Privacy Policy
Effective Date: 07 June 2023
I. General
Midas Software GmbH takes its responsibility for data protection and information security very seriously. The careful handling of all personal data is a core part of our business and the basis for our procedures and processes. With this data protection declaration, we inform you within the scope of the European General Data Protection Regulation (GDPR) which personal data we collect on which legal basis within the scope of the use of this website and the associated functions and for which purposes we process this personal data. The use of our site is possible without providing personal data.
Person responsible and contact
Responsible for the web presence of Midas is Midas Software GmbH.
Midas Software GmbH
Represented by Dennis Klaus Dinkelmeyer
Kurfürstendamm 15
10719 Berlin
Email: team@midas.app
Internet: www.midas.app
If you have any questions or suggestions regarding data protection, or if you wish to exercise your rights, please do not hesitate to contact us using the contact details provided here.
II. Data protection officer
Reach out at team@midas.app.
III. Subject of data protection
The subject of data protection is personal data. According to Art. 4 No. 1 GDPR, this is all information relating to an identified or identifiable natural person. Personal data is also referred to as data in the following.
IV. Cookies
We use so-called cookies on our site to recognize multiple use of our offer, by the same user / Internet connection owner. Cookies are small text files that your Internet browser stores on your computer. They serve to optimize our Internet presence and our offers. Most of these are so-called “session cookies”, which are deleted after the end of your visit. The legal basis for using cookies is our legitimate interest (Art. 6 (1) lit. f) GDPR) to provide a better user experience.
In some cases, however, these cookies provide information to automatically recognize you. This recognition is based on the IP address stored in the cookies. The information obtained in this way is used to optimize our offers and to provide you with easier access to our site.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
Automated data collection on this website of server data.
For technical reasons, the following data, among others, which your Internet browser transmits to us or to our web space provider, is collected (so-called server log files):
Browser type and version.
Operating system used.
Website from which you visit us (referrer URL).
Website that you visit.
Date and time of your access.
Your Internet Protocol (IP) address.
This anonymous data is stored separately from any personal data you may have provided and thus does not allow any conclusions to be drawn about a specific person. They are evaluated for statistical purposes in order to be able to optimize our Internet presence and our offers.
Since it is not possible for Midas Software GmbH to assign your IP address (only your Internet provider can do this) and a pattern recognition over a longer period of time is omitted by a short-cycle deletion, Midas’s interest in the proper operation of the website outweighs any possible interests of visitors that are worthy of protection. The legal basis for the processing of the aforementioned data to ensure proper website operation are our legitimate interests pursuant to Art. 6(1) lit. f) GDPR. We point out that the internet-based data transmission has security gaps, a complete protection against access by third parties is therefore impossible.
V. User onboarding
In order to use our service, users must onboard as stipulated in our Terms and Conditions.
When onboarding, users provide the following information (jointly “Customer Data”):
First and last name.
A valid e-mail address.
Country of residence.
Wallet address.
Data processing is carried out based on legal provisions which authorise the data processing because it is necessary for the provision of this functionality to the user (Art. 6(1) lit. b) GDPR).
Customer Data is generally stored until the respective investor closes its account or otherwise unregisters for the use of the service, unless statutory retention obligations apply, or the Customer Data is necessary for other purposes described herein.
VI. Authentication
To buy tokens, investors must verify their identities. In this regard we receive certain information from Know Your Customer service provider(s) (“KYC-Provider”) we work with and the respective investor chooses to verify its identity with. In this regard, we receive the result of any such verification process (i.e. verified “yes” or “no”) and store that information.
Data is processed because it is contractually required for the provision of the service to the investors (Art. 6(1) lit. b) GDPR), and because compliance with KYC- and Anti-Money-Laundering regulations is required by law (Art. 6(1) lit. c) GDPR).
This information is generally stored until the respective investor closes its account or otherwise unregisters for the use of the service, unless statutory retention obligations apply, or the information is necessary for other purposes described herein.
The data processing is carried out on the basis of legal provisions which authorise the data processing because it is necessary for the provision of this functionality to the investor (Art. 6(1) lit. b) GDPR). Full name, date and place of birth, nationality, address, ZIP-Code, City and country of residence, type of ID document (e.g. identity card, passport), ID-document number, issuing authority, country and date of issuance, expiry date, signature, copies of front and back of ID document.
Tax information: Tax ID number(s), tax authority.
Bank information: IBAN, Bank name, Bank address.
VII. Contact option and Newsletter
On our website, we offer you the opportunity to contact us by e-mail or via a contact form. In this case, the information provided by the user will be stored for the purpose of processing his contact. The legal basis for this data processing is your consent in accordance with Art. 6 (1) (a) GDPR and, in the case of contract initiation, Art. 6 (1) (b) GDPR. The data will not be passed on to third parties. A comparison of the data collected in this way with data that may be collected by other components of our site also does not take place.
By subscribing to our newsletter, you agree to receive regular e-mail updates from Midas about firm news and products. Your consent is voluntary and can be revoked at any time without giving reasons via the contact options given in the legal notice. Please note that data processing that took place before the revocation is not affected by the revocation and is therefore lawful despite the revocation.
After your enquiry or subscription is done, the data provided will be deleted unless it is required for a following contractual relationship, or it has to be kept due to mandatory retention obligations. You can also request to delete your data at any time.
VIII. Social Media and Messaging Services
We operate company pages on social media platforms and messaging services to inform users and visitors about our product and to communicate with them. When you use our social media site and/or messaging services by a third-party provider, personal data may be collected and processed in connection with your actions and interactions with our social media site and/or the messaging service via the server of the third-party provider servers. You can view the provider responsible for the social media platforms or messaging services on the respective pages of the social media platform or messaging service provider in the legal notice.
Social media operators provide us with aggregated, anonymous insights on user interactions with our page, such as follower numbers, post engagement, and other usage metrics. These insights do not allow us to identify individual users and help us improve our content based on audience interests. Our data processing practices align with our legitimate interests under GDPR, focusing on optimizing communications and engaging our audience. We retain personal data only as long as necessary for our purposes or as required by legal obligations, but have no control over how long social media platforms store data on their servers.
IX. Disclosure of data to third parties in general
Based on Art. 28(1) GDPR, we share personal data with external service providers as our processors. The processors may only use the data for the purposes specified by us. Including the processors already explicitly mentioned in this Privacy Policy, we use the following categories of processors:
IT service providers.
Cloud service providers.
Hosting service providers.
Marketing service providers.
If we use third-party providers, any processing of personal data takes place on servers within the European Economic Area or in countries covered by an adequacy decision of the European Commission.
If it is necessary for the clarification of an illegal use of our website or for legal prosecution, personal data will be forwarded to law enforcement authorities and, if necessary, to injured third parties. However, this only happens if there are concrete indications of unlawful or abusive behavior. A transfer may also take place if this serves the enforcement of claims. We are also legally obligated to provide information to certain public authorities upon request. These are law enforcement agencies, authorities that prosecute administrative offenses subject to fines and the tax authorities. The disclosure of this data is based on our overriding legitimate interest according to Art. 6(1) lit. f) GDPR or based on a legal obligation according to Art. 6(1) lit. c) GDPR.
As part of the organization of our operations, financial accounting and compliance with legal obligations, such as archiving, we disclose or transmit here the same data that we have processed for the purpose of reimbursement of costs or, if applicable, in connection with the assertion, safeguarding or defense of claims from you, if applicable, to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers. The transfer of this data is based on our legitimate interest in maintaining our business activities, the performance of our tasks as well as for the implementation of the reimbursement of costs, Art. 6(1) lit. f) GDPR or on the basis of a legal obligation according to Art. 6(1) lit. c) GDPR.
X. Information / Revocation / Deletion
We delete your personal data as soon as they are no longer required for the purposes for which we processed them. We will continue to store your data if we are obliged to do so for legal reasons (Art. 6(1) lit. c) GDPR) or if the data is required for a longer period of time to secure, assert or enforce legal claims. Insofar as data must be retained for legal reasons, processing will be restricted. The data is then no longer available for further use. Further storage takes place on the basis of our aforementioned legitimate interests in accordance with Art. 6(1) lit. f) GDPR.
XI. Your rights as a data subject
You have the following rights vis-à-vis us with regard to the personal data concerning you:
A. Right to restriction of processing
You have the right to demand that we restrict processing in accordance with Art. 18 GDPR. This right exists in particular if the accuracy of the personal data is disputed between you and us, for the duration that the verification of the accuracy requires, as well as in the event that you request restricted processing instead of erasure in the case of an existing right to erasure; furthermore, in the event that the data is no longer necessary for the purposes pursued by us, but you need it to assert, exercise or defend legal claims, as well as if the successful exercise of an objection is still disputed between you and us.
B. Right to data portability
You have the right to obtain from us the personal data concerning you that you have provided to us in a structured, commonly used, machine-readable format in accordance with Art. 20 GDPR.
C. Right to object to processing
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is carried out, inter alia, on the basis of Art. 6(1) lit. f) GDPR, in accordance with Art. 21 GDPR. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
D. Right to lodge a complaint with a data protection supervisory authority
You have the right to contact a supervisory authority of your choice in case of complaints. The competent supervisory authority is
The Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61
10555 Berlin
We will store the personal data provided by you when exercising your rights pursuant to Art. 15 to 22 GDPR for the purpose of implementing these rights and providing evidence thereof. These processing operations are based on Art. 6(1) lit. c) GDPR in conjunction with. Art. 15 to 22 GDPR and Section 34(2) BDSG.
[CD1]Delete this paragraph if there is no obilgation to appoint a data protection officer. It is mandatory if more than 20 employees are involved in the processing of personal data.
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