Privacy & Data Protection
The privacy of our users, and therefore the protection of your personal data, is our top priority. For this reason, we not only encrypt all data and data transfers in accordance with current industry standards, but we have also restricted the processing of personal data to absolutely necessary areas only. We will never pass your data on to third parties.
With this Data Protection Declaration within the meaning of the General Data Protection Regulation (GDPR), Wealthy Mind Academy as the responsible body for data processing (for contact details see our imprint), explains Who, What, When, How, Why and Where personal customer data is processed. The collection, administration and use of personal data by Wealthy Mind Academy complies with the highest security and data protection regulations applicable in the European Union and its member states.
What?
First of all, we would like to point out that the entire software solution provided by Wealthy Mind Academy is basically completely independent of the disclosure of personal data, i.e. data that can be clearly assigned to a specific person, and can therefore also be operated fully functional on an anonymised or pseudonymised basis.
A valid e-mail address must be provided when registering to use the Wealthy Mind Academy applications. Other information, however, is optional and voluntary during registration and can be added or deleted by the user afterwards (e.g. first and last name; date of birth; address). Wealthy Mind Academy does not currently offer the option of encryption of individual user accounts.
We process the personal data that we receive from you as part of our business relationship (mandatory and voluntary). We may also process personal data that we legitimately receive from publicly accessible sources. This may include the following personal data:
- Personal details (e.g. name, address, contact details, date of birth, gender, place of birth, nationality)
- Legitimisation data (e.g. ID card data) and authentication data
- Order data (e.g. payment orders and wallet or account number)
- Data from the fulfilment of our contractual obligations (e.g. purchase amount, exchange amount, virtual payment data)
- Information in accordance with the KYC principle resulting from the legal obligations in the Financial Market Money Laundering Act (e.g. customer profile, documentation on the purpose and nature of the business relationship, proof of origin of funds, PEP check)
- Advertising and sales data
- Documentation data (e.g. counselling protocols, meeting notes)
- Processing results that we generate ourselves and data in fulfilment of legal and regulatory requirements
Why?
The purpose of data collection is the automated data processing and provision of services in the context of transaction analyses and applications in the field of Wealthy Mind Academy technology. Wealthy Mind Academy has a business licence for services in automatic data processing and information technology. If the aforementioned personal data has been disclosed to us, we may process it in the following ways:
- for the fulfilment of contractual obligations (Art. 6 para. 1 lit. b GDPR) for the provision of our services and in particular for the performance of our contracts with you or for the implementation of pre-contractual measures taken at your request, as well as for the performance of all activities necessary for the operation and administration of our company and for legal and claims prosecution. The purposes of data processing may also include needs analyses, quality assurance, consulting and the execution of transactions; or
- to fulfil legal obligations (Art. 6 para. 1 lit c GDPR; e.g., Financial Market Money Laundering Act, tax laws, possible future regulatory requirements) for identity and age verification, fraud and money laundering prevention, the fulfilment of tax and regulatory control and reporting obligations; or
- within the scope of your consent (Art 6 para 1 lit a GDPR), insofar as you have given us your consent to the processing of personal data for specific purposes; or
- to safeguard legitimate interests (Art 6 para 1 lit f GDPR) in the context of balancing interests in favour of Wealthy Mind Academy or a third party, such as in cases of consultation of and data exchange with credit agencies, advertising or market research (unless you have objected to the use of your data), measures to protect customers and employees as well as Wealthy Mind Academy's property, measures to prevent and combat fraud (transaction monitoring) and measures for business management and further development of products and services.
Why?
For technical reasons, the following data that your browser transmits to us or to our web space provider is also recorded (so-called server log files):
- Browser type and version
- Operating system used
- Website from which you visit us (referrer URL)
- Website you visit
- Date and time of your access
- Your Internet Protocol (IP) address.
Why?
This anonymous data is stored separately from any personal data you may have provided and therefore does not allow any conclusions to be drawn about a specific person. It is evaluated for statistical purposes in order to optimise our website and our offers.
All data that the user has processed on the Wealthy Mind Academy platform will be (i) anonymised or (ii) deleted within 30 days of termination or exclusion, provided that there are no legal storage obligations or legitimate interests to the contrary. At the user's request, all personal data relating to the user will be deleted, provided there are no legal retention obligations or legitimate interests to the contrary. This requires an email with the email address provided during registration and the request for final deletion to Wealthy Mind Academy. Wealthy Mind Academy will comply with such requests within the statutory period.
Who and Where?
Wealthy Mind Academy treats all user data confidentially and only publishes such data if required by law or with the express consent of the user. At Wealthy Mind Academy, only those departments or employees receive access to your data who need it to fulfil contractual, legal and potential regulatory obligations and to protect legitimate interests. The service providers we use (processors) also only receive data from us if they need this data to fulfil the respective service or if a corresponding authorisation is given. All processors and vicarious agents are contractually obliged (order processing contracts) to maintain data secrecy and to treat your data confidentially and only process it in the context of providing the service.
Wealthy Mind Academy has implemented appropriate security regulations and procedures to protect the stored user data. Sensitive data is not collected. Non-individualisable information is stored and used for the purposes of newsletter advertising or on Wealthy Mind Academy by Wealthy Mind Academy or its contractual partners. Registered users can also unsubscribe from this advertising using a function on the Wealthy Mind Academy website.
When?
We process and store your personal data for as long as is necessary for the fulfilment of our contractual and legal obligations, but in any case for the duration of the entire business relationship and beyond in accordance with the statutory retention periods (e.g. 7 years according to the Austrian BAO or UGB; 30 years according to the Austrian ABGB due to warranty and compensation). It is possible to anonymise the data instead of deleting it. In this case, any personal reference is irretrievably removed, which is why the deletion obligations under data protection law no longer apply.
Data Security
Data security is very important to us and we therefore have comprehensive administrative, technical and physical measures in place to protect your personal data from accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. These measures comply with the highest international security standards and are regularly reviewed for their effectiveness and suitability to achieve the intended security objectives.
We have implemented the following technical and organisational measures, among others:
- SSL encryption of our websites from which we send personal data;
- Ensuring the confidentiality, integrity, availability and resilience of our systems and services;
- Use of encrypted systems;
- Pseudonymisation and anonymisation of personal data;
- Access, entry and transmission control for our offices and systems;
- Measures to quickly restore the availability of personal data in the event of a physical or technical incident;
- Introduction of procedures for the regular review, evaluation and assessment of the effectiveness of technical and organisational measures to ensure the security of data processing
- Internal IT security guidelines and IT security training;
- Incident-response management.
Payment and Subscription Information
You have the option of initiating booking transactions in FIAT or crypto via our services. If this is necessary for the fulfilment of the contract, data will also be transferred to our payment service providers (e.g. Stripe, PayPal, Apple Store, Google Store etc) or the credit institution commissioned to process the payment. The scope of the data is limited to the minimum required for the purpose of processing the contract. Please note, however: Personal data may also be passed on by these third parties to service providers, subcontractors or other affiliated companies if this is necessary to fulfil the contractual obligations arising from your order or if the personal data is to be processed on our behalf.
When paying by credit card, instant bank transfer or direct debit, payment is processed by the payment service provider Stripe Payment Europe Ltd, Block 4, Harcourt Centre, Harcourt Roud, Dublin 2, Ireland. You can find more information about Stripe's data protection at https://stripe.com/privacy.
When paying via the Apple App Store, payment is processed by the payment service provider Apple Inc, One Apple Park Way, Cupertino, CA 95014, USA. You can find more information on data protection in the App Store at https://developer.apple.com/app-store/app-privacy-details/.
When paying via the Google Store, payment is processed by the payment service provider Google Commerce Limited, Gordon House, Barrow Street, Dublin 4, Ireland. You can find more information on data protection in the app store at https://policies.google.com/privacy?hl=en.
If you decide to pay with the online payment service provider PayPal as part of your order process, your contact details will be transmitted to PayPal as part of the order process. PayPal is an offer from PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. PayPal assumes the function of an online payment service provider as well as a trustee and offers buyer protection services. Depending on the payment method selected via PayPal, e.g. invoice or direct debit, the personal data transmitted to PayPal will be transmitted by PayPal to credit agencies. This transmission is used to check your identity and creditworthiness in relation to the order you have placed. To find out which credit agencies are involved and which data is generally collected, processed, stored and passed on by PayPal, please refer to PayPal's privacy policy at https://www.paypal.com/us/legalhub/privacy-full.
Although we do not store any credit card information ourselves, we register a payment ID, which is issued by the respective provider and can be assigned to a person by them, as well as the duration of your subscription, the price, the currency, the VAT (based on country information) and the payment provider. We need to do this in order to activate the correct licence for you.
Service providers and other third-party services
We use third parties to help us provide and improve our products (e.g. maintenance, analytics, audit, payments, fraud detection, marketing and development). These service providers may have access to your browsing data, unless you have disabled this (see cookie statement) and this is necessary to fulfil these tasks on our behalf, and are obliged not to pass it on or use it for other purposes. We use processors such as Google, Meta, Apple, Amazon Web Services, Firstpromoter, Miro, Notion Labs, Zoom, Semrush, Atlassian, Zendesk, Stripe, AdRoll, Zapier, Hotjar & Hubspot .
Data protection rights
Every data subject has the right to information, rectification, erasure, restriction of processing, objection and data portability. In addition, there is a right to lodge a complaint with a data protection supervisory authority. The supervisory authority for Wealthy Mind Academy's compliance with data protection regulations is the Austrian Data Protection Authority, Wickenburggasse 8-10, 1080 Vienna, phone: +43 1 531 15-202525, email: dsb@dsb.gv.at, website: http://www.dsb.gv.at.
However, before you contact the data protection authority, we ask that you first submit all claims to Wealthy Mind Academy.
Automated decision-making including profiling?
We do not use automated decision-making to establish and conduct the business relationship. Personal aspects are also not evaluated (profiling).
Plugins and widgets for social media
Wealthy Mind Academy uses third-party content on social media paltforms.
The social media plugins may collect the user's IP address and the page the user has visited on the Wealthy Mind Academy platform and they may set up a cookie for the function to work properly. Social media plugins and widgets are either hosted by third parties or directly on our websites and the IP address is transmitted to a third country or within the EU. The user's interaction with these features is subject to the privacy policy of the respective company providing the feature. Wealthy Mind Academy is not responsible for the policies and practices regarding collection, use, disclosure, including data security practices of third parties. Please contact these companies directly to learn about their legal bases and retention periods.
Google Analytics and App Analytics
The Wealthy Mind Academy applications use Google Analytics, a network analysis service from Google Inc ('Google'). Google Analytics uses 'cookies'. The information relating to the visit to a website, including the IP address, is collected by the cookie and usually transmitted to a Google server in the USA and stored there. If a website has activated IP anonymisation, Google first shortens IP addresses from member states of the European Union and EEA states. The full IP address is then, only in exceptional cases, transmitted to the Google server in the USA or Asia and only shortened there. Google uses the information collected on behalf of the website provider to analyse the use of the Wealthy Mind Academy applications, to compile reports on website activity and to provide additional services relating to the Wealthy Mind Academy applications. Under no circumstances will Google link the IP address transmitted by the browser as part of Google Analytics with other Google data.
Your consent allows us to transfer certain data to our partners for processing in countries outside the EU, in particular the USA (e.g. Google Analytics). There is no adequacy decision by the EU Commission for the USA and, despite extensive measures, the high EU level of data protection cannot be guaranteed in the USA. There is a risk that transmitted data may not be deleted or further processed for any purpose, that US authorities may have disproportionate access to your data or that you may not be able to effectively enforce your rights in the USA. You can also revoke your consent at any time with effect for the future. However, rejecting some of these cookies may affect your user experience.
Users can prevent the recording by Google and Google's processing of information regarding the use of the Wealthy Mind Academy platform, including the IP address, by downloading and installing the following browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en.
The Wealthy Mind Academy applications use Google DoubleClick for Publishers ('DFP'). DFP uses cookies to display relevant adverts to the user - the user can find more information about DFP at https://support.google.com/dfp_premium/answer/2839090?hl=en. The user can deactivate the setting of cookies by DFP on the following page and thus prevent the display of adverts relevant to the user on the Wealthy Mind Academy platform: http://www.google.com/ads/preferences.
Access data / server log files
Wealthy Mind Academy (or its web space provider) collects data about every access to the website (so-called server log files). The access data includes: Name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider. The provider uses the log data only for statistical evaluations for the purpose of operation, security and optimisation of the website. However, the provider reserves the right to check the log data retrospectively if there is a justified suspicion of unlawful use based on concrete evidence.
Deletion of user data
If a registered user's account is terminated, all personal data provided by the respective user upon registration will be deactivated. All data collected from the user will be (i) anonymised, i.e. it will be visible that this information originates from a deleted account, or (ii) in the event of the deletion of an account, deleted within 30 days, provided that there are no legal storage obligations or legitimate interests of Wealthy Mind Academy to the contrary and, at the request of this Registered User, all user data which is no longer required for the fulfilment of the contract by Wealthy Mind Academy or which must be stored due to legal requirements will be irrevocably deleted. Such a request for deletion must be made by e-mail, stating the e-mail address provided during registration. Wealthy Mind Academy will fulfil this request immediately.
Newsletter
Wealthy Mind Academy sends newsletters to registered users on the one hand, and to people who have provided their email addresses for another service offered by Wealthy Mind Academy on the other. The email address is processed for the purpose of the newsletter and the user has the option to unsubscribe from the newsletter each time they receive it. The legal basis is your consent in accordance with § 107 TKG.
Changes to the privacy policy
In order to comply with all legal requirements, this privacy policy is continuously adapted. You can always find the latest version on our website. If we make material changes to this Privacy Policy, we will notify you after you log in to your Wealthy Mind Academy account and provide you with the updated version of the Privacy Policy. If required by applicable law, Wealthy Mind Academy will obtain your express consent to any material changes.
For further questions, please contact us.