1.      General Provisions

1.1.        The protection of your personal data is of the utmost importance to NWG-NFT GmbH. NWG-NFT GmbH therefore complies with the applicable legal provisions on the protection, lawful processing, and confidentiality of personal data as well as on data security, in particular the Austrian Federal Act concerning the Protection of Personal Data (Datenschutzgesetz, “DSG”), the EU’s General Data Protection Regulation (“GDPR”) and the Telecommunications Act (Telekommunikationsgesetz, “TKG”).

1.2.       This Privacy Policy applies to the use of the website www.newworldguardians.com (the “Website”), to whitelisting for the purchase, and to the purchase of digital photographs, images, and other digital works of art by NWG-NFT GmbH which have been individualized as so-called NFTs (non-fungible tokens) (hereinafter called “New World Guardian(s)”), via the Website.

1.3.       This Privacy Policy is regularly updated, amendments will be published on our Website. In order to be aware of the most recent version, you should regularly access the Privacy Policy.

2.          What are personal data?

2.1.        Personal data encompass all information on identified or identifiable persons.

3.          In what context do we process your personal data?

3.1.        NWG-NFT GmbH processes your personal data in relation to (a) the use of the Website, (b) whitelisting and registration, (c) the purchase of “New World Guardians”, (d) the newsletter, and (e) if you contact us.

a.          Processing of your data relating to the use of the Website

i.           Which data do we process?

3.2.        In order to be able to make the Website accessible to you and to detect, prevent, and examine attacks on the Website, we shall gather, collect, and store the following types of data:

–           IP address and IP location;

–           referrer URL (the websites accessed before and after);

–           total number, as well as duration and time of each Website access;

–           name and version of your browser;

–           browser type and settings; 

–           type of device, operating system, monitor resolution; and

–           Internet service provider.

3.3.        Providing this data is required for the use of our Website.

ii.          For what purpose do we process your data?

3.4.        This data is processed relating to your Website use for statistical analyzes and for the purposes of operation, security, and optimization of the Website.

iii.        For how long do we store your data?

3.5.        We store the data for as long as it is required to provide you with unrestricted access to the Website, and/or for as long as it is required for the pursuit of or protection from legal claims or to comply with legal retention obligations.

b.          Processing of your data relating to whitelist entries and registration on the Website

i.           Which data do we process?

3.6.        We process the following personal data for the purpose of registration and whitelisting in order to be able to provide you with an offer for the purchase of “New World Guardians”:

–           your name;

–           your address (place of residence or headquarters);

–           your e-mail address;

–           your Ethereum wallet address.

3.7.        Providing this data is required for you to be added to the whitelist for the purchase of “New World Guardians”. If you do not indicate this data, you will neither be able to register on the Website nor use the whitelist.

ii.          For what purpose do we process your data?

3.8.        We process these data in compliance with (pre)contractual obligations and/or based on our legitimate interests.

iii.        For how long do we store your data?

3.9.        We store the data for the period of whitelisting, i.e., from the time of your registration until the end of the whitelisting phase, and/or for as long as it is required for the pursuit of or protection from legal claims or to comply with legal retention obligations.

c.          Processing of your data for the purchase of “New World Guardians”

i.           Which data do we process?

3.10.   We process the following personal data for you to be able to purchase “New World Guardians”:

–           your first name and last name;

–           your e-mail address;

–           your place of residence or company headquarters;

–           your Ethereum wallet address;

–           your payment details (credit card details);

–           the time and date of your purchase.

3.11.      Providing the above-mentioned personal data is required for you to be able to purchase “New World Guardians”. In case you do not provide the personal data indicated, you will not be able to purchase “New World Guardians”.

ii.          For what purpose do we process your data?

3.12.      We process these data in compliance with (pre)contractual obligations and/or based on our legitimate interests.

iii.        For how long do we store your data?

3.13.      We store the data for the duration necessary to process the purchase process and/or for as long as it is required for the pursuit of or protection from legal claims or to comply with legal retention obligations.

d.          Processing of your data relating to a newsletter subscription

i.           Which data do we process?

3.14.      You can subscribe to our newsletter in order to receive information and offers relating to products and services by Anja Grundböck. We process the following personal data if you subscribe to the newsletter:

–           your first name and last name;

–           your e-mail address;

–           your place of residence or company headquarters;

–           your Ethereum wallet address.

3.15.      Provision of the above-mentioned personal data for the purpose of marketing is effected on a voluntary basis. If you do not provide the personal data for the purpose of marketing and do not give consent, you will not receive any newsletter e-mails.

ii.          For what purpose do we process your data?

3.16.      We process the data based on your consent.

iii.        For how long do we store your data?

3.17.      We store the data until you withdraw your consent. Withdrawal of your consent shall not affect the lawfulness of processing due to the consent given before it was withdrawn.

e.          Processing of your data when you contact us

i.           Which data do we process?

3.18.      If you contact us via the contact form on our Website, e-mail, our social media channels (Facebook, Instagram, Twitter, Discord, and Telegram) or telephone, we will process

–           the personal data you indicated (such as name, user name, telephone number, e-mail, fax number, any documents transmitted, etc.) and

–           your enquiry

for the purpose of processing your enquiry.

ii.          For what purpose do we process your data?

3.19.      We process these data in compliance with (pre)contractual obligations and/or based on our legitimate interests.

iii.        For how long do we store your data?

3.20.      We will store the data for as long as necessary to process your enquiry and/or for as long as it is required for the pursuit of or protection from legal claims or to comply with legal retention obligations.

4.          Will your data be passed on to third parties?

4.1.        We will not pass on the personal data we collected from you to third parties, except in cases in which it is necessary to comply with our obligations, a legal requirement, or ordered by the authorities.

4.2.        We contract service providers that perform services on our behalf (processors). The processors include in particular IT service providers, IT maintenance providers, and marketing service providers as well as providers of similar services. The processors are allowed to process data passed on to them solely according to our instructions and only to the extent required for the performance of services for the above-mentioned purposes. The processors are contractually bound to safeguard the confidentiality and security of the data that are processed in connection with the contract.

5.          Do we use cookies and social plug-ins?

5.1.        Cookies are small text files that are stored on your device. Some of the cookies we use are deleted after the end of your browser’s session, i.e., after closing your browser (so-called session cookies). Other cookies remain on your device and enable us, or our partner companies, to recognize your browser when you next access the Website (persistent cookies). This makes your use of the Website more comfortable.

5.2.        Like most websites, we only use cookies if you have given your consent. If you do not give your consent, we only collect anonymous data on your Website access, e.g., to be able to determine the total number of visitors to our Website.

a.          Borlabs Cookie

5.3.        NWG-NFT GmbH uses Borlabs Cookies based on mainly legitimate interests. The tool uses cookies in order to determine which cookies you chose when accessing our Website. To that end, you are shown a Borlabs Cookie banner when accessing our Website which allows you to consent with or refuse the use of cookies.

5.4.        We use Borlabs Cookies in order to activate exclusively the cookies you chose when accessing our Website.

5.5.        This information is exclusively stored on NWG-NFT GmbH’s servers.

b.          Klick-Tipp

5.6.        Based on your consent, which is asked for when subscribing to the newsletter, NWG-NFT GmbH uses Klick-Tipp, an e-mail analysis service by KLICK-TIPP LIMITED (Klick-Tipp). This analysis tool uses cookies in order to determine whether you have received our newsletters and how you interacted with our newsletters.

5.7.        We use Klick-Tipp to allow us to send newsletters that are as interesting as possible to our e-mail audience. At the same time, Klick-Tipp enables us to determine the reach of our newsletters for statistical and market research purposes.

5.8.        This information is also transmitted to and stored on Klick-Tipp servers in the US or in non-EU states. Should there be no existing adequacy decision by the EU Commission for a certain non-EU state, the data will be transmitted on a case-by-case basis, subject to appropriate safeguards or optionally based on consent for specific purposes.

c.          Meta-Pixel

5.9.        Based on your consent, which is asked for upon your access to our Website on a banner, this Website uses Meta-Pixel, a web analysis service of Meta Platforms, Inc. (“Meta”). The analysis tool uses cookies to trace your activities on our Website if you viewed or interacted with advertisements (“ads”) on one of Meta’s social media platforms (in particular Instagram and Facebook). Subsequently, Meta matches your user data (in particular your IP address and user ID) with the data from your Meta accounts (Instagram, Facebook).

5.10.      We use Meta-Pixel in order to guarantee that our ads on Meta’s social media platforms only reach those users that are actually interested in our products. We can also use Meta-Pixel in order to determine the effectiveness of our advertisements for statistical and market research purposes.

5.11.      Meta uses this information to analyze your use of our Website following an interaction with ads placed on Meta’s social media platforms. Find more information on Meta’s terms of data processing on www.facebook.com/legal/terms. If you are registered and logged into Meta’s social media platforms, you can change your advertisement settings in your profile, under “settings”.

5.12.      This information is (usually) transmitted to and stored on Meta’s servers in the US or in non-EU states. Should there be no existing adequacy decision by the EU Commission for a certain non-EU state, the data will be transmitted on a case-by-case basis, subject to appropriate safeguards or optionally based on consent for specific purposes.

d.          Twitter-Pixel

5.13.      Based on your consent, which is asked for upon your access to our Website on a banner, this Website uses Twitter-Pixel, a web analysis service of Twitter, Inc. (“Twitter”). The analysis tool uses cookies to trace your activities on our Website if you viewed or interacted with advertisements (“ads”) on Twitter. Subsequently, Twitter matches your user data (in particular your IP address and user ID) with the data from your Twitter account.

5.14.      We use Twitter-Pixel in order to guarantee that our Twitter ads only reach those users that are actually interested in our products. We can also use Twitter-Pixel in order to determine the effectiveness of our advertisements for statistical and market research purposes.

5.15.      Twitter uses this information to analyze your use of our Website following an interaction with ads placed on Twitter. Find more information on Twitter’s terms of data processing on https://twitter.com/de/privacy#update. If you are registered and logged into Twitter, you can change your advertisement settings in your profile, under “settings”.

5.16.      This information is (usually) transmitted to and stored on Twitter’s servers in the US or in non-EU states. Should there be no existing adequacy decision by the EU Commission for a certain non-EU state, the data will be transmitted on a case-by-case basis, subject to appropriate safeguards or optionally based on consent for specific purposes.

6.          How do we protect your data?

6.1.        We do everything in our power to make your access to and use of our Website as secure as possible and to safeguard the confidentiality and security of your personal data at any time. We therefore comply with the provisions laid down in Art. 32 GDPR and implement appropriate technical and organizational measures.

7.          What are your rights pursuant to the GDPR?

7.1.        As a data subject, you have the following rights pursuant to the GDPR:

–           The right to access personal data processed by us.

–           The right to rectification of inaccurate data, the right to erasure of your data, and the right to restriction of processing.

–           The right to data portability, which is the right to receive the personal data you provided in a structured, commonly used, and machine-readable format.

–           The right to object to data processing for reasons relating to your particular situation.

7.2.        You can withdraw your consent to the processing of your personal data at any time with future effect. Processing that took place before the withdrawal of your consent shall not be affected by this.

7.3.        You have the possibility to address a complaint to the data protection supervisory authority. The competent data protection supervisory authority is the Austrian Data Protection Authority.

8.          How to contact us

8.1.        Should you have any further questions relating to your personal data, please do not hesitate to contact us at support@newworldguardians.com.