Data Privacy Notice for the SWIAT GmbH Company Page on LinkedIn

This Data Privacy Notice has been issued in accordance with the European General Data Protection Regulation (GDPR) and applies to the processing of personal data in connection with our LinkedIn Company Page (“Company Page”), available at: www.linkedin.com/company/swiat or in the LinkedIn app, that is performed by us, SWIAT GmbH, Frankfurt am Main (“SWIAT” or “we”), as operator of the Company Page.
We (see section 3) and LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”) (see section 4) are both partially responsible and we and LinkedIn are partially jointly responsible (see section 5) in the EU and European Economic Area for the processing of personal data collected from users of our LinkedIn Company Page. LinkedIn is the main focus of the data processing. We explain how this works and what your rights are below.

1. General information on provision of the LinkedIn Company Page

Visiting our Company Page gives you the opportunity to receive information, reports etc. about our company. We also publish reports and information on the page concerning conditions and developments in the blockchain area and related topics and inform users about informational events.

2. Alternative information and contact options

We inform users that they use the LinkedIn Company Page and its features at their own responsibility. This applies in particular to use of the interactive features (e.g. commenting, sharing, liking etc.). The type and scope of processing of your personal data when you visit our Company Page are greatly dependent on your user behaviour and can be influenced in part by you as a user. If you would like to learn more about us, please visit our website at www.swiat.io. Information on data processing in connection with our website is available in our website Data Privacy Notice at https://www.swiat.io/terms.html.

3. Processing of personal data by SWIAT 3.1 Name and address of the Controller for our Company Page | Contact information for our Data Protection Officer

If you actively use our Company Page, we are responsible for the processing of your personal data as described below. Please use the following contact information to reach us or our Data Protection Officer:

SWIAT GmbH
c/o DekaBank Deutsche Girozentrale
Mainzer Landstraße 16,
60325 Frankfurt am Main,

3.2 Purposes for the processing of personal data that users provide to us by actively using our Company Page | Legal basis

Community feature

Users of the Company Page can use a variety of integrated Community features to interact with us; you can, for example, share, comment on or “like” posts on our Company Page.

If you use the Community features, we process your user name, profile picture, active click interaction with our posts (“like”, “share” etc.) and your comments and other content that you provide to us on the Company Page (“Community Data”). We process all Community Data in order to provide the Community features to users in accordance with applicable provisions. We are not able to provide these Community features to you without this data. The legal basis for the processing is our overriding legitimate interest in providing your content, the Company Page and its features to you and other users of our Company Page (Art. 6 para. 1 letter f GDPR).

We only process your personal data as long as necessary, as a rule as long as we operate our Company Page or as long as you are actively using our Company Page. In addition, we only store your data for pursuing or defending against legal claims or to fulfil any statutory retention requirements.

3.3 Notice regarding sensitive data

Please do not post or incorporate any personal data or other sensitive data on our Company Page.

3.4 No data profiles

We do not create a profile for you (no decision-making based solely on automated processing, including profiling) and do not mix your Community Data with other data we have about you.

3.5 Data recipients for processing by SWIAT

Processors: We may transfer your activity data to external services providers, such as IT service providers, in connection with the purposes indicated here. We have chosen these service providers carefully and have concluded processing agreements with them. We use the technical platform and services provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, to provide our company profile and the content indicated above.

Other recipients: We otherwise only transfer your activity data in individual cases to other recipients, if and to the extent required or permissible by law or to enforce legal claims, or to investigate or prevent activities that are suspected to be or actually are illegal. We inform you separately about transfers in such cases, if and to the extent this is required and permissible by law.

We notify users in this regard that these areas are publicly accessible and all personal information that is included there or is visible during login can be seen by other users. We cannot control or influence how other users of our Company Page use this information. In particular, we cannot prevent other users from sending unwanted messages.

4. Processing of personal data by LinkedIn

LinkedIn processes other information and personal data about users and their usage behaviour when they visit our Company Page in order to provide the “LinkedIn” social network.

If you use a browser or the LinkedIn app to visit our Company Page, LinkedIn might process information about your visit to our Company Page and the LinkedIn platform as a whole that LinkedIn collects using cookies and similar technologies such as pixels and local storage or app interfaces on your PC or other device. In addition, advertisers or other LinkedIn partners might use cookies or similar technologies on your device that we have no control over.

We have no influence over what data LinkedIn processes, the scope of the data processed, how it is processed or whether LinkedIn transfers such data to third parties, including in particular those in countries outside the European Union and European Economic Area.

Your personal data will be processed by LinkedIn Ireland Unlimited Company and transferred to the US (and to other subsidiaries as indicated at https://www.linkedin.com/help/linkedin/answer/62533?trk=microsites-frontend_legal_privacy-policy&lang=de) in order to provide our Company Page on the LinkedIn platform. LinkedIn uses standard contractual clauses approved by the European Commission as a legal mechanism for transferring data out of the European Union. The standard contractual clauses are contractual obligations that require companies to protect privacy and data security when transferring personal data (e.g. between LinkedIn Ireland Unlimited Company or its customers and LinkedIn Corporation). LinkedIn companies observe the standard contractual clauses in order to legally secure the data transfers required for the provision, maintenance and development of LinkedIn services.

LinkedIn’s processing of your personal data is subject to the LinkedIn Privacy Policy, which also provides LinkedIn contact information. The Privacy Policy can be viewed using the following link: https://www.linkedin.com/legal/privacy-policy

LinkedIn Ireland Unlimited Company is the sole controller for such processing of personal data. LinkedIn could change the link indicated above for the LinkedIn Privacy Policy in the future. If the link shown above does not lead to the desired information, we ask that users access the LinkedIn websites directly for such information if necessary.

5. Joint processing of usage statistics (Page Insights) by SWIAT and LinkedIn

When you use our Company Page, according to our knowledge LinkedIn collects the following personal data about you (“Usage Data”):

• Interactions with the Company Page, in particular whether the user is a follower of our Company Page;
• Information about you, such as occupation, country, industry, length of employment, company size and employment status (all from the user profile of logged-in users).

We do not receive this data directly, but instead only receive it from LinkedIn in aggregated form, i.e. in summary form by using LinkedIn's “Page Insights” tool. LinkedIn does not provide any personal data of members through Page Insights. We cannot attribute usage data to users.

As indicated in its Privacy Policy, LinkedIn uses cookies and similar technologies to collect usage data, which is then provided to us as usage data in aggregated form.

We can use the usage data and other visible data to optimise our Company Page.

We would not be able to obtain the usage data without our Company Page. We and LinkedIn are therefore “joint controllers” for processing of the usage data. That means this data is processed by LinkedIn and us with the common purpose of learning about the usage behaviour of users of our Company Page. In cases such as this where there are joint controllers, the GDPR requires that we reach an arrangement with LinkedIn in accordance with Article 26 GDPR. This arrangement can be viewed here: https://legal.linkedin.com/pages-joint-controller-addendum. The arrangement includes further details and explanations of our joint responsibility with LinkedIn with respect to Page Insights.

Our participation in the joint processing is based on our legitimate interest in the usage data to manage and improve our Company Page. Art. 6 para. 1 letter f GDPR provides the legal basis for such processing.

6. Your data subject rights under the GDPR 6.1 In relation to us

As a controller, we are required to inform you of your rights under the GDPR (data subject rights).

The GDPR gives you certain rights with respect to your personal data. An explanation is available here: https://www.deka.de/privatkunden/konfiguration/footer/datenschutz/rechte-datenschutzgrundverordnung

6.2 In relation to LinkedIn

For information on your data protection rights in relation to LinkedIn and how you can manage or delete the information LinkedIn has about you, see the LinkedIn Privacy Policy at https://de.linkedin.com/legal/privacy-policy?trk=hb_ft_priv and the profile settings in your profile.

6.3 In relation to us and LinkedIn with respect to Page Insights

You can assert the data subject rights explained at https://www.deka.de/privatkunden/konfiguration/footer/datenschutz/rechte-datenschutzgrundverordnung with respect to usage statistics (Page Insights) against both us and LinkedIn.

7. Changes to this Data Privacy Notice

This version of our Data Protection Notice is applicable as of 31/01/2022.

Further development of our Company Page could also affect how personal data is handled. We therefore reserve the right to make future changes to this Data Privacy Notice based on applicable data protection laws and make any adjustments needed as a result of changes in the realities of data processing. We therefore recommend that users visit our Company Page from time to time to take note of any updates to our Data Privacy Notice. We will notify you of updates that make significant changes to our Data Privacy Notice.