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 Platform (“Platform”) 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 Platform.

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 Platform, 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 Platform.

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. Please also note that the collection, use and disclosure of your personal data is essential and necessary to enable your access to and use of the Platform.

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

We may update this Privacy Notice from time to time to reflect changes to our practices, Services or applicable law. For non-material changes, we will update the “Last updated” date and may notify you by email, through the Platform or by other appropriate means. Continued use of the Platform after the effective date of the updated Privacy Notice constitutes acknowledgement of the updated notice. Where a change materially affects how we process your Personal Data, or where applicable law requires consent, we will provide you with appropriate notice before the change takes effect and obtain any consent required by law.

It is important to review this Privacy Notice regularly. You may access the current version of this Privacy Notice at any time after you log in on the Platform by clicking on the “Help” button and then the link marked “Platform Privacy Notice”.

What Personal Data do we collect?

Information you provide.

We collect the Personal Data you provide to us through the Platform. The information we collect is the information you share when logging in on the Platform for the purposes of receiving our Services. For example, when you use the Platform and during your on-boarding process on the Platform, you receive email communications from us, and we collect your email address and any related information you provide.

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.

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 the Platform 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 Platform – which pages they visit, which links they use, and how long they stay on each page;
  • to support the features and functionality of our Platform;
  • to personalize your experience when you use our Platform.

Cookies that are essential for the Platform 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.

Which cookies do we use?

The cookies we use can be classified into two categories.

 “Session cookies” are allocated to your computer for the duration of your visit of our Platform and which will be automatically removed from your computer when you close your browser.

“Persistent cookies” expire after a reasonable period of time or until the user deletes the cookie.

Some cookies are necessary; without these, the Platform will not work. Our use of cookies may also 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 Platform. Third party cookies may collect information about your online activities over time and across different websites following your visit to our Platform.

“Necessary cookies”

Without these cookies, the Platform will not work.

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 Platform. For more information on how to do so, please refer to your browser ‘help’ section or see http:// www.allaboutcookies.org  or http://www.aboutcookies.org.  Although you are not required to accept our cookies when you visit our Platform, if you set your browser to reject cookies, you will not be able to use our Platform.

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 or fraud prevention purposes;
  • to provide you with Service;
  • to provide you with a personalized experience when you use our Services and Platform;
  • 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 improve our Services;
  • for user authentication and authorization;
  • 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 Platform where you provide that information. By providing your Personal Data on the Platform 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. If you wish to exercise any of these rights, please contact us using the contact details below. We will retain your personal data in accordance with the applicable regulatory requirements for archiving, to the extent necessary for audit, dispute resolution and litigation purposes.

If you think we have processed your Personal Data in a manner which is unlawful or breaches your rights, you may report the matter to the Swiss Federal Data Protection and Information Commissioner (FDPIC), and you may also bring a civil action before the competent Swiss courts. Where you have the right under applicable law, such as in the EEA, you may in addition lodge a complaint with your local supervisory authority.

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. 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 Platform is developed with a focus on security, using commercially reasonable best 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 as outlined in the Platform User Terms.

Links to third-party websites/applications

This Platform may contain links to websites or applications operated by other companies, including websites operated by our third-party service providers. 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.

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 Platform or on the relevant third-party websites, which users may access on or from the Platform, 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 Platform to learn about the conditions applicable to the processing of Personal Data since this Privacy Notice applies only to this Platform.

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 where they have a “need to know”. Please know, however, that no matter where your Personal Data is collected, used, transferred or stored, if it was collected through our Platform, it will be processed in accordance with this Privacy Notice.

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

By using this Platform, you are consenting to the collection, use, and transfer of your personal data in or to Argentina, Canada, China, EEA, Guatemala, India, Japan, Mexico, Singapore, South Korea, Switzerland, Taiwan, Uruguay, the USA, Australia, Brazil, Chile, Colombia, Egypt, Indonesia, Morocco, Panama, Paraguay, Peru, UAE, United Kingdom, Vietnam to which we are permitted to transfer that data in accordance with applicable laws.

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

Esplanade de Pont-Rouge 9A, 1212 Lancy, Geneva, Switzerland

legal@covantis.io