Privacy Policy

GENERAL INFORMATION
1. Witnium Technologies AB, company registration number 559416-7453 having its visiting address at Peter Myndes Backe 16, Stockholm, Sweden ("Witnium" "we" or "us"). This document contains a policy statement regarding Witnium&s collection, use and Processing of Personal Data ("Privacy Policy"). This privacy policy is applicable when you register, upload and share files through Witnium (the "Service" collectively the "Services"), or otherwise interact with the service while logged in.
DEFINITIONS
1. "Data Protection Laws" refers to the Swedish Personal Data Act (1998:204), which implements the EU directive 95/46/EC, and the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.
2. "Personal Data" means information which is directly, or indirectly, referable to a natural living person, e.g. name, address, location data or IP addresses.
3. "Processing" refers to any operations which is performed on Personal Data e.g. collection, organising, storage, use, erasure and disclosure.
4. "Data Controller" refers to Witnium in this case, since Witnium decides the purposes and the means of Processing.
PROCESSED DATA
1. The following Personal Data may be Processed when you use the Service:
  1. name;
  2. email address;
  3. IP address;
  4. ID number or social security number;
  5. information about your use of the Services;
  6. content that you post, upload and/or contribute to the Services;
  7. technical data, which may include the URL you are accessing the Website from, your IP address, unique device ID, network and computer performance, browser type, language and identifying information and operating system; and
  8. location data.
2. We are unable to provide you the Service unless you provide the Personal Data above.
PURPOSES OF PROCESSING
1. We will Process the Personal Data set out above for the following purposes:
  1. to administrate your account, to enable and provide the Services and integration with third party services, and to provide, personalize and improve your experience with the Services, and to otherwise provide the Services according to the terms of use;
  2. to send you alerts or messages by email or otherwise, including to provide you with marketing of our and our related parties’ products and services;
  3. to inform you about updates of the Services or the terms of use;
  4. to improve and develop the Services or new services and products and to analyse your use of the Services;
  5. to ensure the technical functioning of the Services and to prevent use of the Services in breach of the terms of use;
  6. to enforce the terms of use, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary; and
  7. to fulfil requirements by law.
LEGAL GROUND
1. Consent. By registration to our Service you consent to the processing of the Personal Data above as set out in this Privacy Policy.
2. Fulfilment of contract. By entering into contract with us we process your Personal Data to be able to fulfil our obligations set out in the agreement with you.
3. Legitimate interest. The Processing of your Personal Data is conducted on the basis of the legitimate interest of Witnium. Our legitimate interest for the Processing is to enable our users to obtain reliable evidence regarding ownership of their intellectual property through our blockchain technology (Digital Witness™). We also need to process Personal Data when you visit our Website to be able to maintain sufficient IT-security, to evade fraud and to protect the Website and the Services from cyber threats. The Personal Data will also be processed in order for Witnium to maintain and improve our Website and Services.
4. You have an absolute right to object to the Processing of your Personal Data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue Processing your Personal Data based on other legal grounds, except for direct marketing.
5. If you object to the Processing of your Personal Data that is Processed based on public interest or the legitimate interest of the controller, we will cease to Process your Personal Data for these purposes if we have not been able to provide you with sufficient support for our Processing.

DISCLOSURE OF PERSONAL DATA

We may share and disclose your Personal Data to third parties (e.g. payment service providers, service providers hosting the Website) to be able to provide you with the Service.

The recipients below are located outside the EU/EEA and we are therefore applying specified safeguards for the data transfers as set forth in the table below. You can acquire further information regarding the transfer by contacting us.

MailGun	U.S.A.	EU-U.S. Privacy Shield
Stripe	U.S.A.	EU-U.S. Privacy Shield
Google	U.S.A.	SCC and EU-U.S. Privacy Shield
Microsoft	U.S.A.	SCC and EU-U.S. Privacy Shield
Rollbar	U.S.A.	EU-U.S. Privacy Shield
Adobe	U.S.A.	EU-U.S. Privacy Shield
FontAwesome	U.S.A.	EU-U.S. Privacy Shield

When visiting our Website you may be directed to other websites where the Personal Data collected is not in our control. The privacy policy of the other website will govern the Personal Data obtained from you on that website.

RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM
We may access, preserve and share your Personal Data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.
COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES
We collect information by using technology such as cookies, pixels and local storage (on your browser or device). For information about how we use this type of technologies, please see our cookie policy: www.witnium.com/legal/cookie-policy.
RETENTION
We store your personal data as long as necessary to perform the Services requested by our users and to comply with applicable law (e.g. bookkeeping reasons). When a customer terminates his account, we delete the personal data regarding the customer except for the personal data we must store according to mandatory law.
CHILDREN
The Services are not directed to persons under the age of thirteen (13). We do not knowingly collect Personal Data from persons under the age of thirteen (13) (the "Child"). If you are a parent or guardian of a Child and you become aware of that the Child has provided Personal Data to the Witnium without your consent, please contact: info@witnium.com to exercise your access, rectification, erasure, limiting of Processing and objection rights.
YOUR RIGHTS
1. You have the right to request access and further information concerning the Processing of your Personal Data, or request that we correct, rectify, complete, erase or restrict the Processing of your Personal Data. You have the right to obtain a copy of the Personal Data that we Process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.
2. You have the right to have the Processing of your Personal Data restricted if (i) you have contested the accuracy of the Personal Data, (ii) the Processing is unlawful and you have requested restriction, (iii) if we no longer need your Personal Data for the original purposes but we require it to establish, exercise or defend legal rights, or (iv) if a verification of overriding grounds, regarding an erasure request, is pending.
3. If the Processing is based on consent you have the right to data portability. Data portability means that you can receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers.
CONTACT INFORMATION
1. To exercise your rights, or if you have any questions about our Processing of your Personal Data, please contact us at the following address: info@witnium.com. In your email please state your full name, user name and the email address used for registration. Note that you should sign the request to receive information of the Processing of your Personal Data yourself.
2. If you have any complaints regarding our Processing of your Personal Data, you may file a complaint to the competent Data Protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
NOTICE OF CHANGES TO THE PRIVACY POLICY
If we make changes to this Privacy Policy we will notify registered users by e-mail. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.