Privacy Policy

Be-Leader d.o.o.

PRIVACY INFORMATIVE
pursuant to Art.13 of the EU Regulation 2016/679 (hereafter, “GDPR”) regarding the Processing, Protection and Transfer of Personal Data

INFORMATIVE PRIVACY
In the quality of Data owner and Controller Be-Leader d.o.o. represents  the following.

1. GENERAL INFORMATION ON TREATMENT
The following describes how to manage the www.waco-token.com site and the app called “WaCo APP” with reference to the processing of users’ personal data. The information is made pursuant to Article 13 of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data, as well as the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), to those interacting with web services, accessible electronically from the address mentioned corresponding to the initial page of the website www.waco-token.com  The information is made only for the aforementioned site and its app not for other websites that may be consulted by the user through links.

2. OWNER AND MANAGERS
The data controller is Be-Leader d.o.o. with headquarter in Belveder,4 6000 Koper (SLO), in the person of the Director who must be able to process your personal data in order to be able to deliver the requested services and performance; therefore, in accordance with Article 13ofEU Regulation 2016/679 (GDPR), with this document provides the information referred to in this disclaimer.
The Data Controller can be contacted at the following e-mail address:  info@beleadersrl.com
The updated list of data controllers, where designated, can be provided at the request of the Data Subject.

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING
The processing of your data will be carried out in order to proceed with a correct management ofthe   contractual relationship that is established with its registration to WaCo APP program and download and the consequent acceptance of the contractual terms and this information, for the visit of the web page and the connected app, as well as for all the necessary ordinary and extraordinary management activities, including communications.  The principle of legal lawfulness is therefore identified in Art. 6 paragraph 1 lit. b) of the GDPR, and all related legal obligations to which the Data Controller is subject as well as that of his express consent to the processing, freely provided at the time of accession.

4. METHODS OF PROCESSING AND SCOPE OF DISSEMINATION
The processing will be carried out with paper, electronic and IT tools with logics closely related to the purposes indicated above and will be stored on computer media, adopting organizational, physical and logical measures to ensure the security of data. The data will be stored in EU territory and will not be used and are not closely related to the purposes for which they are delivered.

The software applications responsible for the operation of the website www.waco-token.com  acquire some personal data transmitted through secure protocols. This information  is not collected to be associated with identified data subjects, but could, through processing and associations with data held by third parties, allow users to be identified. This category of data includes ip addresses, user agent identifier, uniform resource identifier (URI) address of the requested resources, request time, method used to submit the request to the server, numeric code indicating the status of the server’s response (e.g. successful, error), and other parameters related to the user’s operating system and it environment. This data is used for the purpose of obtaining anonymous statistical information about the use of the site and to check its proper functioning.
From the website and the app of Be-Leader d.o.o. you can directly access other sites. The data subject is therefore made known that, passing to other sites, the processing of his personal data comes out of the availability of this Data Controller and these data will be available to another manager.

5. NATURE OF DATA PROVISION AND DURATION OF PROCESSING (DATA RETENTION)
The provision of consent to the processing for the purposes referred to in point 3 is mandatory by law. Any refusal will, however, make it impossible to follow up relations with  the Data Controller. The data retention period is established by regulatory obligations to which the Data Controller must submit on the basis of current tax regulations. In any case, your personal data will be deleted from all our archives three years after the last use of the app or access to the site, unless legal obligations.

6. COMMUNICATION AND DISSEMINATION
Our associates, suppliers and collaborators may become aware of your data and, as data controllers and/or data controllers, are authorized to process them for the purposes indicated in this information and social purposes.
Your data may be processed in particular by the employees of the following offices: Administration, Information Technology, Investor Relation, Legal, who will have access as data controllers.
The data processed will not be otherwise disseminated in any way nor will they be the subject of profiling.

7. RIGHTS OF THE PERSON CONCERNED
You can exercise the rights of access to personal data provided for in art. 15 of the GDPR, as well as the rights provided for in Art. 16, 17, 18, 21 of the Regulation itself with regard to the correction, cancellation, limitation and opposition to processing, in the manner laid down in art. 12 of the GDPR.
The aforementioned rights may be exercised with a request addressed without formalities, also through an appointee, through a request to be forwarded directly to the data controllerand/or the DPO where appointed.
For what is not expressly indicated in this policy, reference is made to current regulations.

8. RIGHT TO LODGE A COMPLAINT UNDER ART. 77 EU REGULATION TO THE GUARANTOR AUTHORITY
If our Company does not provide you with a response within the time frame provided by the legislation or the response to the exercise of its rights is not suitable, it may lodge a complaint with the Guarantor for the protection of personal data.

SLOVENIA INFORMATION COMMISSIONER

Zaloška 59  1000  Ljubljana
Tel. +386 1 230 9730 Fax +386 1 230 9778

e-mail: gp.ip@ip-rs.si
Website:  https://www.ip-rs.si/