b) Where we do this by way of cookies, with your consent.
• Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  Type of data: Technical and Usage
  Lawful basis for processing including basis of legitimate interest:
  (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
  (b) Where we do this by way of cookies, with your consent.
• Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
  Type of data: Identity, Contact, Profile, Usage, Technical  and Marketing and Communications
  Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
• Purpose/Activity: To process a job application and keep you informed of employment opportunities
  Type of data: (a) Identity (b) Contact (c) Financial (d) Profile
  Lawful basis for processing including basis of legitimate interest:
  (a) Performance of a contract with you
  (b) Necessary to comply with a legal obligation
  (c) Necessary for our legitimate interests (to recruit good candidates for our business)

Marketing

Promotional offers from us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Third parties providing services to us such as legal and accounting services, and analytics partners to analyse website traffic and understand customer needs and trends.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Other third parties, if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Many of our external third parties listed above are based outside the EU and UK so their processing of your personal data will involve a transfer of data outside the EU and UK.

Whenever we transfer your personal data out of the EU or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO.
• Where we use certain service providers outside the UK or EU, we may use specific contracts approved by the ICO and/or European Commission as applicable which give personal data the same protection it has in the UK and/or Europe as applicable.

Unless you do not consent to us using Google Analytics, Google Analytics (Google Inc. and its affiliates), may process your data in the course of providing analytical information to us about the use of our website. These service providers may collect and/or transfer your data outside of the UK or EU. See Google Analytics: Safeguarding your data

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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