Protecting your personal data is very important to weeNexx AG.
1. LEGAL BASIS. We pay special attention to the protection of personal data in accordance with applicable national data protection laws, especially the EU General Data Protection Regulation (hereinafter the „GDPR„). Your personal data may be processed if justified under applicable data protection law (e.g. for the purpose of fulfilling a contract with you) or based on your explicit consent (for further details please see below).
3. YOUR RIGHTS. Pursuant to applicable data protection law you may have the following rights. Please note that these rights might be limited under the applicable national data protection law.
3.1. RIGHT TO ACCESS PERSONAL DATA
You have the right to confirm with us whether or not We process personal data about you and you also have the right to access the personal data and be provided with a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
3.2. RIGHT TO RESTRICT THE USE OF PERSONAL DATA
Under certain circumstances, you have the right to claim from us restriction of processing your personal data, i.e., ask Us not to process your personal data in the following cases:
- Where you contest the accuracy of the personal data.
- Where the processing is unlawful, but you do not wish the personal data to be erased, you may request restriction instead.
- Where we no longer require the personal data for the purpose of processing, but it is still required by an individual in connection with a legal claim. In this case, the respective data will be marked and may only be processed by us for certain purposes.
3.3. RIGHT TO REQUEST THAT PERSONAL DATA IS ERASED (“RIGHT TO BE FORGOTTEN”)
Under certain circumstances, you have the right to request that personal data are erased and we may be obliged to erase such personal data.
3.4. RIGHT TO REQUEST THAT PERSONAL DATA ARE RECTIFIED
You have the right to request rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
3.5. RIGHT TO OBJECT TO PROCESSING OF PERSONAL DATA.
Under certain circumstances, you have the right to object to processing of personal data on grounds relating to your particular situation at any time to the processing of your personal data by us and We will have to stop processing until we are able to verify that we have compelling legitimate grounds for processing which override your interests, rights and freedoms, or alternatively that we need to continue processing for the establishment, exercise or defense of legal claims.
Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.
3.6. RIGHT TO DATA PORTABILITY (IN CERTAIN CIRCUMSTANCES)
Under certain circumstances, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and have the right to transmit the data to another controller where technically feasible.
3.7. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
You have the right to lodge a complaint with a supervisory authority, in particular, in the member state where you are habitually resident, work or where an alleged infringement of data protection laws has taken place. You can exercise your rights by contacting us at email@example.com.
To the extent our processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time with future effect without affecting the lawfulness of Our processing based on your consent before its withdrawal.
4. CATEGORIES OF PERSONAL DATA
We process the following personal data relating to you:
4.1. INFORMATION YOU GIVE US
a) You may give Us information about you by filling in forms on the Website or by corresponding with Us by phone, e-mail or otherwise. This includes information you provide when you register on the Website and use our services at https://weemat.io or in case you report a problem with the Website to our support team. The information you give Us may differ, but may include at the maximum:
b) Identification data, such as name, sex, age/date of birth, place of birth, contact details including address (private and professional), phone number (private and professional), email (private and professional);
- Profession, job title and position;
- Nationality or civil status;
- Passport information or other national identification number;
- Tax identification;
- Personal bank account and financial information such as account identification and number, income and (for professional investors) financial license;
- Information about the account holders’ or investors’ transactions;
- Account history with us;
- Financial details such as fees paid and bank account details;
- Financial license, dealer number and dealer name;
- “Politically Exposed Person” status, criminal convictions and potentially source of wealth relating to an investment;
- Dealer number and dealer name; and any other information required to meet contractual obligations and statutory obligations.
4.2. INFORMATION WE COLLECT ABOUT YOU
With regard to each of your visits to our Website, We may automatically collect the following information:
a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
b) information about your visit, including the full Uniform Resource Locators (URL), through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-movers), and methods used to browse away from the page and any phone number used to call our customer service number.
4.3. INFORMATION WE RECEIVE FROM OTHER SOURCES
We may receive information about you if you use any of the other websites we operate or are affiliated to. In this case, We will have informed you when We collected that data that it may be shared internally and combined with data collected on this Website subject to applicable data protection laws. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and others) and may receive information about you from them subject to applicable data protection laws.
5. USES MADE OF THE PERSONAL DATA PURPOSES
5.1. WE USE PERSONAL DATA HELD ABOUT YOU IN THE FOLLOWING WAYS:
a) Personal data you give to Us. We will use this data:
- To verify your identity.
- To provide services and products to yourself and to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about.
- To market our services and products to you, including contacting you telephonically and electronically.
- To improve the services and products that we provide to you.
- To undertake credit checks of you (if necessary).
- To bill you and to collect money that you owe us.
- To respond to communications from you, including a complaint.
- To protect and/or enforce our legal rights and interests, including defending any claim. To effectively discharge our contractual and statutory obligations arising from our contract with you.
- To provide you or permit selected third parties to provide you with information about goods or services We feel may interest you. If you are an existing customer, We will only contact you by telecommunication and electronic means (phone, e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by telecommunication and electronic means only if you have consented to this. If you do not want Us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know at firstname.lastname@example.org and We will update our records;
- To notify you about changes to our service;
- To ensure that content from our Website is presented in the most effective manner for you and for your computer;
b) Personal data We collect about you. We will use this data:
- To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our Website safe and secure;
- To measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
c) Personal data We receive from other sources. We may combine this data with data you give to Us and data We collect about you. We may use this data and the combined data for the purposes set out above (depending on the types of information We receive).
d) Personal data We verify. As part of our customer due diligence (Know Your Customer) process We may send to third parties your personal data to be verified for identification purposes, this personal data shall include sensitive personal data such as a picture of your passport. The third parties We work with may be outside of the European Union. If you have any queries about this process, please do not hesitate to contact Us at email@example.com.
6. DISCLOSURE OF YOUR PERSONAL DATA
6.1. Your data is not forwarded to third parties excluding affiliates, unless We are under the obligation to do so by law or if the forwarding of the data is justified under applicable data protection law.
6.2. We may share your personal data with selected third parties including:
a) Business partners, suppliers.
b) Sub-contractors. We may engage external service providers, who act as a data processor of Us, to provide certain services to Us such as website service providers, marketing service providers, distribution partners, forwarding agents, commissioned producers, legal and tax advisors or IT support service providers. When providing such services, the external service providers may have access to and/or may process your personal data.
Those external service providers will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data and to process the personal data only as instructed.
c) Analytics and search engine providers that assist us in the improvement and optimization of our Website. Those external service providers will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data and to process the personal data only as instructed.
d) ID verification agencies for the purpose of verifying your identity where this is a condition of us entering into a contract with you depending on the trading level on our Website.
e) Some of our colleagues administering the Website and providing IT services may be employees of our group companies. When administering the Website our colleagues may have access to and/or may process your personal data. The respective transfer of your personal data is based on our legitimate interests. Our legitimate interests are the transmission of personal data within the group of companies for internal administrative and support purposes. The access is limited to colleagues with a need to know. More information on the balancing test is available upon request.
6.3. We may disclose your personal data to third parties:
a) In the event that We sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
b) If weeNexx AG or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of weeNexx AG, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction.
d) We may also transfer your personal data to law enforcement agencies, governmental authorities, legal counsel and external consultants in compliance with applicable data protection law. The legal basis for such processing is compliance with a legal obligation, to which We are subject to or are legitimate interests, such as exercise or defense of legal claims if there is a suspicion of a criminal offence or the abuse of the services offered on our Website. More information on the balancing test is available upon request.
7. WHERE WE STORE YOUR PERSONAL DATA / ENCRYPTION
7.1. All personal data you provide to Us is stored exclusively on our secure servers and may be transferred to, and stored at a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. I.e., the personal data that we collect or receive about you may be transferred to and processed by recipients which are located inside or outside the European Economic Area (“EEA”) and which maybe do not provide for an adequate level of data protection. The countries that are recognized to provide for an adequate level of data protection from an EU law perspective are Andorra, Argentina, Canada, Switzerland, Faeroe Islands, Guernsey, the State of Israel, Isle of Man, Jersey, New Zealand and the Eastern Republic of Uruguay. Recipients in the US may partially be certified under the EU-U.S. Privacy Shield and thereby deemed to provide for an adequate level of data protection from an EU law perspective. To the extent your personal data are transferred to countries that do not provide for an adequate level of data protection from an EU law perspective, we will base the respective transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission. You can ask for a copy of such appropriate safeguards by contacting us as set out under 11 below. The access is limited to recipients with a need to know.
7.2. Any transactions will be encrypted using the latest SSL technology or better. In case we have given you (or where you have chosen) a password which enables you to get access to our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
7.3. Please Note that We will never ask you to provide other personal or financial information such as passwords, date of birth, bank account balances, portfolio balances or your personal bank account details, or instruct you to pay funds into third party bank accounts.
7.4. If you receive a communication from someone who claims to be from weeNexx AG and who asks you to provide your personal or financial information, this may indicate that you are the target of a scam. If this happens to you, please immediately report this to weeNexx AG by sending the details to us at firstname.lastname@example.org.
7.5. Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your personal data, We will use strict procedures and security features to try to prevent unauthorized access.
7.6. Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. STORAGE PERIOD
Your personal data are stored only as long as this is required by law or as long as necessary for fulfilling the defined purpose. After the purpose has been attained or after expiry of the storage periods, We will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including personal data, to comply with legal or regulatory obligations to which We are subject, e.g. statutory retention periods which can result from, e.g. commercial law or tax law and usually contain retention periods from 6 to 10 years, or if we need it to preserve evidence within the statutes of limitation, which is usually three years but can be up to thirty years.
9. COOKIES POLICY
9.1. WHAT IS A COOKIE?
Cookies are small text files containing small amounts of information which are sent to and stored on your computer, smartphone or other device when you access a website. Cookies are then sent back to the originating website on each subsequent visit or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device.
Cookies are used on the Website for a number of reasons. This includes, but is not limited to, the following:
a) to allow users to log on to their weeNexx AG account;
b) to allow users to choose log-in preferences;
c) to monitor and collect information about transactions placed on the Website; and
d) for fraud prevention purposes and generally to safeguard privacy.
e) Cookies are generally used to improve and enhance the user experience. Some of the cookies we use may be essential for the Website to operate.
a) Session Management – these cookies are essential to enable use of the Website, they manage session information and enable users to navigate through the Website. The legal basis for the collection of information through the use of strictly necessary cookies is contract performance (if we concluded a contract on the use of the Website with you) or legitimate interests of us or third parties, such as the provision of a functioning Website. More information on the balancing test is available upon request.
b) Functionality – these cookies store information which enables us to remember user preferences e.g. preferred language, sort types, media settings. They are also used to improve users’ experience by, for example, stopping users from being shown the same message twice. The legal basis for the collection of information through functionality cookies is your consent.
c) Fraud Prevention – these cookies store information which helps Us stop fraudulent use of the Website. The legal basis for the collection of information through fraud prevention cookies is your consent.
d) Tracking – these cookies enable Us to store information about how users landed on the Website. We need to record this so that we can appropriately pay our affiliates. The legal basis for the collection of such information by targeting/advertisement cookies is your consent.
e) Analysis – these cookies allow Us to recognize and count the number of users and to see how users move around our Website when they are using it. This helps Us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily and to deliver adverts and information which are more relevant to each user and their interests and to monitor the effectiveness of such adverts and information. The legal basis for the collection of information through the use of analysis cookies are legitimate interests of us or third parties, such as the provision of a functioning website. More information on the balancing test is available upon request.
Where links are provided on the Website to third party websites it is important to remember that those websites will have their own cookies and privacy policies which will govern any information you may submit. If you decide to use any linked third-party websites please read their cookies and privacy policies before doing so.
9.4. MANAGING COOKIES
At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please, note that the process you follow to delete cookies will differ from browser to browser. If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Website, you can do so by deleting your existing cookies and/or altering your browser’s privacy settings. However, should you choose to disable, reject or block our cookies, some parts of our Website will not function fully, or in some cases, our Website will not be accessible at all.
10. RESPONSIBLE ENTITY
The responsible controller is:
weeNexx AG, Müligässli 1, 8598 Bottighofen, Switzerland
Contact Details: Email: email@example.com