GDPR & Privacy Rights Notice: This Privacy Policy explains how GoWolffia LLC collects, uses, and protects your personal information in compliance with the General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act (CCPA), Swiss Federal Act on Data Protection (FADP), and other applicable privacy laws.
1. Data Controller Information
Data Controller: GoWolffia LLC
Email: moc.aiffloWoG@ofni
Data Protection Officer: moc.aiffloWoG@opd
1.2 International Compliance
This Privacy Policy complies with:
- EU GDPR (General Data Protection Regulation) - For users in the European Union
- UK GDPR (UK General Data Protection Regulation) - For users in the United Kingdom
- CCPA (California Consumer Privacy Act) - For California residents, USA
- FADP (Swiss Federal Act on Data Protection) - For users in Switzerland
2. Information We Collect
2.1 Personal Information You Provide
We collect personal information that you voluntarily provide to us, including:
- Contact Information: Name, email address, phone number
- Inquiry Details: Messages, questions, and feedback you submit through our contact forms
- Partnership Applications: Business information, company details, and professional background
- Communication Records: Records of your communications with us
2.2 Information Collected Automatically
When you visit our website, we automatically collect certain information:
- Usage Data: Pages visited, time spent, navigation patterns
- Device Information: Browser type, operating system, current screen resolution, device identifiers
- Technical Data: IP address, referral URLs, access times
- Performance Data: Page load times, error logs, system performance
Note: We do not currently use analytics cookies or third-party tracking. All data collection is limited to essential website functionality.
3. Legal Basis for Processing (GDPR, UK GDPR, FADP)
Under GDPR (EU), UK GDPR, and FADP (Switzerland), we process your personal data based on the following legal grounds:
- Consent: When you provide explicit consent for specific processing activities (e.g., functional cookies, performance cookies)
- Contractual Necessity: To fulfill our obligations in providing services to you
- Legitimate Interests: For business operations, website improvement, and fraud prevention
- Legal Obligation: To comply with applicable laws and regulations
4. How We Use Your Information
We use the collected information for the following purposes:
- Service Provision: To respond to your inquiries and provide requested information
- Communication: To send you updates, newsletters, and marketing communications (with consent)
- Partnership Processing: To evaluate and process partnership applications
- Website Improvement: To analyze usage patterns and improve user experience
- Security: To prevent fraud, abuse, and security incidents
- Legal Compliance: To comply with legal obligations and protect our rights
5. Cookies and Tracking Technologies
5.1 What Are Cookies
Cookies are small text files stored on your device that help us provide and improve our services. We use both session cookies (temporary) and persistent cookies (stored longer-term).
5.2 Types of Cookies We Use
| Cookie Name |
Type |
Purpose |
Duration |
Legal Basis |
| sidebar:state |
Functional Cookie |
Remembers sidebar open/closed state for user preference |
7 days |
Consent |
| gowolffia_consent |
Essential Cookie |
Stores your cookie consent preferences |
12 months |
Legitimate Interest |
5.2.1 Local Storage Usage
| Storage Key |
Type |
Purpose |
Duration |
Legal Basis |
| investorFormData |
Essential (localStorage) |
Temporarily saves investor form data as draft (prevents data loss) |
Until form submission or manual clear |
Legitimate Interest (form functionality) |
| gowolffia_cookie_consent |
Essential (localStorage) |
Stores your cookie consent preferences and timestamp |
12 months |
Legitimate Interest (consent management) |
| React Query Cache |
Performance (localStorage) |
Caches API responses to improve website performance and reduce server load |
5-30 minutes (managed by React Query) |
Consent (performance optimization) |
5.3 Local Storage and Session Storage
Our website uses browser storage technologies including:
- Local Storage:
- Form data persistence (investor form drafts) - Essential
- Cookie consent preferences - Essential
- React Query cache for performance optimization - Requires consent
- Session Storage: Currently not used
- Rate Limiting Storage: In-memory storage (not persisted) to prevent abuse and ensure fair usage of our services - Essential
5.4 Third-Party Technologies
We currently do not use third-party services that set cookies. Our website is self-hosted and does not integrate with:
- Google Analytics or similar analytics services
- Social media tracking pixels
- Advertising networks
- Third-party CDNs that set tracking cookies
Note: If we add third-party services in the future, we will update this policy and require your consent before implementing any tracking cookies.
5.5 Cookie Consent Management
We use a cookie consent banner that allows you to:
- Accept all cookies
- Reject non-essential cookies
- Customize your cookie preferences by category
- Withdraw your consent at any time
- Access detailed information about each cookie category
Your consent preferences are stored for 12 months. After this period, you will be asked to provide consent again.
You can manage your cookie preferences at any time by clicking the "Cookie Preferences" link in our footer or by clearing your browser's cookies and localStorage.
6. Data Sharing and Disclosure
6.1 We Do Not Sell Personal Data
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.
6.2 When We May Share Information
We may share your information only in the following circumstances:
- Service Providers: With trusted third-party service providers who assist in our operations
- Legal Requirements: When required by law, regulation, or legal process
- Business Transfers: In connection with mergers, acquisitions, or asset sales
- Protection of Rights: To protect our rights, property, or safety, or that of others
- With Your Consent: When you explicitly agree to such sharing
7. International Data Transfers
Data Location: All personal data collected through our website is stored on servers located in the United States. We do not transfer personal data to servers located in the European Union, United Kingdom, or Switzerland.
For EU, UK, and Swiss Users: When you use our website, your personal data is processed on servers in the United States. This constitutes an international data transfer under GDPR, UK GDPR, and FADP.
Safeguards: We ensure appropriate safeguards are in place for international data transfers:
- Standard Contractual Clauses (SCCs) with our hosting provider
- Technical and organizational measures to protect your data
- Compliance with applicable data protection laws
Your Rights: Despite the data being stored in the United States, you retain all rights under GDPR, UK GDPR, and FADP, including the right to access, rectify, erase, restrict processing, and object to processing of your personal data.
8. Data Retention
We retain your personal data only as long as necessary for the purposes outlined in this policy:
- Contact Form Data: 3 years from last contact
- Partnership Applications: 5 years for business record purposes
- Website Analytics: 2 years for analysis purposes
- Legal Compliance Data: As required by applicable laws
9. Your Privacy Rights
9.1 GDPR Rights (EU Residents)
Under GDPR, you have the following rights:
- Right of Access: Request information about how we process your data
- Right to Rectification: Correct inaccurate or incomplete data
- Right to Erasure: Request deletion of your personal data
- Right to Restrict Processing: Limit how we use your data
- Right to Data Portability: Receive your data in a structured format
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time
- Right to Lodge Complaints: File complaints with supervisory authorities
9.1.1 UK GDPR Rights (UK Residents)
Under UK GDPR, you have the same rights as EU GDPR. Additionally:
- You can contact the UK Information Commissioner's Office (ICO) for complaints
- UK-specific data protection laws apply
- Data transfer provisions may differ from EU GDPR
UK Supervisory Authority: Information Commissioner's Office (ICO)
Website: https://ico.org.uk
9.1.2 FADP Rights (Swiss Residents)
Under FADP (Swiss Federal Act on Data Protection), you have the following rights:
- Right of Access: Request information about your personal data
- Right to Rectification: Correct inaccurate data
- Right to Erasure: Request deletion of your personal data
- Right to Object: Object to processing of your data
- Right to Withdraw Consent: Withdraw consent at any time
- Right to Lodge Complaints: File complaints with the FDPIC
Swiss Supervisory Authority: Federal Data Protection and Information Commissioner (FDPIC)
Website: https://www.edoeb.admin.ch
9.2 CCPA Rights (California Residents)
Under CCPA, California residents have the right to:
- Know: What personal information we collect and how it's used
- Delete: Request deletion of personal information
- Opt-Out: Opt-out of the sale of personal information (we don't sell data)
- Non-Discrimination: Not be discriminated against for exercising privacy rights
9.3 How to Exercise Your Rights
To exercise any of these rights, contact us at:
- Email: moc.aiffloWoG@opd
- Subject Line: "Privacy Rights Request"
- Include: Your full name, email address, and specific request
We will respond to your request within 30 days (GDPR) or 45 days (CCPA).
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
- Encryption: Data encryption in transit and at rest
- Access Controls: Restricted access to personal data
- Input Validation: XSS prevention and data sanitization
- Rate Limiting: Protection against abuse and spam
- Regular Security Reviews: Ongoing security assessments and updates
- Incident Response: Procedures for handling data breaches
11. Children's Privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information promptly.
12. Cookie Management
12.1 Managing Cookies
You can control cookies through your browser settings:
- Block Cookies: Configure your browser to reject all cookies
- Delete Cookies: Remove existing cookies from your device
- Selective Blocking: Block specific types of cookies
12.2 Impact of Disabling Cookies
Please Note: Disabling certain cookies may impact website functionality, including form submissions, user preferences, and performance optimization.
13. Data Breach Notification
In the event of a data breach affecting your personal information:
- We will notify relevant supervisory authorities within 72 hours (GDPR requirement)
- We will inform affected individuals without undue delay if high risk is involved
- We will provide clear information about the breach and steps being taken
14. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. We will:
- Post the updated policy on our website
- Update the "Last Updated" date at the top of this policy
- Notify you of material changes via email or website notice
- Obtain your consent for material changes when required by law
15. Supervisory Authorities
If you have concerns about our data processing, you can contact your local data protection authority:
15.1 European Union
You can find contact details for EU supervisory authorities at: https://edpb.europa.eu/about-edpb/board/members_en
15.2 United Kingdom
Information Commissioner's Office (ICO)
Website: https://ico.org.uk
Helpline: +44 303 123 1113
15.3 Switzerland
Federal Data Protection and Information Commissioner (FDPIC)
Website: https://www.edoeb.admin.ch
Email: contact@edoeb.admin.ch
15.4 United States (California)
California Attorney General
Website: https://oag.ca.gov/privacy/ccpa
16. Contact Information
Your Consent: By using our website, you consent to the collection and use of your information as described in this Privacy Policy. You can withdraw your consent at any time by contacting us at moc.aiffloWoG@opd.