Privacy Policy
Last updated: December 23, 2024
Eroica Labs GmbH ("Eroica", "we", "us", or "our") is committed to protecting your privacy in accordance with Swiss data protection law (nDSG - Federal Act on Data Protection) and applicable international standards including GDPR. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.
1. Data Controller
The data controller responsible for your personal data is Eroica Labs GmbH, a Swiss company headquartered in Switzerland. We are subject to Swiss data protection laws and regulations.
2. Personal Data We Collect
We collect information that you provide directly to us and information automatically collected through your use of our services.
- •Account information: name, email address, password, profile picture
- •Community data: memberships, roles, voting history, proposals
- •Transaction data: Eroica Coins balance, donations, project contributions
- •Device information: device type, operating system, unique identifiers
- •Usage data: app interactions, features used, timestamps
- •Communications: support requests, feedback, survey responses
3. How We Use Your Data
We process your personal data for the following purposes:
- •Providing and maintaining our civic participation platform
- •Processing community votes, proposals, and governance activities
- •Managing the Eroica Coins economy and project funding
- •Sending notifications about community activities and updates
- •Improving our services through analytics and research
- •Ensuring platform security and preventing fraud
- •Complying with legal obligations under Swiss law
4. Legal Basis for Processing
Under Swiss data protection law (nDSG), we process your data based on: (a) your consent where explicitly provided; (b) the necessity for the performance of our contract with you; (c) our legitimate interests in operating and improving our platform; (d) compliance with legal obligations. You may withdraw consent at any time without affecting the lawfulness of prior processing.
5. Data Sharing
We share your data only in the following circumstances:
- •With your community: votes, proposals, and profile information you choose to make visible
- •Service providers: hosting, analytics, and support services bound by confidentiality
- •Legal requirements: when required by Swiss law or valid legal process
- •Business transfers: in connection with merger, acquisition, or asset sale with prior notice
6. International Data Transfers
Your data is primarily stored on servers located in Switzerland. When transfers to countries outside Switzerland are necessary, we ensure adequate protection through Swiss-approved Standard Contractual Clauses or equivalent safeguards as required by Swiss data protection law.
7. Your Rights
Under Swiss data protection law (nDSG), you have the following rights:
- •Right to information: obtain details about what data we process
- •Right of access: request a copy of your personal data
- •Right to rectification: correct inaccurate or incomplete data
- •Right to erasure: request deletion of your data (subject to legal retention requirements)
- •Right to data portability: receive your data in a structured format
- •Right to object: oppose processing based on legitimate interests
- •Right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC)
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, typically for the duration of your account plus 5 years for legal and tax compliance purposes under Swiss law. Voting records and community governance data may be retained longer for transparency and accountability.
9. Data Security
We implement appropriate technical and organizational measures to protect your data, including encryption in transit and at rest, access controls, regular security audits, and employee training. Despite our efforts, no system is completely secure, and we cannot guarantee absolute security.
10. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated through the app or via email at least 30 days before taking effect. Continued use after changes constitutes acceptance of the updated policy.
11. Contact Us
For questions about this Privacy Policy or to exercise your rights, contact our Data Protection Officer at [email protected] or write to: Eroica Labs GmbH, Data Protection Officer, Switzerland.
Swiss Law Compliance
This Privacy Policy is governed by Swiss law, specifically the Federal Act on Data Protection (nDSG) and its implementing ordinances. For users in the European Economic Area, we also comply with GDPR requirements. The competent supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland.