This policy describes how The RWA Insights ("we", "our") collects, uses, shares and protects your personal data when you visit therwainsights.com or use its services, in accordance with Regulation (EU) 2016/679 (GDPR) and applicable laws (GDPR; law applicable to the publisher entity).
1. Data Controller
- Controller entity: EquusChain Ltd
- Address: Al Sarab Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates
- Contact: legal@equuschain.io
2. Data Protection Officer (DPO)
A DPO has been appointed. For any question regarding your personal data or the exercise of your rights: dpo@equuschain.io.
3. Data We Collect
3.1 Data you provide directly
- Identity data: first name, last name
- Contact data: e-mail address, phone number
- Professional data: organisation, position, country of residence (if provided)
- Message content: information you send via the newsletter subscription form (if offered)
3.2 Data collected automatically
- Technical data: IP address, browser type and version, operating system, time zone, language
- Navigation data: pages viewed, visit duration, browsing paths (via cookies — see our Cookie Policy)
3.3 Sensitive data
We do not intentionally collect special categories of data (Art. 9 GDPR). No sensitive data should be submitted.
4. Purposes and Legal Bases
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Responding to your information/access requests | Identity, contact, message | Art. 6.1(b) — pre-contractual measures |
| Managing membership / qualification applications | Identity, contact, profile | Art. 6.1(b) + 6.1(f) — legitimate interest (eligibility check) |
| Sending the weekly newsletter and publication alerts (explicit consent required) | Contact | Art. 6.1(a) — consent |
| Sending communications related to your request | Contact | Art. 6.1(b) |
| Security and fraud prevention | Technical, navigation | Art. 6.1(f) — legitimate interest (website security) |
| Complying with legal and regulatory obligations (Press/media obligations as applicable by jurisdiction) | As required | Art. 6.1(c) — legal obligation |
| Improving the website and user experience | Navigation | Art. 6.1(a) consent (if non-essential analytics) / 6.1(f) |
5. Cookies
The website uses cookies. Essential cookies (session, security) do not require consent. Non-essential cookies (analytics, advertising) are only placed after your consent via the cookie banner. See our Cookie Policy.
6. Recipients of Data
Your data is accessible to authorised personnel of EquusChain Ltd and, as needed, to:
- Hosting provider: Infomaniak Network SA (Switzerland — EU adequacy decision, Art. 45 GDPR)
- E-mail delivery and hosting providers (processors)
- Technical service providers and CRM tools, bound by processor agreements compliant with Art. 28 GDPR
- Competent authorities when required by law
We never sell your personal data.
7. International Transfers
Depending on your location and ours, your data may be transferred outside the EU/EEA:
- Switzerland (hosting): EU Commission adequacy decision
- Potential transfers outside the EU: governed by EU SCCs: transfer governed by EU Standard Contractual Clauses (SCCs) or an adequacy decision
You may obtain a copy of the applicable safeguards by contacting the DPO: dpo@equuschain.io.
8. Retention Periods
| Data | Duration |
|---|---|
| Contact / information requests | 3 ans à compter du dernier contact |
| Membership application data (if rejected) | N/A |
| Navigation data / technical logs | 13 mois maximum |
| Newsletter (until unsubscribe) | jusqu'au désabonnement (lien de désinscription dans chaque envoi) |
| Documents required by law (AML/KYC, invoicing) | Applicable legal periods (N/A) |
9. Security
We implement appropriate technical and organisational measures to protect your data: encrypted transmissions (HTTPS), access controls, data minimisation, secure hosting in Switzerland. HTTPS encryption, access controls, data minimisation.
10. Your Rights
Under the GDPR you have the following rights:
- Access (Art. 15) — obtain a copy of your data
- Rectification (Art. 16) — correct inaccurate data
- Erasure (Art. 17) — request deletion of your data
- Restriction (Art. 18) — restrict processing
- Portability (Art. 20) — receive your data in a structured format
- Objection (Art. 21) — object to processing based on legitimate interest
- Withdrawal of consent — at any time, without affecting the lawfulness of prior processing
- No automated decision-making — you are not subject to automated individual decisions (Art. 22) — no automated decision-making is performed based on your data.
To exercise your rights: dpo@equuschain.io or at the publisher's address. We respond within one month (extendable by two months for complex requests).
11. Complaints
If you believe your rights are not respected, you may lodge a complaint with the competent supervisory authority: CNIL (France, 3 place de Fontenoy, 75007 Paris — cnil.fr) or the data protection authority of your country of residence. EU residents: authority of their country of residence.
12. Minors
The The RWA Insights website addresses professionals and investors interested in real-world asset markets and research. It is not intended for minors under 18, and we do not knowingly collect their data.
13. Changes
We may update this policy. The online version prevails. Material changes will be notified on the website.
14. Contact Us
For any question regarding this policy or your data: dpo@equuschain.io — This website is governed by the laws of Abu Dhabi Global Market (ADGM) and the United Arab Emirates. Any dispute falls under the jurisdiction of the ADGM courts. For users residing in the EU, the mandatory provisions of the law of their country of residence remain applicable.