Privacy Policy

(Effective from March 11, 2024)

I General Terms

This privacy policy applies to personal data collected and processed by Spawn Solutions Ltd. Novi Sad, as the data controller. 

We honor and appreciate your privacy, demonstrating a serious commitment to data protection. We have developed this privacy policy to transparently and comprehensibly outline the ways in which we gather, utilize, and disclose your data, as well as how you can exercise your rights as the data subject.

This privacy policy is crucial for you to be able to determine the scope and consequences of data processing , allowing you to maintain control over your personal data. Therefore, we recommend that you read it carefully and become familiar with how your personal data is processed and protected.

II Definitions

    • ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

    • ‘data subject‘ is the individual the personal data relates to;

    • ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

    • ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

    • ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

    • ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

    • ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 2However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

    • ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

    • ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

    • ‘cookies‘ are small files of information that a web server generates and sends to a web browser; 

    • ‘Google Analytics‘ – service of the Google company that track website performance and collect visitor insights. 

III Processing of data

This privacy policy applies to individuals who:

    1. Access our website at wafian.io;

    1. Contact us via the email address marketing@wafian.io;

    1. Subscribe to receive our newsletters.

Depending on how you use our website or services, the information we may process about you includes personal data that you voluntarily provide.

We do not process data beyond the specified purposes outlined below, specifically:

    • We do not sell any personal data;

    • We do not disclose this information to marketing agencies;

    • We do not disclose your personal data to any third party, individual, public authority, or other company at any time, unless explicitly imposed by contract or law. 

IV  The data we collect, why we collect it, and on what basis:

1.

    • Data we collect: The data we collect includes technical usage data, primarily obtained through cookies and similar tracking technologies. We use different types of cookies for the following purposes:

A) Necessary cookies – These enable the regular functioning of the website, collecting only pseudonymized data.

B) Analytical cookies – These are used to gather data on how visitors interact with the website.

    • Purpose of processing: Collecting this data helps us understand how visitors use our website, allowing us to tailor our content and services to better meet user needs.

    • Legal basis: Your consent.

    • Retention period: Until you revoke your consent. You can revoke your consent at any time by adjusting cookie settings, as explained in our cookie policy. Revocation of consent does not affect the lawfulness of processing based on consent before its revocation.

2.

    • Data we collect: Contact details and other information you choose to provide us in your inquiries via our contact form, email on the website or through other means.

    • Purpose of processing: To respond to your inquiries sent via email.

    • Legal basis: The processing is necessary for executing a contract and/or for cocluding a contract with you.

    • Retention period: If there is no legal, contractual, or other justification for retaining your data, we will delete it within 30 days after responding to your inquiry.

3.

    • Data we collect: The contact details of subscribers to our free newsletters;

    • Purpose of processing: If you wish to periodically (once a week) receive our free newsletters via email, providing you with following information:

    1. Share the latest developments, features, and enhancements to your Web3 platform. Highlight how these updates improve user experience and address pain points.

    1. Provide insights into trends, news, and developments in the blockchain and Web3 space. This could include analysis of market dynamics, regulatory updates, and emerging technologies.

    1. Offer educational content to help subscribers better understand blockchain technology, decentralized finance (DeFi), non-fungible tokens (NFTs), and other Web3 concepts. This could include articles, guides, tutorials, and webinars.

    1. Showcase real-world use cases and success stories of how your platform is empowering users and solving problems in different industries. Highlight testimonials and case studies to demonstrate the value of your solution.

    • Legal basis: Your consent.

    • Retention period: We retain your data until you revoke your consent. You can revoke your consent at any time and unsubscribe using the “unsubscribe” option in the email.

V How we store your data 

We implement suitale administrative, technical, organizational, and other measures to ensure an adequate level of protection for the personal data we collect and process.

VI Data processors

In order to execute certain processing actions, we require support from external processors. When using processors for specific processing tasks, we only utilize those that provide sufficient guarantees for the implementation of appropriate technical and organizational measures.

We use Google Analytics services to monitor and process data related to visitors to our website.  Google Analytics employs cookies to collect pseudonymized data about how users interact with the website. The data includes information about visited pages, time spent on the website, and other statistical details.

The following processors are listed below, with whom we share data about you:

Google LLC, headquartered in the USA.

VII Rights of the data subject

In accordance with the provisions of the Personal Data Protection Act (Official Gazette of the Republic of Serbia, No. 87/2018), you have, among other things, the following:

    • The right to revoke your consent for the processing of your data;

    • The right to access information regarding whether we process your personal data, as well as the right to access that data if we process it;

    • The right to rectify and supplement data

    • The right to delete data if: personal data are no longer necessary for the purpose for which they were collected or otherwise processed; you have revoke the consent on the basis of which the processing was carried out, and there is no other legal basis for processing; other reasons provided by the Personal Data Protection Act;

    • The right to restrict processing of your data;

    • The right to lodge a complaint – if you have any questions regarding the processing of your data, please contact us at marketing@wafian.io. If you believe that we process your data contrary to the provisions of the Personal Data Protection Act, you have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, Belgrade, 11120. 

If you wish to exercise your rights, you can contact us at marketing@wafian.io 

You are not required to pay any fee to exercise your rights. We have a 30-day deadline to respond to your request, but in cases of increased complexity or a high volume of requests, we may extend this period by an additional 60 days.

VIII Changes to our privacy policy 

We reserve the right to periodically update this privacy policy in the event of changes that significantly impact the processing of your personal data, and to monitor changes in legislation and technological innovations. 

All changes take effect immediately upon publication on the website. 

We will seek your consent in the event of any substantial modifications to this privacy policy, as mandated by applicable data protection laws. 

If you do not agree with our Privacy Policy, we encourage you to cease using the website or our service promptly and unsubscribe from our newsletter.

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