Privacy Policy

Effective Date: January 27, 2025

At Spawn Solutions Ltd. Novi Sad ("we," "us," "our"), we value your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, store, and safeguard your data when you use our website or services. We encourage you to read it carefully to understand how your information is managed and your rights as a data subject.

I General Terms

This Privacy Policy governs all personal data collected and processed by Spawn Solutions Ltd., which acts as the data controller. We are committed to transparency and clarity, ensuring you are fully informed about how we handle your data and empowering you to retain control over your personal information.

By accessing or using our website and services, you confirm that you have read, understood, and agree to the terms outlined in this Privacy Policy. If you do not agree with any part of this policy, please discontinue your use of our website and services immediately.

II Definitions

To provide clarity, the following key terms are used in this Privacy Policy:

• Personal Data: Any information related to an identified or identifiable natural person ("data subject"). An identifiable person is someone who can be identified, directly or indirectly, through identifiers such as a name, ID number, location data, online identifier, or factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

• Data Subject: The individual to whom the personal data pertains.

• Processing: Any action performed on personal data, whether automated or not. This includes collecting, recording, organizing, structuring, storing, adapting, retrieving, consulting, using, disclosing, transmitting, disseminating, aligning, combining, restricting, erasing, or destroying the data.

• Pseudonymization: Processing personal data in a way that prevents it from being attributed to a specific data subject without additional information. This additional information must be stored separately and protected with technical and organizational measures to ensure the data remains unlinked to any identifiable person.

• Controller: The natural or legal entity, public authority, agency, or other body that determines the purposes and means of processing personal data, either alone or jointly with others.

• Processor: A natural or legal entity, public authority, agency, or other body that processes personal data on behalf of the controller.

• Recipient: A natural or legal entity, public authority, agency, or other body to whom personal data is disclosed. Public authorities receiving data as part of a specific inquiry under applicable law are not considered recipients.

• Third Party: Any natural or legal entity, public authority, agency, or body other than the data subject, controller, processor, or individuals authorized by the controller or processor to process personal data under their authority.

• Consent: A data subject's freely given, specific, informed, and unambiguous agreement to the processing of their personal data, expressed through a clear affirmative action or statement.

• Cookies: Small text files generated by a web server and stored on a user's browser to collect and remember information about their activity.

• Google Analytics: A service provided by Google that tracks website performance and gathers insights about visitor behavior and interactions.

III Scope of Data Processing

This Privacy Policy applies to individuals who:

1. Access our website at spawnsolutions.com;

2. Contact us via the email address info@spawnsolutions.com;

3. Subscribe to receive our newsletters.

We process personal data that you voluntarily provide, depending on how you interact with our website or services. Our commitment to your privacy includes the following:

• No sale of personal data: We do not sell your personal information under any circumstances.

• No disclosure to marketing agencies: Your data is not shared with external marketing agencies.

• Limited third-party disclosure: We do not disclose your personal data to any third party, individual, public authority, or company, except as required by law or contract.

IV Data We Collect, Purpose, and Legal Basis

1. Data Collected: Technical Usage Data

We collect technical usage data primarily through cookies and similar tracking technologies. The types of cookies we use include:

• Necessary Cookies: Enable essential website functionality and collect only pseudonymized data.

• Analytical Cookies: Provide insights into how visitors interact with our website, helping us improve content and services.

Purpose of Processing: To understand user behavior and optimize our website for a better user experience.

Legal Basis: Your consent.

Retention Period: Until you revoke your consent. You can adjust cookie settings at any time as explained in our Cookie Policy. Revoking consent does not affect the lawfulness of prior data processing.

2. Data Collected: Contact Details and Inquiries

We collect contact details and any information you choose to share when reaching out via our contact form, email, or other communication channels.

Purpose of Processing: To respond to your inquiries or facilitate communication regarding pre-contractual or contractual matters.

Legal Basis: The processing is necessary for contract execution or pre-contractual steps.

Retention Period: Data will be deleted within 30 days of responding to your inquiry unless legal, contractual, or other justifications require its retention.

3. Data Collected: Newsletter Subscription Information

We collect the contact details of individuals who subscribe to our newsletters.

Purpose of Processing: To send weekly newsletters containing:

• Updates on developments, features, and enhancements to your Web3 platform.

• Insights on blockchain and Web3 trends, market dynamics, and emerging technologies.

• Educational content on blockchain, DeFi, NFTs, and other Web3 concepts through articles, guides, and webinars.

• Real-world use cases, success stories, testimonials, and case studies showcasing the value of your solutions.

Legal Basis: Your consent.

Retention Period: Data is retained until you revoke your consent. You can unsubscribe at any time using the "unsubscribe" link in the email.

V How We Store and Protect Your Data  

We take the protection of your personal data seriously and implement comprehensive administrative, technical, and physical safeguards to prevent unauthorized access, alteration, disclosure, or destruction.

Our security measures include:

• Encrypted Communication: All data transmitted through our website is protected using HTTPS encryption to ensure secure communication.

• Secure Infrastructure: We store your data on secure servers with robust access controls, limiting access to authorized personnel only.

• Regular Security Checks: We conduct regular security audits and vulnerability assessments to identify and address potential risks proactively.

Despite our rigorous efforts to secure your data, it’s important to note that no method of data transmission over the internet can be guaranteed as 100% secure. We continuously monitor and update our security practices to mitigate risks to the best of our ability.

VI Data Processors and Sharing

To carry out specific processing activities, we collaborate with external processors. We only engage processors that provide adequate assurances regarding the implementation of appropriate technical and organizational measures to safeguard your personal data.

Google Analytics

We use Google Analytics to analyze and monitor visitor interactions with our website. This service employs cookies to collect pseudonymized data, such as:

• Pages visited,

• Time spent on the website,

• Other statistical insights into user behavior.

These data points help us enhance the user experience and optimize our website's performance.

Data Sharing

We share limited data with the following processor:

• Google LLC, headquartered in the USA.

This data is handled in compliance with applicable data protection laws, including the use of safeguards for international data transfers, such as standard contractual clauses.

VII Your Rights as a Data Subject

Under the provisions of the Personal Data Protection Act (Official Gazette of the Republic of Serbia, No. 87/2018), you have the following rights regarding your personal data:

1. Right to Withdraw Consent: You may revoke your consent for data processing at any time.

2. Right to Access: You have the right to know whether we process your personal data and, if so, to access that data.

3. Right to Rectification: You can request corrections or updates to your personal data if it is inaccurate or incomplete.

4. Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your personal data if:

1. It is no longer necessary for the purposes for which it was collected or processed.

2. You withdraw the consent on which the processing is based, and there is no other legal basis for processing.

3. Other conditions specified by the Personal Data Protection Act are met.

5. Right to Restrict Processing: You can request a limitation on how your personal data is processed under certain circumstances.

6. Right to Lodge a Complaint:

1. If you have questions or concerns about how we process your data, contact us at info@spawnsolutions.com.

2. If you believe we are processing your data contrary to the law, you can lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection at:

Address: Bulevar kralja Aleksandra 15, Belgrade, 11120.

How to Exercise Your Rights

To exercise any of your rights, please contact us at info@spawnsolutions.com.

• Cost: Exercising your rights is free of charge.

• Response Time: We will respond to your request within 30 days. If your request is complex or we receive a high volume of requests, this period may be extended by an additional 60 days.

VIII Changes to This Privacy Policy

We reserve the right to update this Privacy Policy periodically to reflect changes in data processing practices, legal requirements, or technological advancements.

• Effective Date: All updates will take effect immediately upon publication on our website.

• Notification of Substantial Changes: If significant modifications are made that materially affect how your personal data is processed, we will notify you and, where required by applicable data protection laws, obtain your consent.

If you do not agree with the updated Privacy Policy, we encourage you to discontinue using our website and services and unsubscribe from our newsletter promptly.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, feel free to reach out to us:

• Email: info@spawnsolutions.com

We are here to assist you and address any concerns you may have.

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