Data Policy

Data Policy

Libra Association Privacy Policy

The Libra Association Privacy Policy (“Privacy Policy”) applies to the processing of personal data by the Libra Association and its subsidiaries (the “Association,” “we,” “us,” “our”). This Privacy Policy describes our practices for handling your personal data collected in connection with our Association and business development, recruitment, and other processing activities. The Association only processes your personal data in accordance with applicable data protection legislation, in particular, the Swiss Federal Act on Data Protection (SR 235.1) and the Ordinance thereto (SR 235.11), and, if applicable, the European Union General Data Protection Regulation 2016/679. This Privacy Policy does not cover any personal data you may provide when using a product or service that may be offered by either the Association or any third parties.

Libra Association, Quai de l’Ile 13, 1204 Geneva (UID No.: CHE-329.081.073), is responsible for your personal data provided to us or collected by us during the course of our business.

Collection of Personal Data

General

We collect information that you directly provide to us. We may also receive or collect further personal data from third parties such as your organization or other organizations that you have dealings with, regulators, government agencies, and courts. We may also collect personal data from publicly available sources.

Business Development

When you interact with us as a representative of a Libra Association Member or prospective Member, a business counterparty or prospective counterparty, for business purposes, the Association may, for example, collect, receive, or store the following personal data:

  • your name, employer’s name, address, telephone number, and email.

Recruitment

If you apply for a job with the Association or provide us with information in connection with a recruiting event, you may need to provide the personal data described below, in addition to other potential categories of personal data. By applying for a position or participating in a recruiting event, you expressly consent to our use of this personal data. We may use this personal data to consider your application and to carry out checks to verify the personal data you provided. We may, for example, collect, receive, or store the following personal data from you:

  • your name, employer’s name, address, telephone number, email address, references, background, information included in identification documentation, education history information, excerpts from the debt collection register, and criminal record checks. Where we need to collect personal data required to process your employment application, and you fail to provide that personal data when requested, we may not be able to further consider your application.

Other Contacts

We collect and process personal data about you if you contact us, if you offer or provide products or services to us, if we evaluate your products or services, and generally when you request information from us or provide information to us.

How We Use Personal Data

Personal data collected from you or from third parties and publicly available sources are used:

  • to maintain and develop our business relationship with you;
  • to fulfill contractual duties and rights agreed upon with you;
  • to pursue certain business development initiatives;
  • to send you publications and marketing communications;
  • to invite you to events;
  • to comply with applicable legal or regulatory obligations;
  • to evaluate your eligibility for an open job position with us that you apply to; and
  • to the extent it is not possible to use anonymized, encrypted, coded, or aggregated personal data, to develop and test our products and services.

In general, we do not use automated individual decision-making in any of our data processes. If we should rely on such processing in a particular situation, we will inform you separately, insofar as we are legally required to do so.

How We Share Personal Data

We may share your personal data with certain third parties as set forth below:

  • Authorized third-party vendors and service providers. We may share your personal data with third-party vendors and service providers who support us and the provision of our services and products by providing technical and other infrastructure services, business analytics, accounting and payroll services, and other services that require data processing, such as TMF Group.
  • Members. We may share your personal data with the Association’s Member organizations (“Members”). You may find more information about the Members here.
  • Affiliates. We may share your personal data with other departments, affiliated organizations, and companies or subsidiaries as necessary to fulfill our contractual and legal obligations.
  • Legal and safety purposes. We may disclose your personal data to respond to subpoenas, court orders, legal processes, law enforcement requests, legal claims or government inquiries, to detect fraud, and to protect and defend the rights, interests, safety, and security of the website, our affiliates, users, or the public.
  • Business transfers. We may share your personal data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
  • With your consent. We may share your personal data for any other purposes disclosed to you at the time we collect the personal data and pursuant to your prior consent.

Our Legal Bases For Processing Personal Data

We rely on a variety of legal bases to process your personal data for the above purposes, including:

  • as necessary to uphold the Association’s Articles of Association and fulfill the purpose of the Association;
  • as necessary for the performance of a contractual relationship with you or the organization you work for;
  • consistent with your consent, which you can withdraw at any time;
  • as necessary to comply with our legal obligations;
  • and as necessary for our (or others’) legitimate interests, including our interests in providing an innovative personalized, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights or freedoms that require protection of personal data.

You may withdraw consent at any time. Such withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

How You Exercise Your Rights

Under applicable laws, you have the right to access, rectify, port, and erase your personal data, as well as the right to restrict and object to certain processing of your personal data. This includes:

  • the right to object to our processing of your personal data for direct marketing, which you can exercise by contacting us;
  • the right to object to our processing of your personal data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party;
  • where we rely on your consent to process personal data, the right to withdraw your consent at any time; and
  • the right to have us delete your personal data.

To the extent required by applicable data protection law, you may exercise any of your rights at any time by contacting us at optout@libra.org.

You also have the right to lodge a complaint with or notify your local supervisory authority. In Switzerland, the local supervisory authority is the Federal Data Protection and Information Commissioner.

Data Security

We have implemented appropriate security measures to hold your personal data securely in electronic and physical form, to protect it from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction, or accidental loss.

Data Retention

We generally retain your personal data until it is no longer necessary to serve the purposes for which it was collected (e.g., for the duration of our business relationship or recruiting process, for the period required to comply with statutory or regulatory retention duties, or for as long as we have a legitimate interest in retaining the personal data unless such interest is overridden by your interests or fundamental rights or freedoms that require protection of personal data). This is a case-by-case determination that depends on factors such as the categories of the personal data, nature of the personal data, why it is collected and processed, and relevant legal or operational retention needs.

In certain circumstances, we may need to retain your personal data for a longer period of time, for example, in the context of an ongoing or potential litigation or as required by supervisory authorities or law. Your personal data will not be kept for more than five (5) years from the dissolution of the Association unless specifically required by law.

Data Transfers

We utilize standard contract clauses approved by the European Commission (i.e., EU Model Clauses) and rely on the Federal Data Protection and Information Commissioner and the European Commission’s adequacy decisions about certain countries, as applicable, for transfers of your personal data from Switzerland and the European Economic Area to the United States and other countries.

Contact Information


Libra Association

Quai de l'Ile, 13
1204 Geneva
SWITZERLAND

Changes to this Privacy Policy will be brought to your knowledge by appropriate means.

Last updated May 1, 2020

Libra Association Website Privacy Policy

This website (“Website”) is owned and operated by the Libra Association. The Libra Association Website Privacy Policy (“Website Privacy Policy”) applies to the processing of personal data by the Libra Association and its subsidiaries (the “Association,” “we,” “us,” “our”). This Website Privacy Policy describes our practices for handling your personal data collected in connection with your use of this Website. The Association only processes your personal data in accordance with applicable data protection legislation, in particular, the Swiss Federal Act on Data Protection (SR 235.1) and the Ordinance thereto (SR 235.11) and, if applicable, the European Union General Data Protection Regulation 2016/679. This Website Privacy Policy does not cover any personal data you may provide when using a product or service that may be offered by either the Association or any third parties.

Libra Association, Quai de l’Ile 13, 1204 Geneva (UID No.: CHE-329.081.073), is responsible for your personal data provided to us or collected by us during your use of our Website.

Collection of Personal Data

Information you provide directly to us

When you interact with us through our Website, such as by subscribing to our newsletter or contacting us via the Website, we may, for example, collect, receive, or store the following personal data:

  • your name, title, and email address.

If you express interest in your organization joining the Association, we may also, for example, collect, receive, or store the following personal data:

  • the name, revenue, website or location of the headquarters of your organization or the reasons your organization would like to join the Association.

If you interact with our Community website or interact with us via GitHub, we may, for example, collect, receive, or store any personal data, information, and content you provide to us on a voluntary basis.

Information we collect through your use of the Website

When you use the Website, we may, for example, automatically collect, receive, or store certain personal data, such as:

  • your Internet Protocol (IP) address, mobile device identifier, browser type, operating system, Internet service provider, pages that you visit before and after using the Website, the date and time of your visit, information about the links you click and pages you view within the Website, and other standard server log information.

We may use cookies, pixel tags, and similar technologies to collect and store the information described above automatically. We obtain your consent prior to the use of any cookies other than for those cookies that are essential to enable you to use the Website and its features. More information on our use of cookies and changing your cookie preferences can be found in our Cookie Policy.

If you access third-party services, such as Facebook, Google, or Twitter, through the Website to share information and personal data about your experience on the Website with others, these services are outside our control. These third-party services may be able to collect information and personal data about you, including information about your activity on the Website, and they may notify your contacts on such third-party services about your use of the Website, in accordance with the respective privacy policies of such third-party services.

Personal data we collect from other third parties

We may also store, receive, or collect further personal data from third parties such as your organization or other organizations that you have dealings with, regulators, government agencies, and courts. We may also collect personal data from publicly available sources.

How We Use Personal Data

We use personal data collected from you or from third parties and publicly available sources to:

  • help inform the design and implementation of the Website;
  • operate and improve the functionality of the Website;
  • maintain and develop our business relationship with you;
  • fulfill contractual duties and rights agreed upon with you;
  • pursue certain business development initiatives;
  • send you publications and marketing communications;
  • invite you to events; and
  • comply with applicable legal or regulatory obligations.

In general, we do not use automated individual decision-making in any of our data processes. If we should rely on such processing in a particular situation, we will inform you separately, insofar as we are legally required to do so.

How We Share Personal Data

We may share your personal data with certain third parties as set forth below:

  • Authorized third-party vendors and service providers. We may share your personal data with third-party vendors and service providers who support our Website, such as by providing technical infrastructure services, business analytics, and data processing.
  • Members. We may share your personal data with the Association’s Member organizations (“Members”). You may find more information about the Members here.
  • Legal and safety purposes. We may disclose your personal data to respond to subpoenas, court orders, legal processes, law enforcement requests, legal claims or government inquiries, to detect fraud, and to protect and defend the rights, interests, safety, and security of the Website, our affiliates, users, or the public.
  • Business transfers. We may share your personal data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
  • With your consent. We may share your personal data for any other purposes disclosed to you at the time we collect the personal data and pursuant to your consent.

Our Legal Bases for Processing Personal Data

We rely on a variety of legal bases to process your personal data for the above purposes, including:

  • as necessary to provide the services and ensure proper use of the Website;
  • as necessary to uphold the Association’s Articles of Association and fulfill the purpose of the Association;
  • as necessary for the performance of a contractual relationship with you or the organization you work for;
  • consistent with your consent, which you can withdraw at any time;
  • as necessary to comply with our legal obligations; and
  • as necessary for our (or others’) legitimate interests, including our interests in providing an innovative personalized, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights or freedoms that require protection of personal data.

You may withdraw consent at any time. Such withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

How You Exercise Your Rights

Under applicable laws, you have the right to access, rectify, port, and erase your personal data, as well as the right to restrict and object to certain processing of your personal data. This includes:

  • the right to object to our processing of your personal data for direct marketing, which you can exercise by contacting us;
  • the right to object to our processing of your personal data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party;
  • where we rely on your consent to process personal data, the right to withdraw your consent at any time; and
  • the right to have us delete your personal data. We will delete all the personal data we have about you, such as personal data from cookies and personal data you have provided us.

To the extent required by applicable data protection law, you may exercise any of your rights at any time by contacting us at optout@libra.org.

You also have the right to lodge a complaint with or notify your local supervisory authority. In Switzerland, the local supervisory authority is the Federal Data Protection and Information Commissioner.

Data Security

We have implemented appropriate security measures to hold your personal data securely in electronic and physical form to protect it from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction or accidental loss.

Data Retention

We generally retain your personal data until it is no longer necessary to serve the purposes for which it was collected, e.g., for the proper use and functionality of our Website, for the period required to comply with statutory or regulatory retention duties, or for as long as we have a legitimate interest in retaining the personal data unless such interest is overridden by your interests or fundamental rights or freedoms that require protection of personal data. This is a case-by-case determination that depends on factors such as the categories of the personal data, nature of the personal data, why it is collected and processed, and relevant legal or operational retention needs.

In certain circumstances, we may need to retain your personal data for a longer period of time, for example, in the context of an ongoing or potential litigation or as required by supervisory authorities or law. Your personal data will not be kept for more than five (5) years from the dissolution of the Association unless specifically required by law.

Data Transfers

We utilize standard contract clauses approved by the European Commission (i.e., EU Model Clauses) and rely on the Federal Data Protection and Information Commissioner and European Commission’s adequacy decisions about certain countries, as applicable, for transfers of your personal data from Switzerland and the European Economic Area to the United States and other countries.

Do Not Track Signals

Do Not Track (“DNT”) is an optional browser setting offered by various browsers that allows you to express your preferences regarding tracking by advertisers and other third parties. At present, there is no industry standard for recognizing DNT browser signals, so we do not respond to such DNT signals.

Contact Information


Libra Association

Quai de l'Ile, 13
1204 Geneva
SWITZERLAND

We may amend this Website Privacy Policy from time to time to ensure that you are fully informed about all processing activities and our compliance with applicable data protection legislation.

Changes to this Website Privacy Policy will be brought to your knowledge by appropriate means.

Last updated: May 1, 2020

Libra Association Cookie Policy

Cookies

Our Website Privacy Policy explains our principles when it comes to the collection, processing, and storage of your personal data and information. The Libra Association Cookie Policy (“Cookie Policy”) specifically explains how we, our partners, and users of our services deploy cookies, as well as the options you have to control and consent to the use of them.

What are cookies?

A cookie is a small piece of data, stored in text files, that are stored on your browser or other device when websites are loaded in the browser. Cookies are used to “remember” you and your preferences when you visit the Website either for a single visit (through a “session cookie”) or for multiple repeat visits (called a “persistent cookie”).

We use cookies to ensure consistent and efficient experiences for participants in the Website. Cookies also perform functions like allowing participants to remain logged into the Website, if applicable. You can find more information about the types of cookies we use and the purposes for which we use them in the table below:

Functionality

These cookies remember choices you make, for example the country you visit our Website from, and any changes you have made to text size or other parts of web pages that you can customize, in order to improve your experience of our Website and to make your visits more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.

Type of Cookie

Purpose of Cookie

 

Strictly Necessary

These cookies are essential in order to enable you to use the Website and its features. The information collected by these cookies relate to the operation of the Website, for example, language detection, website scripting language and security tokens to maintain secure areas of our Website.

 

Performance

These cookies collect anonymous information about how you use our Website, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our Website. They are also used to track details like the number of unique visitors and pageviews to improve user experience. Information collected by these cookies is used only to improve your use of Website and never to identify you. These cookies are sometimes placed by trusted third-party providers, such as Google Analytics.

 

Functionality

These cookies remember choices you make, for example the country you visit our Website from, and any changes you have made to text size or other parts of web pages that you can customize, in order to improve your experience of our Website and to make your visits more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.

 

Third Party / Embedded Content

These cookies enhance the experience of Website users. These cookies allow you to share what you’ve been doing on our Website with social media organizations such as Facebook and Twitter. We have no control over the information collected by these cookies.

 


Which cookies are used and why?

The Website only automatically uses Strictly Necessary cookies to enable you to use the Website and its features and ensure the functionality of the Website.

Upon your consent, the Website uses performance and analytics, functionality, and third-party or embedded content cookies for the purposes of providing relevant content, analyzing our traffic, and providing a variety of features to you.


How do I disable cookies?

You may withdraw your consent to the use of certain cookies (other than Strictly Necessary cookies) any time. Most internet browsers are automatically set up to accept cookies. If you want to change your cookie preferences or refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies.

Please note you may not be able to take advantage of all the features of our Website if you delete or disable certain cookies, such as the Performance cookies described above.


Web Beacons

We, or our third-party partners, may employ a software technology called web beacons (also known as web bugs, clear gifs or pixels) which helps us understand what content is effective, for example by counting the number of users who have visited these pages, and to understand usage patterns. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to let us know when content is viewed. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded on web pages, ads, and email. We, or our third-party partners, may tie the information gathered by web beacons to the other information we collect about you.

Libra Association Website Terms of Use

These Terms of Use (“Terms”) govern the use of the Libra Association website and any other website or online service that links to these Terms (collectively, the “Website”). These terms constitute an agreement between you and the Libra Association, so it is important that you review them carefully.

Content

The Website is available only for your personal and informational purposes. We make no representations or warranties of any kind as to the accuracy, currency, or completeness of the information and other materials made available through the Website. The Website is not liable for any decisions you may make in reliance of this content.

Your Commitments

We provide these services to you and others. We ask that you make the following commitments:

  • Not use the Website if you are under 13 years old (or the minimum legal age in your country).
  • You are not prohibited from receiving our products, services, or software under applicable laws.

Prohibited Conduct

You may not access or use, or attempt to access or use, the Website to take any action that could harm us or any third party, interfere with the operation of the Website, or use the Website in a manner that violates any laws. For example, and without limitation, you may not:

  • Share anything that breaches these Terms or other applicable terms;
  • Upload viruses or malicious code or do anything that could disable, overburden, or impair the proper working or appearance of our products;
  • Access or collect data from our products using automated means (without our prior permission) or attempt to access data you do not have permission to access; and
  • Engage in any conduct that restricts or inhibits any person from using or enjoying the Website or that, in our sole judgment, exposes us or any of our users, affiliates, or any other third party to any liability, damages, or detriment of any type.

Violations of system or network security may result in liability. We may suspend or terminate your access to the Website for any reason at any time without notice.

Limitation of Liabilities

The Website is provided for informational purposes only and “as is” without warranties of any kind, either express or implied, including without limitation warranties of merchantability, fitness for a particular purpose, title, non-infringement, or other violation of rights. We do not warrant the adequacy, currency, accuracy, likely results, or completeness of the Website or any third-party sites linked to or from the Website, or that the functions provided will be uninterrupted, virus, or error-free. We expressly disclaim any liability for any errors or omissions in the content included in the Website or any third-party sites linked to or from the Website. Some jurisdictions may not allow the exclusion of implied warranties, so some of the above exclusions may not apply to you.

In no event will we, or our owner, subsidiaries, affiliates, directors, officers, employees, agents, and assigns be liable for any direct or indirect, special, incidental, consequential or punitive damages, lost profits, or other damages whatsoever arising in connection with the use of the Website. Any interruption in availability of the Website, delay in operation or transmission, computer virus, loss of data, or use, misuse, reliance, review, manipulation, or other utilization in any manner whatsoever of the Website or the data collected through the Website, even if one or more of them has been advised of the possibility of such damages or loss.

Indemnification

You agree to indemnify, defend, and hold us and our owner, subsidiaries, affiliates, directors, officers, employees, agents, and assigns harmless from and against any and all loss, costs, expenses (including reasonable attorneys’ fees and expenses), claims, damages, and liabilities related to or associated with your use of the Website and any alleged violation by you of these Terms. We reserve the right to assume the exclusive defense of any claim for which we are entitled to indemnification under this section. In such event, you shall provide us with such cooperation as we reasonably request.

Disputes

If you are a consumer and habitually reside in a Member State of the European Union, the laws of that Member State will apply to any claim, cause of action, or dispute that you have against us, which arises out of or relates to these Terms, and you may resolve your claim in any competent court in that Member State that has jurisdiction over the claim. In all other cases, you agree that the claim must be resolved in a competent court in Switzerland and that Swiss law will govern these Terms and any claim, without regard to conflict of law provisions.