09 Privacy Policy

Privacy Policy

This Privacy Policy has been updated as of April 2, 2019.

Privacy Policy Golem Factory GmbH

We are delighted that you have shown interest in Golem and Golem Factory GmbH (the “Company”). Data protection is of a particularly high priority for us. The use of the Internet pages of the Company is possible without any indication of personal data; however, if a data subject wants to use services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject shall always be in line with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the Company. By means of this data protection declaration, the Company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Company has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

Definitions

This Privacy Policy of the Company (the “Privacy Policy”) is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (“GDPR”). Our Privacy Policy should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this Privacy Policy, we use, inter alia, the following terms:

Personal data

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

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Data Protection Officer

The Data Protection Officer is an employee, third-party individual or third-party entity designated by the Company to fulfil the tasks according to Article 39 GDPR. The Company reserves its right to not assign a Data Protection Officer if such assignment is not required by the applicable laws. In this case, the Company will designate a person responsible for the tasks assigned to the Data Protection Officer as described herein.

Processing

Processing is 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.

Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation

Pseudonymisation is 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 or controller responsible for the processing

Controller or controller responsible for the processing is 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

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, 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

Third party is 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

Consent of the data subject is 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. Name and Address of the Controller Controller for the purposes of the GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Golem Factory GmbH

Gotthardstrasse 26

6300 Zug

Switzerland

privacy@golem.network

Legal Basis for the Processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our Company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our Company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR). Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

Cookies

The Internet pages of the Company use cookies. Through the use of cookies, we can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. Cookies are text files that are stored in a computer system via an Internet browser. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie. The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable. The processing of the information by using cookies is based on the legitimate interests of the Company pursuant to Article 6(1) lit. f GDPR.

Collection of General Data and Information When Visiting our Website

The website of the Company collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using these general data and information, the Company does not draw any conclusions about the data subject. Rather, this information is needed to (1) provide our products and services, including our Apps and this Site, and improve them over time, (2) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, (4) personalize and manage our relationship with you, including introducing you to products or services that may be of interest to your or to provide customer support, (5) investigate, respond to, and manage inquiries or events, and (6) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Company analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject. The general data and information collected will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. The processing of the information by collecting general data and information is based on the legitimate interests of the Company pursuant to Article 6(1) lit. f GDPR.

External Network Monitor

The Company maintains an external network monitor that shows various network statistics of the Golem Network and displays them to the public. The external network monitor allows the Company to gather data regarding functioning of the network and nodes in order to constantly improve and upgrade the network protocol and the Golem application. When the user downloads and installs the Golem application, he or she will be asked during the installation procedure whether he or she wishes to contribute certain information about his or her node and the usage of the application to the external network monitor. If the user decides to opt-in to contribute network statistics to the Company, the following information relating to the user’s use of the application (“External Statistics”) will be transferred to the Company and published on https://stats.golem.network/ui/:

  • Node ID
  • Node Name
  • Node Version
  • Last Time Seen
  • Operating System
  • Network IP
  • Start Port
  • End Port
  • Performance Indexes
  • Allowed Resource Size
  • Allowed Resource Memory
  • CPU Cores
  • Minimum Price
  • Maximum Price
  • Subtasks Completed with Success
  • Subtasks with Error
  • Subtasks with Timeout
  • P2P Protocol Version
  • Task Protocol Version
  • Number of Tasks Requested
  • Number of Known Tasks
  • Number of Supported Tasks
  • Requestor Statistics, including tasks, finished tasks, requested subtasks, collected results, verified results, subtasks with timeout, downloadable tasks, failed subtasks, work offers)
  • Provider Statistics, including requested subtasks, received subtasks, total time between subtask request and assignment

The storing and publishing of the External Statistics is required in order to display it on the external network monitor. The user understands that the External Statistics published on the external network monitor are available to the public, including individuals and legal entities that do not use the Golem Network. The External Statistics transferred to the Company will be updated on a regular basis and therefore continuously replaced with more current information. This means that the external monitor represents a real time reflection of the Golem Network and that all the data displayed in the external monitor is being overwritten in real time. The processing of the information by storing and publishing the External Statistics on the external network monitor is based on the user’s consent pursuant to Article 6(1) lit. a GDPR. The user shall have the right to withdraw his or her consent at any time. If the user wishes to end his or her contribution of External Statistics to the external network monitor, he or she can opt out by using the command line interface of the Golem application. In this case, the information will be immediately excluded from being displayed on the network monitor.

Internal Network Monitor

The Company maintains an internal network monitor that collects various network statistics of the Golem Network. The internal network monitor allows the Company to gather data regarding functioning of the network and nodes in order to constantly improve and upgrade the network protocol and the Golem application. The network statistics stored in the internal network monitor are also used to improve the performance of the Golem Networks but are more informative and accurate than the External Statistics. When the user downloads and installs the Golem application, he or she will be asked during the installation procedure whether he or she wishes to contribute certain information about his or her node and the usage of the application to the internal network monitor. If the user decides to opt-in to contribute network statistics to the Company, the following information relating to the user’s use of the application (“Internal Statistics”) will be transferred to the Company and stored on its internal servers:

  • Node ID
  • Node Name
  • Node Version
  • Last Time Seen
  • Operating System
  • Network IP
  • Start Port
  • End Port
  • Performance Indexes
  • Allowed Resource Size
  • Allowed Resource Memory
  • CPU Cores
  • Minimum Price
  • Maximum Price
  • Subtasks Completed with Success
  • Subtasks with Error
  • Subtasks with Timeout
  • P2P Protocol Version
  • Task Protocol Version
  • Number of Tasks Requested
  • Number of Known Tasks
  • Number of Supported Tasks
  • Requestor Statistics, including tasks, finished tasks, requested subtasks, collected results, verified results, subtasks with timeout, downloadable tasks, failed subtasks, work offers)
  • Provider Statistics, incliding requested subtasks, received subtasks, total time between subtask request and assignment
  • OS version
  • OS release date
  • OS edition
  • Public key
  • Provider incomes statistics
  • Requestor payments statistics
  • Marketplace statistics

The storing of the Internal Statistics on the servers of the Company is required to display it on the internal monitor and to analyze it in order to improve the performance of the Golem Network. In contrast to the External Statistics, the Internal Statistics are not replaced with but rather continuously enhanced by more current information. The internal monitor is therefore a historical reflection of the Golem Network, providing the Company with an overview of everything that has happened on the Golem Network in the past. The Internal Statistics are not available to the public and are not being shared with third parties. The processing of the information by storing the Internal Statistics on the internal network monitor is based on the user’s consent pursuant to Article 6(1) lit. a GDPR. The user shall have the right to withdraw his or her consent at any time. If the user wishes to end his or her contribution of information to the network monitor, he or she can opt out by using the command line interface of the Golem application. To delete personal data that has already been submitted to the Company, the user can contact the Controller.

Sentry Service for Error Tracking

The Company uses an open-source error tracking service called Sentry that is offered by Functional Software, Inc. domiciled in San Francisco and provides real-time error tracking for web applications Sentry (“Sentry Sentry”). The information collected by the Sentry Service and provided to the Company gives the Company the insight needed to reproduce and fix crashes that happen in the Golem Network. When the user downloads and installs the Golem application, he or she will be asked during the installation procedure whether he or she wishes to contribute information about errors happening in his or her node to the Sentry Service, including the node name. If the user decides to opt-in to contribute such error information, all errors that happen in the user’s nodes as well as the name of the node are automatically sent to the Company (“Error Information”). All other data related to the error is filtered and encrypted so that the Company is not able to access it. The Error Information sent to the Company is subsequently stored on the Company’s servers in the form of logs. The storing of the Error Information on the servers of the Company is required for the Company to be able to prioritize the most common errors that happen in the Golem Network and fix them in the proper order. The Company will delete the Error Information as soon as it is no longer required for the purpose for which it was collected. The Error Information is not available to the public and is not being shared with third parties. The processing of the information by storing the Error Information on the servers of the Company is based on the user’s consent pursuant to Article 6(1) lit. a GDPR. The user shall have the right to withdraw his or her consent at any time. If the user wishes to end his or her contribution of information to the network monitor, he or she can opt out by using the command line interface of the Golem application.

Contact Possibility via the Website

The website of the Company contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

Bug Bounty Reports

The Company may invite the community to join so called Bug Bounty competitions (“Competitions”) during which community members (“Participants”) can report software bugs and other technical issues in connection with the Golem Project. To participate in a Competition, the Participants are required to submit a bounty application to the Company. The personal data sent to the Company as part of a bounty application will be automatically stored by the Company and used to determine the distribution of the Bug Bounty among the various Participants. In addition, Participants may be contacted by email in case such contact is necessary for the execution of the respective Competition or the distribution of a Bug Bounty to the Participant. There will be no transfer of personal data collected during a Competition to third parties. The participation in a Competition may be terminated by the Participant at any time. The consent to the storage of personal data, which the Participant has given by participating in a Competition, may be revoked at any time by contacting the Controller. The processing of the personal data sent to the Company in a bounty application is based on the Participant’s consent pursuant to Article 6(1) lit. a GDPR. The Participant shall have the right to withdraw his or her consent at any time.

Traffit Service for Job Applications

The Company uses a cloud-based recruitment software program called Traffit which offers a complete set of features that allow the Company to acquire candidates, manage its candidate base, publish new job advertisements, set up application forms, manage applications, communicate with candidates, and generate detailed reports. When the user applies for a job on our website he or she will be forwarded to the Golem Traffit form where the user will be asked to provide the following information:

  • Name and Surname
  • CV
  • Current Location
  • Financial Expectations

The Golem Traffit form as well as the personal information that is entered by the user when applying for a job are kept on servers that are provided by Amazon Web Services and located in Ireland and Germany. The personal data provided by the user will be deleted from these servers after a period of two years. The processing of the personal data sent to the Company as part of a job application is based on the user’s consent pursuant to Article 6(1) lit. a GDPR. To delete personal data that has already been submitted to the Company as part of a job application, the user can contact the Controller.

Web Analysis by Google Analytics and Inspectlet

On our website we use Google Analytics, a web analysis service of Google Inc. ("Google"). The legal basis for processing users' personal data as set forth below is art. 6 (1) (f) GDPR. Google Analytics uses the following cookies which may be saved on the user's computer and which enable an analysis of the use of the website:

  • _ga – persistent cookie, deleted after two years
  • _gid – persistent cookie, deleted after 24 hours
  • _gat – persistent cookie, deleted after 1 minute
  • AMP_TOKEN – persistent cookie, deleted after 30 seconds to 1 year
  • gac - persistent cookie, deleted after 90 days
  • __utma – persistent cookie, deleted after 2 years from set/update
  • __utmt – persistent cookie, deleted after 10 minutes
  • __utmb – persistent cookie, deleted after 30 minutes from set/update
  • __utmc – session cookie, deleted when visit is over
  • __utmz – persistent cookie, deleted after 6 months from set/update
  • __utmv – persistent cookie, deleted after 2 years from set/update
  • __utmx – persistent cookie, deleted after 18 months
  • __utmxx – persistent cookie, deleted after 18 months
  • _gaexp – persistent cookie, deleted after approx. 90 days (depends on experiment)

If individual pages of our website are accessed, the following data is collected and stored by Google:

  • The IP address of the user's calling system
  • The accessed website
  • The website from which the user has accessed the accessed website (referrer)
  • The sub-pages accessed from the accessed website
  • The time spent on the website
  • The frequency with which the website is accessed

To ensure that any personal reference can be excluded when processing your IP address, we have activated the "_anonymizeIp()" function at Google Analytics. As a result, IP addresses are not stored completely and are only processed further in abbreviated form. As far as the data collected about you contains a personal reference, this will be excluded, and the personal data will be deleted immediately. The information generated by Google’s cookies about your use of this website is usually transferred to a Google server in the USA and stored there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use. Google will shorten the user's IP address within member states of the European Union or in other signatory states to the Agreement on the European Economic Area prior to transmission. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user's browser within the scope of Google Analytics is not merged with other Google data. We have concluded a data processing agreement with Google and fully implement the strict requirements of the GDPR for the use of Google Analytics.

Web Analysis by Inspectlet

On our website we use the software tool Inspectlet which is operated by Inspectlet, Santa Clara, USA (“Inspectlet”). The legal basis for processing users' personal data as set forth below is art. 6 (1) (f) GDPR. The users have to option to opt-out of data collection by Inspectlet by visiting https://www.inspectlet.com/optout. Inspectlet creates and stores the following cookies on the user's computer which enables us to analyze the use of our website:

  • __insp_sid - session cookie, deleted when visit is over
  • __insp_ref - session cookie, deleted when visit is over
  • __insp_scpt - session cookie, deleted when visit is over
  • __insp_nv - session cookie, deleted when visit is over
  • __insp_wid - session cookie, deleted when visit is over
  • __insp_identity - session cookie, deleted when visit is over
  • __insp_uid – persistent cookie that contains random ID assigned to visitor

If individual pages of our website are accessed, the following data is collected and stored by Inspectlet:

  • Current URL
  • Country
  • Time zone
  • Browser type and version
  • Device type and version
  • Operating system type and version
  • Referrer URL
  • Screen size
  • User last seen date
  • Mouse activity including pixel coordinates for mouse movements and clicks and keyboard activity typed into non-sensitive input fields.
  • HTML content that isn't marked as sensitive content

The data collected by Inspectlet is stored in the AWS US East data centers in Virginia for a period of three months and is permanently deleted from the data centers on a rolling basis when it becomes older than the retention policy for that data. All data is encrypted during transmission and collected data is stored encrypted at rest using AES encryption. To ensure that any personal reference can be excluded when processing your IP address, we have activated the "Automatically Anonymize Visitor IPs" function at Inspectlet. As a result, IP addresses are not stored completely and are only processed further in abbreviated form.

Routine Erasure and Blocking of Personal Data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Rights of the Data Subject

Right of Confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the Data Protection Officer.

Right of Access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may at any time contact the Data Protection Officer.

Right to Rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact the Data Protection Officer.

Right to Erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary: The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed. The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been unlawfully processed.

The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Company, he or she may at any time contact the Data Protection Officer. The Data Protection Officer shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer will arrange the necessary measures in individual cases.

Right of Restriction of Processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies: The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Company, he or she may at any time contact the Data Protection Officer. The Data Protection Officer shall arrange the restriction of the processing.

Right to Data Portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer.

Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. The Company shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If the Company processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Company to the processing for direct marketing purposes, the Company will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Company for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications. Automated Individual Decision-Making, including Profiling Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Company shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer.

Right to Withdraw Consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact the Data Protection Officer.

Provision of Personal Data as Statutory or Contractual Requirement

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact the Data Protection Officer. The Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

Changes to this Privacy Policy

This Privacy Policy will be updated from time to time to reflect legal changes, customer feedback, and changes related to the Golem Project and our services. When we make changes to this Privacy Policy, we will revise the “Effective Date” at the top of the Privacy Policy and will describe the changes in the Change History page which is accessible under Privacy Policy history. If there are any material changes to this Privacy Policy regarding the way we process your personal data, we will notify you either by sending you a notification or posting a notice of such changes on our website and/or in the Golem application before they take effect. We encourage you to periodically review this Privacy Policy to learn how we process your personal data.