Privacy Notice

Commitment To Privacy

Your privacy is important to us. This Privacy Notice (“Privacy Notice”) explains how we protect your privacy when you use our website (our “Site”) and associated services, sign up to communications from us and participate in events organized by us or in which we are participating (“Services”). This Privacy Notice describes what types of information we gather and track when you use our Services, how this information is used and with whom it is shared. If you have any questions about this Privacy Notice, please contact us.

Covantis is a Swiss based company whose purpose is to develop and operate a software platform for digitalizing post-trade execution of international agriculture commodity trading (jointly referred to in this Privacy Notice as “Covantis,” “we,” “us,” and “our”).

Scope of this Privacy Notice

This Privacy Notice covers the “Personal Data” we collect. “Personal Data” is information that identifies you personally, either alone or in combination with other information available to us. Examples of Personal Data include your name, contact details and information about the pages you have viewed and the path you have taken through our Site.

Your Consent and other legal basis for using your Personal Data

Please take a few minutes to review this Privacy Notice. By providing your Personal Data or accessing or using our Site, you are consenting to the collection, use and disclosure of your Personal Data as set forth in this Privacy Notice, to the extent permitted by applicable law.

IF YOU DO NOT CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AS SET FORTH IN THIS PRIVACY NOTICE, PLEASE EXIT AND DO NOT USE OUR SITE.

WHERE YOU HAVE THE RIGHT UNDER APPLICABLE LAW, SUCH AS IN THE EEA, YOU MAY ALSO WITHDRAW YOUR CONSENT AT ANY TIME BY CONTACTING US. PLEASE NOTE THAT IN THE EVENT THAT YOU WITHDRAW YOUR CONSENT, WE MAY STILL BE REQUIRED OR PERMITTED BY LAW TO COLLECT, USE AND DISCLOSE SOME OR ALL OF YOUR PERSONAL DATA.

We also collect, use and disclose your Personal Data where it is necessary for the performance of a contract with you or where it is necessary for our legitimate interests of operating, protecting and improving our Services.

Changes to This Privacy Notice

As we add new features and functionality to our Services, we may need to update or revise this Privacy Notice. We reserve the right to do so, at any time and without prior notice, by posting the revised version on our Site. These changes will be effective as of the date we post the revised version on our Site. They will apply only to the Personal Data we collect after we have posted the revised version. Your use of our Services following any such change constitutes your consent to the terms of the revised Privacy Notice. For this reason, it is important to review this Privacy Notice regularly.

You may access the current version of this Privacy Notice at any time by clicking on the link marked “Privacy” at the bottom of each page of our Site.

What Personal Data Do We Collect?

Information You Provide. We collect the Personal Data you provide to us through our Website. The information we collect depends on how you use our Services. For example, if you sign up to receive email communications from us, we collect your email address and any related information you provide. If you communicate with us using a “Join Us” feature, we collect the information you provide when you complete any “Join Us” form.

Generally, we distinguish between information we need to provide you with a particular service or to fulfill your request (“mandatory fields”), and information that although useful is optional with respect to that particular service or your request. Please be aware that if you do not provide us with mandatory fields we will not be able to provide you with the service or fulfill your request.

Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your Web browser. This information typically includes your IP address, the identity of your Internet Service Provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. An “IP address” is a unique number that is automatically assigned to your computer when you connect to the Internet. It is used to identify your computer’s “location” in cyberspace, so that the information you request can be delivered to you. If you use a dial-up connection or a connection that assigns dynamic IP addresses, your computer will be assigned a new IP Address each time you connect to the Internet. If, however, your computer is permanently connected to the Internet using a static IP address, the IP address assigned to your computer will generally be the same each time you use your computer. Although it does not identify you by name, we treat your IP address as your Personal Data.

You should be aware that when you respond to an electronic communication you receive from us, for example, by opening an email, downloading images or clicking on a link in an electronic newsletter, your browser tells us that you (or someone using your email address) has done so. We use this information to improve our marketing efforts. In addition, we review our server logs – which contain visitors’ IP addresses – for security and fraud prevention purposes. If criminal activity is suspected, we may share our server logs and the Personal Data we have collected through this Site with the appropriate investigative authorities who could use that information to trace and identify individuals.

Cookies and Similar Technologies. A cookie is a small file sent by a website and stored on a user’s computer which enables the website to remember information about you and your preferences. We use “cookies” and other Web technologies in a number of ways. For example, we may use these technologies

• to collect information about the ways visitors use our Site – which pages they visit, which links they use, and how long they stay on each page;
• to support the features and functionality of our Site;
• to personalize your experience when you use our Site; and
• to measure the success of our web or email advertising.

Cookies that are essential for the Site to operate will be used. For other cookies, we will obtain consent before using cookies where it is required by applicable data protection law. You may withdraw your consent at any time via accessing this Privacy Notice and following the link provided.

The cookies we use can be classified into two categories:

• “Session cookies” which are allocated to your computer for the duration of your visit of our Site and which will be automatically removed from your computer when you close your browser.
• “Persistent cookies” which expire after a reasonable period of time or until the user deletes the cookie.

Some of these cookies may include analytics cookies, which tell us how our Site is working. We use Google analytics cookies to monitor the performance of our Site. Our ability to use and share information collected by Google Analytics about your visits to our Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Our use of cookies may involve the use of “third party cookies”; that is, cookies that are set by software used by third parties, such as to carry out statistical analysis of page use, page interactions and paths through the site. Third party cookies may collect information about your online activities over time and across different websites following your visit to our Site.

Generally, the information collected using these Web technologies does not identify you by name.

If you do not wish to receive cookies, in addition to controlling their use via this Privacy Notice, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave the Site. For more information on how to do so, please refer to your browser ‘help’ section or see allaboutcookies.org or aboutcookies.org. Although you are not required to accept our cookies when you visit our Site, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of our Site.

Except as otherwise disclosed in this Privacy Notice, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different websites following your visit to our Site.

How Do We Use Your Personal Data?

Generally, and subject to applicable privacy laws, we use the Personal Data we collect

• to provide information and services you request;
• for security, credit or fraud prevention purposes;
• to provide you with Services;
• to provide you with a personalized experience when you use our Services;
• to contact you with information we believe will be of interest to you, subject to applicable requirements related to marketing consent;
• to contact you with information and notices related to your use of our Services;
• to invite you to participate in surveys and provide feedback to us;
• to better understand your needs and interests;
• to improve the content, functionality and usability of our Site;
• to improve our Services;
• to improve our marketing and promotional efforts; and
• for any other purpose identified in an applicable Privacy Notice or other agreement between us and you.

To Whom Do We Disclose Personal Data?

We may share the Personal Data we collect as described below:

Our Service Providers. We may share Personal Data with companies and organizations that perform services on our behalf, for example, companies that provide website support.

Compliance With Laws and Protection of Our Rights and the Rights of Others. We may disclose Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose Personal Data to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

As Described in a Privacy Notice. We reserve the right to disclose your Personal Data as described in any Privacy Notice posted on the Web page where you provide that information. By providing your Personal Data on that Web page you will be consenting to the disclosure of your Personal Data as described in that Privacy Notice.

Your Choices

In some circumstances, we give you choices about the ways we collect, use and disclose your Personal Data. If so, we may ask you to indicate your choices at the time we collect your Personal Data.

How Can You Access, Update or Correct Your Personal Data?

If you wish to access, update or correct your Personal Data, please contact us at legal@covantis.io. We will respond to you within a reasonable time and within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identity.

Your Rights

In some circumstances, you have a right to request the erasure of your Personal Data or to ask for a restriction on its use, to object to its use, to receive it in a portable format or to have it transmitted to another organization. You may also request that we no longer send you direct marketing communications. If you wish to exercise any of these rights, please contact us at legal@covantis.io.

Where you have the right under applicable law, such as in the EEA, you may complain to a Data Protection Authority if you think we have processed your Personal Data in a manner which is unlawful or breaches your rights.

How Long Do We Retain Your Information?

We may keep your Personal Data for as long as is necessary for our business purposes, and in particular to protect ourselves in the event of a legal claim. After this period, your Personal Data will be deleted or, in some instances, pseudonymized or anonymized, as permitted by applicable law. If you subsequently withdraw your consent and we have no other lawful basis to continue processing your Personal Data, we will delete your Personal Data.

Security

We take the confidentiality, integrity and security of your Personal Data seriously. Accordingly, the Covantis platform is being developed with a focus on security, using commercially reasonable practices in security design and technology, for companies of our size and type. However, as security risks cannot be entirely eliminated, we urge users to remain vigilant about protecting their Personal Data when using the Services.

Links to Third-Party Websites

This Site may contain links to websites operated by other companies, including websites operated by our third-party service providers, and unrelated third parties. This Privacy Notice does not apply to Personal Data collected on any of these other websites as such Personal Data are subject to third parties’ terms. We bear no responsibility for the practices of such third parties.

An example of links to third-party websites are plug-ins that may connect our Site to social networks like Facebook or Twitter (‘social plug-in’) and that are usually identified by the relevant social network’s logo. If you interact with a social plug-in on our Site, your browser may send such social network certain data relating to you, such as information on the Site, date and time, and other browser-related information. Such information will be processed by the social networks, owned and operated by third parties, according to their privacy policies.

We do not have access nor control over elements, objects, plug-ins, cookies, web beacon and other items or tracking technologies owned and operated by third parties, available on our Site or on the relevant third-party websites, which users may access on or from the Site, and over the relevant methods of processing of Personal Data through such elements or sites. We disclaim any responsibility for such websites. You should check the privacy policy of third-party websites and elements accessed from the Site to learn about the conditions applicable to the processing of Personal Data since this Privacy Notice applies only to this Site.

HubSpot

We use the services of Hubspot to send newsletters and other wide communication.

Hubspot is a service which organizes and analyzes the distribution of newsletters and wide communication. When you provide Personal Data (e.g. your email address) to subscribe to our newsletter, it will be stored on HubSpot servers in Germany.

We use HubSpot to analyze our newsletter campaigns. When you open an email sent by HubSpot a file included in the email (called a web beacon) connects to HubSpot’s servers in Germany. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address and browser type). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests.

If you do not want your usage of the newsletter to be analyzed by HubSpot, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send.

Data processing in this case is based on consent. You may revoke your consent at any time by unsubscribing to the newsletter. The Personal Data processed before we receive your request may still be legally processed.

The Personal Data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said Personal Data will be deleted from our servers. Personal Data we have stored for other purposes remains unaffected.

For further details, see the https://legal.hubspot.com/privacy-policy.

Children’s Privacy

Our Site is not directed at children under the age of 18. We do not use our Site to knowingly solicit Personal Data from or market to children under the age of 18, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.

International transfers

Covantis is a global initiative and we may transfer your Personal Data across national borders for the purposes described in this Privacy Notice. Our Web servers and databases are located in Switzerland, Ireland, Germany, France and the Netherlands and the information on these servers and databases may be accessed by or staff of our service providers located in other countries in accordance with applicable laws. Please know, however, that no matter where your Personal Data is collected, used, transferred or stored, if it was collected through our Site, it will be processed in accordance with this Privacy Notice.

With respect to Personal Data from the EEA, it is our practice to implement means of providing appropriate safeguards for Personal Data transferred from the EEA to outside the EEA.

BY USING THIS SITE, YOU ARE CONSENTING TO THE COLLECTION, USE, AND TRANSFER OF YOUR PERSONAL DATA IN OR TO THE UNITED STATES, UNITED KINGDOM, IRELAND, GERMANY, FRANCE AND THE NETHERLANDS.

WHERE YOU HAVE THE RIGHT UNDER APPLICABLE LAW, SUCH AS IN THE EEA, YOU MAY WITHDRAW YOUR CONSENT AT ANY TIME BY CONTACTING US. PLEASE NOTE THAT IN THE EVENT THAT YOU WITHDRAW YOUR CONSENT, WE MAY STILL BE REQUIRED OR PERMITTED BY LAW TO COLLECT, USE AND DISCLOSE SOME OR ALL OF YOUR PERSONAL DATA IN ACCORDANCE WITH APPLICABLE LAWS.

Contact us

If you have questions about this Privacy Notice or our privacy practices, or if you want to exercise your rights or withdraw your consent, you can contact us at:

COVANTIS SA
Rue des Contamines 18
1206, Geneva, Switzerland
legal@covantis.io