This Privacy Policy concerns Onchain Ventures AG and its affiliates and subsidiaries, consisting of Onchain Foundation, Onchain AG, Pass App Limited and Lisk Limited (hereinafter jointly referred to as “Onchain”). Your privacy is important to us. We would therefore like to acquaint you with how we handle the information you send and provide us with during the job application procedure.

First of all, we would like to point out that this is the Privacy Policy regarding the handling of personal data in the context of applications for jobs advertised by Onchain. Independently of or in addition to this Privacy Policy, the general Privacy Policy of Onchain applies when using the Onchain homepage (https://onchain.org/privacy-policy/).

I. Collection, processing and use of your personal data

Your data will be processed in accordance with the Swiss Federal Act of 25 September 2020 on Data Protection (hereinafter referred to “FADP”). The EU General Data Protection Regulation (hereinafter the “GDPR”) would apply as well to the processing of your personal data if you are residing in the European Union.

1. Responsible entity and data protection officer

The entity responsible for collecting, processing and using your personal data in accordance with Art. 5 (j) of FADP is Onchain Ventures AG, Gotthardstrasse 26, 6300 Zug (hereinafter referred to as “Data Controller”).

2. Scope of the data collected

Submitted application documents and other data collected in the course of the application process can personally relate to you as an applicant. As such, they are considered  personal data in the meaning of Art. 5 (a) FADP.

In principle, you yourself decide which data you want to send us with your application. However, we would like to point out that the lack of information about your training and your career path means that we cannot evaluate your application sufficiently with regard to an advertised position with us. Therefore, where some crucial information might be missing from your application, we would not be able to consider it.

In addition, we collect personal data from you during job interviews, which can take place as part of the progress of the application process.

We do not advise you to send us any data that is considered to be sensitive personal data in the meaning of Art. 5 (c) FADP, i.e. information on your religious, political, philosophical or trade union-related views, health, racial or ethnic origin, genetic data, biometric data, administrative and criminal records or social assistance measures.

3. Legal basis for the processing of personal data and their retention periods. 

The collection and processing of your personal data is necessary to reach a decision leading to a potential work relationship. The legal basis for this is Art. 6 (3) FADP. Insofar sensitive data are concerned, the legal basis is Article 6 (6) and (7) FADP. 

Under this legal basis, these data will be kept for the duration of the recruitment process. If your application is successful and we agree on a service agreement, separate data protection agreements and policies will be concluded. If your application is unsuccessful, we might retain your data beyond the recruiting time frame in Onchain’s legitimate interest, e.g.: defense against legal claims, until the expiry of the longest possible limitation period for conceivable claims that may be asserted against Onchain and then deleted immediately.

If you voluntarily provide us with sensitive personal data as part of your application process, the legal basis for the collection and processing is Art. 6 (6) and (7) FADP.

If you disclose personal information about others in your application, you declare and warrant that you are authorized to do so and that you will permit us to use such information in accordance with this Privacy Policy. The processing of this data will be done in compliance with the relevant provisions of the Swiss Federal Act on Data Protection (FADP) and any other applicable legal requirements.

II. Recipients of your personal data and where it is stored 

Insofar as we disclose data to other persons and companies (Data Processors) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this only takes place on the following legal basis: consent Art. 6 (6) and (7) FADP, performance of a contract, a legal obligation, our legitimate interests.

1. Data processors 

The following categories of third-party providers (Data Processors) are used to enable the work of our website and to communicate with you

• Email provider.
• CRM software provider.
• Cloud storage providers.

If you wish to receive a complete and exhaustive list of all companies to which your personal data is transferred to, please contact our legal counsel at legal@onchain.foundation. 

2. Data storage location

The information that we collect from you is transferred, stored, and processed within the EEA, Switzerland, the United States, and in other countries where our Data Processors are located. We will take all reasonable steps to ensure that your personal data is treated securely when transferred outside of the EU, with a level of protection adequate to FADP, GDPR and in accordance with this Privacy Policy.

Whitelisted countries

Switzerland was found to have an adequate level of protection for personal data under European Commission Decision 2000/518/EC of 26 July 2000.

Model clause

If we transfer data to a third party located outside of Switzerland or the EEA which is not in a White Listed Country, as data exporters, we enter into the European Commission’s model contracts (“SCCs”) for the transfer of personal data to third countries (i.e., the standard contractual clauses pursuant to Decision 2010/87/EU) with the relevant data importer. Prior to entering into SCCs we assess, on a case-by-case basis, as outlined in the CJEU decision in Case C‑311/18 [also known as Schrems II] on 16.07.2020, whether an adequate level of data protection, comparably to the level of data protection within the EU is given in the country where the data will be transferred to. If the appropriate level of protection is not given, additional protection provisions and measures will be contractually agreed and/or implemented by us to ensure the protection of personal data.

III. Your rights and storage periods

1. Your rights

Aa a data subject you have the following rights under the legal provisions:  

With regard to the processing of personal data, you may request information from the Data Controller (Art. 25 (1), (2) FADP), have incorrect or incomplete personal data concerning you corrected or completed (Art. 32 (1) FADP) and, in particular, exercise your right to erasure (“right to be forgotten”)(Art. 32 (1) c FADP) . In addition, you may request that the processing be restricted (Art. 32 (1) a FADP)and that the data you disclosed is delivered to you in a conventional electronic format (Art. 28 (1) FADP) or preserved and transferred to another responsible party (Art. 28 (2) FADP).  

You may also object at any time to the future processing of the personal data relating to you provided that there are no compelling legitimate reasons on our part to the contrary.

If you are of the opinion that we have in any way processed your data against data protection laws, please let us know how. You can, in any case, complain to a supervisory authority (Art. 49 FADP). The responsible supervisory authority for data protection issues is the data protection officer of the federal state in which our company is based, which is in our case the Federal Data Protection and Information Commissioner, Feldeggweg 1, 3003 Bern, https://www.edoeb.admin.ch/edoeb/en/home.html.  

2. Storage periods

If the application procedure does not lead to your recruitment, we will regularly delete and destroy your data as soon as a period of 6 months has elapsed after your or our final rejection. 

If your application procedure leads to employment, we will include your application document in your personnel file on the legal basis of Article 6 (6) and (7) FADP. 

IV. Updates of this Privacy Policy

Further development of our website and the implementation of new technologies to improve our recruitment process may require changes to this Privacy Policy. We therefore recommend that you re-read this Privacy Policy from time to time, especially if you re-apply for an advertised position.

V. Disclaimer

The operators of the linked pages are solely responsible for their content. Please note that by clicking on a link you will be redirected to another website or document. These offers can be beyond Onchain’s sphere of influence. Liability is excluded. We refer you to their privacy policy.