Privacy Policy

Version 1.3 – November 2023

This Privacy Policy explains how we process and protect your personal data when you use this website or our services offered through www.oomnium.com (collectively, the "Website").

The Website is operated by OOMNIUM AG, Talstrasse 9, 8001 Zurich, Switzerland (the "OOMNIUM", "we", "our" or "us"). We are the responsible party for the data processing described below. Unless otherwise defined in this Privacy Policy or our Terms and Conditions, the definitions used in this Privacy Policy have the same meaning as in the Federal Act on Data Protection ("FADP") or the EU General Data Protection Regulation ("GDPR").

For all questions regarding data protection, please feel free to contact us at any time at the following contact addresses:

by e-mail: hello@oomnium.com

1. Personal data we collect

When you use our Website or services, we may collect or receive personal information for a number of purposes related to our business activities. This may include the following:

Contact information (e.g., email, phone, address)
Wallet-address
Know-your-customer (KYC) information (e.g., ID copy, statement of beneficial ownership, photos, selfie-videos)
IP address and log-in data

2. How we collect personal data

We collect information about our users when they use our Website or services, including certain actions on the Website. Further, we may request data about you from third-party registries for KYC verification purposes.

3. Legal bases and purposes of data processing

Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific purposes for which we collect it.

Contract: To perform our contractual obligations or take action in connection with a contract with you. Specifically:

To provide our services.
As part of an application process.

Consent: We may rely on your consent voluntarily given at the time you provide us with your personal information. Specifically:

To provide you with news, special offers, newsletters, and general information about the goods and services we offer.

Legitimate interests: We may rely on legitimate interests based on our assessment that the processing is fair and reasonable and does not outweigh your interests or fundamental rights and freedoms. Specifically:

To maintain and improve our Website and services.
To develop new services.
To provide you with news, special offers, newsletters and general information about the services we offer.

Necessity to comply with legal obligations: To comply with legal and public interest obligations. In particular:

To comply with applicable regulations and laws, in particular from the Anti-Money Laundering Act.

4. Storage time limits

We retain personal information for as long as it is needed for the purposes for which it was collected or in accordance with legal and regulatory requirements or contractual agreements.

5. Third-party service providers

The Company may engage third-party companies ("Service Providers") to facilitate the operation of our Website, assist in analyzing the use of the Website, or provide services related to the Website and our offerings to you, such as payment and the provision of IT infrastructure services. These third parties have access to the user's personal data only to the extent necessary to perform these tasks on behalf of the company.

Type(s) of Service Provider(s) that may access your personal data:

Companies that launch campaigns through our platform.
Professional advisors who assist us in managing the campaigns or otherwise such as legal advisors, notaries, and payment service providers.
Third parties that provide services, such as document processing and translation services, software providers or IT systems, IT support services, and document and information storage providers, service provider for identity and address verification and sanction checks.

6. Data transfers to third countries

We and/or Service Providers may transfer and process your personal data in the following locations:]

In Switzerland
In the EU
In the USA

We may use Service Providers, some of which are located in or process personal data in so-called third countries (outside the European Union or the European Economic Area), i.e., countries whose level of data protection does not correspond to that of the EU.

We protect your personal data in accordance with our contractual obligations and applicable data protection laws when we transfer data abroad.

Such protections may include:

Transfers to countries that provide an adequate level of protection according to the country lists published by the Swiss Federal Data Protection and Information Commissioner, as well as countries for which an adequacy decision has been issued by the European Commission;
Application of standard contractual clauses, binding corporate rules or other standard contractual obligations that ensure adequate data protection.

7. Data transfers

We may disclose your personal data if we believe in good faith that such action is necessary or covered by our legitimate interests:

To comply with a legal obligation (i.e., when required to do so by law or in response to reasonable requests from public authorities, such as a court or government agency);
To protect the security of the Website and defend our rights or property;
To prevent or investigate possible wrongdoing in connection with us;
To defend ourselves against legal liability.
To conduct joint or affiliated campaigns with group companies or other partner companies.

8. Tools and Cookies

Our Website uses the following third party tools:

Meta Pixel, a service of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Meta Pixel is a tool that allows us to measure the effectiveness of our advertising by understanding users' actions on our Website. It helps us implement JavaScript code on our Website to track and dynamically deliver content to Website visitors by setting tracking cookies that help us understand how our Website is being used, as well as advertising cookies so that we can reach customers in the future through Facebook ads. Website visitors are linked to their respective Facebook accounts and identified by the cookies set on their devices. Meta Pixel tracks the URLs and domains visited, as well as the devices used by visitors to the Website. If you would like to learn more about Meta's use of cookies, please read their privacy policy at https://www.facebook.com/privacy/policy/.
Mautic, an open-source marketing automation tool. Mautic is an analytics and tracking software to assign and store usage data (including browser used, last website visited, length of stay). The software uses this information to individualize our marketing efforts and better target the interests of each user. For this purpose, we work together with Friendly Analytics of Friendly GmbH, Werkhofstrasse 5, 6052 Hergiswil, Switzerland.

The way Mautic works is expressed through:
1. Email marketing and campaigns: In so-called email marketing, personalized emails are sent to you. These are partly based on your usage behavior on the Website, when reading our emails, and when interacting with the links contained therein. Furthermore, we also send e-mails as part of campaigns. The allocation to the campaigns is done by segmentations and taggings.
2. Personalized web links to recognize whether, for example, a user calls up a link from an e-mail. For this purpose, Mautic adds a unique identifier to these links, which has previously been assigned to an individual user profile.
3. IP address: The IP address currently used by Website visitors is transmitted to us each time they visit our Website. Mautic uses this to recognize users of the Website.
4. Reports: Reports evaluate performance data on the collected data and display it in aggregated form.
5. The data collected is the activity on our Website, number of page views and time spent on the Website by the visitor, the click path of each visitor, downloads of files provided through the Website, visits to landing pages, openings of emails from newsletters and campaigns.
6. Mautic may set and read the following cookie on your terminal device:
  - "mautic_device_id" (session): Used by Mautic to track the contact either for the tracking pixel or if the same key is not found in the browser's local storage for the monitored website.
  - "mtc_id" (session): Stores the mautic ID of the tracked contact.
  - "mtc_sid" (session): Stores the session of the tracked contact.
7. For more information about Mautic, see Mautic's privacy policy at https://mautic.com/privacy-policy/.
Google Tag Manager: Our website uses Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google Tag Manager"). The Tag Manager is used by us to manage the tools and external services that we use on our website and allows the use of so-called tags. A tag is a code element that is stored in the source code of the website in order to control, for example, which page or service elements and tools are activated and loaded in which order. In some cases, the data is processed on a Google server in the USA.
To know more about Google's data processing, consult its privacy policy here.
Google Ads Remarketing: We use the remarketing feature within the Google Ads service, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. With the remarketing feature, we can present users of our website with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called "Google Ads" or on other websites). For this purpose, the interaction of users on our website is analyzed in order to be able to display targeted advertising to users on other sites even after they have visited our website. For this purpose, Google stores cookies on the end devices of users who visit certain Google services or websites in the Google display network. These cookies are used to record the visits of these users. The cookies are used to uniquely identify a web browser on a specific end device and not to identify a person.
To know more about Google's cookie usage, consult its privacy policy here.
WalletConnect: Our website uses WalletConnect to give you the option of connecting your wallet. When using Wallet Connect, your browser sends encrypted requests to the Wallet Connect servers, which then forward the request to your wallet. When you scan the WalletConnect QR code, your wallet address is transmitted to us. To ensure functionality, WalletConnect stores information in your local storage.
If you would like to find out more about data processing by WalletConnect, please read the privacy policy here.

9. Data Security

We use appropriate technical and organizational security measures to protect your stored data from manipulation, loss or unauthorized access by third parties. Our security measures are continuously adapted in line with technological developments.

We also take internal data protection very seriously. Our employees and the service providers commissioned by us are obliged to maintain confidentiality and to comply with the applicable data protection laws. In addition, they are only given access to personal data to the extent that this is necessary for the fulfillment of their respective tasks or assignment.

The security of your personal data is important to us, but please keep in mind that no method of transmission over the Internet or electronic storage is 100% secure. Although we use commercially reasonable efforts to protect your personal information, we cannot guarantee absolute security. We recommend the use of anti-virus software, a firewall and other similar software to protect your system.

10. Your Rights

You have the following data protection rights. To exercise these rights, you may contact us at the address above. Please note that we may ask you to verify your identity before responding to such requests.

Right of access: You have the right to request a copy of your personal information, which we will provide to you in electronic form.
Right to rectification: You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.
Right to revoke consent: If you have consented to the processing of your personal data, you have the right to withdraw this consent with effect for the future. This also applies in the event that you wish to unsubscribe from marketing communications. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose(s) to which you originally consented, unless there is another legal basis for the processing. To stop receiving emails from us, please click on the "unsubscribe" link in the email you received or contact us at the email address provided.
Right to data portability: You have the right to request that we transfer your personal data in a standard format, such as Excel, to another data processor, provided that it is data that you have provided to us and we are processing it on the legal basis of your consent or to fulfill our contractual obligations.
Right to object to processing: If the legal basis for processing your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will comply with your request unless we have a compelling legal basis for the processing that overrides your interests or we need to further process the personal data for the exercise or defense of a legal claim.
Right to complain to a supervisory authority: You have the right to complain to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law. You are entitled to contact the competent supervisory authority - in Switzerland, the Federal Data Protection and Information Commissioner, Feldeggweg 1, CH - 3003 Bern, info@edoeb.admin.ch.

11. Links to third-party apps and websites

Our Website may contain links to websites or apps that are not operated by us. When you click on a third-party link, you will be directed to that third-party's website or app. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party websites or services.

12. Changes to this privacy policy

We may update our Privacy Policy from time to time. Therefore, we encourage you to periodically review this Privacy Policy for changes.

Changes to this Privacy Policy will become effective when they are posted on this page.

13. Conflict with the German version

Our privacy statement may be available on our Website in several language versions. In the event of any discrepancy between the different versions, the German version shall prevail.