Privacy Notice
This Privacy Notice (“Privacy Notice”) explains and sets out the basis for our collection of personal data about the people who visit our website(s), when you interact with us in relation to a contract, communicate with us or otherwise deal with us, how we use it, the conditions under which we may disclose it to others and the measures we take to keep it secure. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices. We use the word “data” here interchangeably with “personal data”.
If you provide information to us about any person other than yourself, you must ensure that the data is accurate and that these people understand how their data will be used, that they have given their permission for you to disclose it to us and for you to allow us, and our service providers, to use it. You are welcome to provide them with a copy of this Privacy Notice.
1. Who we are
The responsible person for processing your data under this Privacy Notice (“Controller”) unless we tell you otherwise in an individual case is: Subspace Foundation, c/o Sielva Management SA, Gubelstrasse 11, 6300 Zug. You may contact us regarding data protection matters and to exercise your rights at contact@subspace.foundation
2. What kind of data we process about you and why
We process the following data about you for the purposes outlined below:
2.1 Data collection on this website
When you visit our website, we collect personal data that is necessary for the functionality and security of our website (e.g. IP address; information about the operating system of your end device; cookies; referrer URL; date, region and time of the server request; websites accessed or from which access is made; browser type and version; name of your Internet provider; protocols; etc.).
2.2 Communication and contact forms etc.
When you contact us by email, telephone, chat, letter or other means of communication, we collect the data exchanged between you and us for the purposes of communicating with you, in particular to respond to your enquiries (e.g. contact details; type, manner, place and time of communication; content of communication; etc.). By providing us with this information, you acknowledge that we use your personal information in accordance with this Privacy Notice.
2.3 Newsletters
If you subscribe to our newsletter, we process the information provided by you (e.g. contact details; email address) in order to provide you with our newsletter. You may cancel your subscription at any time by using the option to unsubscribe contained in the newsletter or by sending us an email to the address mentioned above.
2.4 Community Incentives
You can earn different monetary rewards by participating in activities for the Subspace community and by helping us find bugs and faults in the Subspace products and/or website. We process the data collected in this context in order to provide and ensure the functionality and support the implementation of the incentive program (e.g. name; telephone number; email address; place of residence; and date of birth; participation behavior; reported bugs and faults; paid financial rewards; consent with regard to participation in Incentive Program; etc.).
2.5 Performance of a contract
We process your data for entering into a contract with you, perform and administer it (e.g. your contact data and further information provided by you; information when using our services and/or with regard to a possible conclusion of a contract and about the conclusion of the contract; information about the execution and administration of the contracts; information about defects, complaints and contract amendments; financial data; information about downloads of offers, information, brochures, etc. that you have made; etc.).
2.6 Product / services improvement and innovation
We process your data for market research and to improve our products and services (including our website).
2.7 Safety or security reasons
We process your data to protect our IT and other infrastructure (e.g. buildings). For example, we process data for monitoring, analysis and testing of our networks and IT infrastructures including access controls. We might also use surveillance systems, e.g. cameras for security purposes. In such a case, we will inform you at the relevant locations separately.
2.8 Compliance with law and legal procedures
We process your data to comply with legal requirements, e.g., money laundering and terrorist financing, tax obligations etc. and we might have to request further information from you to comply with such requirements («Know Your Customer», “KYC”) or as otherwise required by law and legal authorities. Furthermore, we may process your data for the enforcement of legal claims and for the defense in legal disputes and official proceedings.
2.9 Risk management, corporate governance and business development
We process your data as part of our risk management and corporate government in order to protect us from criminal or abusive activity. As part of our business development, we might sell businesses, parts of businesses or companies to others or acquire them from others or inter into partnerships and this might result in the exchange and processing of data based on your consent, if necessary.
2.10 Cookies
We use cookies to operate and optimise our website (see also "Tracking Tools” below). These are text files that are stored on your device (computer; laptop; smartphone; etc.)and that are necessary for the use of the website as such or certain functions or that enable the analysis of the use of our website. You can configure your browser in such a way that no cookies are stored on your computer or a message always appears before a cookie is installed. Complete deactivation of cookies may result in our website not functioning or not functioning completely.
2.11 Tracking Tools
We process your Personal Data in order to operate and secure our Website, in particular for security reasons to ensure the stability and integrity of our system and to ensure a smooth connection of the Website. In addition, we use Google Analytics to perform basic web analysis to optimize the Website regarding usability and to gain insights about the use of our Website.
2.12 Links to third party offerings
Our website may contain third-party offerings. Please note that when you use such link, your data (e.g. IP address; personal browser settings; etc.) are transmitted to these third parties. We have no control over, do not review and are not responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these third-party websites or their content, or to any collection of your data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
2.13 Social media plugins and our social media presence
Our website includes limited-functionality social media plugins, such as “Share to” buttons for platforms including X, LinkedIn, and YouTube. These plugins do not enable active tracking or data collection by the respective platforms through our website. They are used solely to allow users to share content from our site to their social media accounts.
Additionally, our website may display icons that link passively to our official pages on various social media platforms (e.g., X, LinkedIn, YouTube). These icons do not transmit personal data to the respective platforms unless you actively click on them.
For more information on how these social media providers collect and process data, please refer to their individual privacy policies. This also applies to your interactions with our presence on those platforms.
3. Legal basis for the processing of your data
Where we asked for your consent (e.g. for receiving newsletters), we process your data based on such consent. Where we did not ask for your consent and where required under applicable law, we process your data on other legal grounds, such as
- a contractual obligation
- a legal obligation
- a vital interest of the data subject or of another natural person
- to perform a public task
- our legitimate interest.
4. To whom do we transfer your data?
As part of our data processing, may share your personal data with third parties, in particular to the following categories of recipients:
Service providers
We may share your information with service providers and business partners around the world with whom we collaborate to fulfil the above purposes (e.g. IT provider, shipping companies, advertising service provider, security companies, banks, insurance companies, telecommunication companies, credit information agencies, address verification provider, lawyers) or who we engage to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only.
Legal authorities
We may pass on personal data to offices, courts and other authorities in Switzerland or abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The authorities are responsible for processing data about you that they receive from us.
Contractual partners
In case required under the respective contract we share your data with other contractual partners. If we sell or buy any business or assets, we may disclose your data to the prospective seller or buyer of such business or assets to whom we assign or novate any of our rights and obligations.
5. Do we disclose your data abroad?
The data that we collect from you may be transferred to, processed and stored in, a country outside Switzerland or the European Economic Area (EEA). The laws in some countries may not provide the same legal protection for your personal data as in Switzerland or the EEA. We only transfer data to these countries when it is necessary for the performance of a contract or for the exercise or defence of legal claims, or if such transfer is based on your explicit consent or subject to safeguards that assure the protection of your data (e.g. US-EU Data Privacy Framework; the US-CH Data Privacy Framework; European Commission approved standard contractual clauses, adjusted under Swiss law, if applicable and required).
6. On-Chain Data
When you use blockchains, you acknowledge that your wallet address and other data/information provided by your transactions, which are considered personal data if relating to an identified or identifiable natural person, are permanently and publicly stored on-chain, which means such data is publicly available to anyone. Neither we, nor any third party, has any power to delete such data published by its users to the blockchain. If you want to ensure that your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be available or exercisable by you or us due to the technological infrastructure of the blockchain.
You hereby release and indemnify us of any liability associated with data that you transferred to the blockchain.
7. How long do we keep your data?
We only process your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of complying with legal retention requirements and where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. Upon expiry of the applicable retention period we will securely destroy your data in accordance with applicable laws and regulations.
8. Security of your data
We take appropriate organizational and technical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
However, we and your personal data can still become victims of cyber-attacks, cybercrime, brute force, hacker attacks and further fraudulent and malicious activity including but not limited to viruses, forgeries, malfunctions and interruptions which is out of our control and responsibility.
We have also 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.
9. Your choices and your rights
To the extent provided for by applicable law, you may request information free of charge about the data stored relating to you, its origin and recipients and the purpose of the data processing. You may also have the right to correction, deletion, restriction or objection to processing, as well as to the transfer of the data to another controller.
Furthermore you can revoke your consent at any time with effect for the future. All you need to do is send us an informal e-mail.
Please note that the foregoing rights are subject to legal restrictions and may interfere with or make impossible the provision of our services.
10. How you can update your information
The accuracy of your information is important to us. If you change your email address, or any of the other information we hold is inaccurate or out of date, please email us to the email address mentioned above.
11. Updating and changing this Privacy Notice
Due to continuous development of our website and the contents thereof, changes in law or regulatory requirements, we might need to change this Privacy Notice from time to time. Our current Privacy Notice can be found at our website.