DAV Foundation, established in Switzerland (we, us or the Foundation), is committed to protecting and respecting your privacy. This
policy together with any documents relating to the sale of our DAV tokens and any other documents referred to in it sets out the
basis on which any personal data we collect from you, or that you provide to us, will be processed by us. We process your
information in accordance with the Swiss Federal Act on Data Protection (“FADP”) regarding personal data, and you agree that we, as
the data controller, may directly or through our service providers or agents process your information in compliance with this policy
and the FADP. Please read the following carefully to understand our views and practices regarding your personal data and how we
will treat it.
If you do not agree with our policies and practices, your choice is not to use our website, dav.network (Website). By accessing
This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of
those changes, so please check the policy periodically for updates.
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on
the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any
information on this Website or on or through any of its features/register on the Website, make any purchases through the Website,
use any of the interactive or public comment features of this Website or provide any information about yourself to us, including
your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or
received personal information from a child under 13 without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 13, please contact us at [email protected]
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
1Information you give us. This includes any personal information that you give us by filling in forms on the
Website or by corresponding with us by phone, e-mail or otherwise. It also includes information you provide when you register to
use our Website, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a
competition, promotion or survey, contribute to our Token Sale (as defined in the terms of our Token Sale) and when you report a
problem with our site. The information you give us may include your name, address, e-mail address and phone number, date of birth,
financial information, personal description and photograph, crypto-wallets addresses and any other personal data provided to us.
2Information we collect about you. With regard to each of your visits to our site, we will automatically
collect the following information:
aTechnical information, including the Internet protocol (IP) address used to connect your computer to the
Internet, your login information (if applicable), browser type and version, time zone setting, browser plug-in types and
versions, operating system and platform, information about your visit, including the full Uniform Resource Locators (URL),
clickstream to, through and from our site (including date and time), information you viewed or searched for, page response
times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and
mouseovers), methods used to browse away from the page and any information of yours related to contact our customer service
team (e.g. phone number).
bInformation we receive from other sources. This is information we receive about you from public domain, third
parties or other websites we operate or the other services we provide. Third parties we work with include: business partners
that assist in KYC collection and processing, sub-contractors in technical, payment and delivery services, advertising
networks, analytics providers, search information providers and credit reference agencies.
distinguish you from other users of our Website, which helps us to provide you with a good experience when you browse our Website
and also allows us to improve our Website. The cookies we use are session or time-based. You may refuse to accept browser cookies by
activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts
of our Website or severely impact the functionality of the Website. Unless you have adjusted your browser setting so that it will
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic
analytical/performance cookies or targeting cookies.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
1Information you give to us. We will use this information:
a To carry out our obligations arising from any contracts entered into between us and to provide you with the
information, products and services that you request from us;
- b To provide you with information about other goods and services we offer;
- c To provide you with information about goods or services we feel may interest you.
- d To notify you about changes to our service;
e To ensure that content from our Website is presented in the most effective manner for you and for your
2Information we collect about you. We will use this information:
a To administer our Website and for internal operations, including troubleshooting, data analysis, testing,
research, statistical and survey purposes;
b To improve our Website to ensure that content is presented in the most effective manner for you and for your
- c To allow you to participate in interactive features of our service, when you choose to do so;
- e As part of our efforts to keep our site safe and secure;
f To pass information from partners who link to us and partners we link to regarding usage and users for
marketing and advertising purposes;
g To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant
advertising to you;
h To make suggestions and recommendations to you and other users of our site about goods or services that may
interest you or them.
3 Information we receive from other sources. We will combine this information with information you give to us and
information we collect about you and (depending on the types of information we receive) use it as described above.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information:
- 1 With any member of our group, which means our subsidiaries or affiliates.
2 With selected third parties including:
a Business partners that assist with KYC collection of information, suppliers and vendors necessary for the
performance of the services we provide;
b Google Analytics, other analytics providers and search engine providers that assist us in the improvement and
optimisation of our site;
c Fraud and crime prevention agencies for the purpose of assessing the risk of crime, fraud and money laundering
and this is a condition of us entering into any contract with you. This is not an automated decision-making process.
3 To fulfill the purpose for which you provide it. For example, if you give us an email address to use an "email a
friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
- 4 For any other purpose disclosed by us when you provide the information.
- 5 With your consent.
We will also disclose your personal information to third parties:
- 1 As required by law.
2 In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the
prospective seller or buyer of such business or assets.
3 If the Foundation, or substantially all of its assets are acquired by a third party, in which case personal data
held by it about its customers will be one of the transferred assets.
4 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in
rights, property, or safety of the Foundation, our customers, or others. This includes exchanging information with other companies
and organisations for the purposes of fraud protection, money laundering prevention and credit risk reduction.
5 To ensure that we can successfully seek to complete our Token Sale and to meet our legal and contractual
obligations to you related to the Token Sale.
6 To avoid crime, money laundering and the risk of fraud allegations by sharing the information with lawyers,
accountants and other professionals assisting us in these kinds of matters.
7 To ensure that we have relevant information on persons wishing to contribute to our Token Sale by disclosing the
information to third-parties assisting us in verifying and processing customer information like a KYC processing vendor.
8 In order to provide relevant information to regulators, government agencies and banks that may request information
on the Token Sale.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our and our partners performing know-your-client services servers. We do not intend
to keep personal data any longer than is necessary for the purposes for which the personal data is processed and used.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA),
including in particular, Israel, Canada and the United States. It may be processed by staff operating outside the EEA who works for
us or for one of our suppliers. This includes staff engaged in, among other things, the fulfillment of your order, the processing of
your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or
processing. We will take all steps reasonably necessary to ensure an adequate level of data protection and that your data is treated
securely and in accordance with this policy.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect
your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
ACCESS TO INFORMATION
Under the FADP, you also have a right to access your personal data held by us, and it is your responsibility to inform us of any
changes to your personal data to ensure such data remains accurate. You can exercise your right to access your personal data in
accordance with applicable laws and regulations and by contacting the Data Protection Officer at [email protected]
at [email protected].
UPDATED: April 3, 2018