We are dedicated to protecting the confidentiality and privacy of information entrusted to us. We comply with applicable Data Protection Regulations including in particular the Swiss Federal Act on Data Protection (FADP).
By accessing and using our website you explicitly acknowledge and confirm that you have read, understood and accepted this data privacy statement and, to the extent your consent is necessary under applicable law, you provide consent to the collection, use and potential disclosure of your personal data concerning your person (“personal data”) or any third-party recipient in accordance with the terms of this privacy statement and our Terms of Use.
You shall not access or use this website should you not be able to read and / or understand this privacy policy.
You shall not access or use this website should you not agree to be bound by this privacy policy.
The term "personal data" in this Privacy Policy to shall mean any information that identifies, or could reasonably be used to identify any person.
If you provide us with personal data of other persons, please make sure the respective persons are aware of this Privacy Policy and only provide us with their data if you are allowed to do so and such personal data is correct.
This Privacy Policy is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA»). However, the application of these laws depends on each individual case.
Controller
This Privacy Policy applies to The Hashgraph Group AG, Zentrum Staldenbach 5, 8808 Pfäffikon SZ, Switzerland, UID CHE : CHE- 431.653.200, info@hashgraph-group.com, and its subsidiaries («The Hashgraph Group AG», «we» or «us»). We understand that the privacy of the visitors of this website is important – we respect and are strongly committed to protect it. We are responsible for the collection, processing and use of your personal data as a user (hereinafter “user” or “you”) and compliance with applicable law. The information and data thus provided by users is stored on servers in Switzerland.
The "controller" of data processing as described in this privacy policy (i.e. the responsible person) is The Hashgraph Group AG unless we have informed you differently in certain cases. You can notify us of any data protection related concerns, irrespective of the concerned affiliate company of The Hashgraph Group AG, using the contact details:
The Hashgraph Group AG
Zentrum Staldenbach 5
8808 Pfäffikon SZ
Switzerland
info@hashgraph-group.com
Collection and Processing of Personal Data
We primarily process personal data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our websites and other applications.
Please find below information about the collection of personal data when using our website.
When you contact us by email, the personal data you provide is saved by us so that we can answer your questions. We shall delete the data received in this situation once it is no longer required to store the data, or restrict the processing if legal storage obligations exist.
Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., land registries, commercial registers, press, internet) or we may receive such information from affiliated companies of The Hashgraph Group AG, from authorities or other third parties. Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities (e.g., in order to conclude and carry out contracts with your employer), information about you in correspondence and discussions with third parties, credit rating information (if we conduct business activities with you personally), information about you given to us by individuals associated with you (consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery-address, powers of attorney), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g., payments made, previous purchases), information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with job applications, media reviews, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).
Purpose of Data Processing and Legal Grounds
We fundamentally only process your personal data if this is necessary to provide a functioning website and for our content and services. The processing of your personal data is only done regularly once your consent has been obtained. There is an exception to this in cases where obtaining your consent in advance is not possible due to practical reasons, and the processing of the data is permitted by legal provisions.
We primarily use collected data in order to conclude and process contracts with our clients and business partners, in particular in connection with our offered Grant Program to our partners and the procurement of products and services from our suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations.
providing and developing our products, services and websites, apps and other platforms, on which we are active;
communication with third parties and processing of their requests;
review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
market and opinion research, media surveillance;
asserting legal claims and defense in legal disputes and official proceedings;
prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
ensuring our operation, including our IT, our websites, apps and other appliances;
video surveillance to protect our domiciliary rights and other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals and assets owner by or entrusted to us (such as e.g. access controls, visitor logs, network and mail scanners, telephone recordings);
acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations.
If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or carrying out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.
If we obtain your consent for the processing of your personal data, Art. 6, paragraph 1a GDPR serves as the legal basis for the processing. If the processing is necessary to protect a justified interest of our company, and if the afore-mentioned interest does not outweigh your interests, basic rights and freedom, then Art. 6, paragraph 1f GDPR serves as the legal basis for the processing.
Cookies / Tracking and Other Techniques Regarding the Use of our Website
We typically use "cookies" and similar techniques on our websites, which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website. If you revisit our website, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the website ("session cookies"), we may use cookies in order to save user configurations and other information for a certain time period ("permanent cookies"). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies.
We use permanent cookies for the purpose of saving user configuration (e.g., language, automated log in), in order to understand how you use our services and content, and to enable to show you customized offers and advertisement (which may also happen on websites of other companies; should your identity be known to us, such companies will not learn your identity from us; they will only know that the same user is visiting their website has previously visited a certain website). If you block cookies, it is possible that certain functions (such as, e.g., language settings, shopping basket, ordering processes) are no longer available to you.
In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing e-mails. If such image files are retrieved from our servers, we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting.
By using our websites and consenting to the receipt of newsletters and other marketing e-mails you agree to our use of such techniques. If you object, you must configure your browser or e-mail program accordingly.
If you merely use the website for informational purposes, i.e. if you do not register or transfer us information in any other way, we will only collect the personal data that is transferred by your browser to our server. If you want to view our website, our system collects the following data, which is technically necessary for us to show you our website and ensure stability and safety:
Your IP address
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
The data volume transferred
The website where the request comes from
Operating system and its interface
Language and version of the browser software
The data is also saved in the log files of our system as well as on the system of our hosting provider Swisscom. For additional policies, we refer to their GDPR information page, available at
https://www.swisscom.ch/content/dam/swisscom/nl/rechtliches/res/datenschutzbestimmungende02-2024.pdf.
As the recording of data is mandatory for us to provide the website, and the saving of data in log files is mandatory for the operation of the website, there is no right of objection.
Newsletter
If you wish to receive the newsletter offered on our website, we need your email address, first and last name, and information which allows us to check that you are the owner of the specified email address and you agree to the receipt of the newsletter.
The processing of data is done exclusively on the basis of your consent as per Art. 6, paragraph 1a GDPR. You can revoke the consent you have given for the saving of data, the e-mail address and the use of the address to send the newsletter at any time.
The legality of the data protection processes already carried out remains unaffected by the revocation. The data about you we have saved for the purpose of sending the newsletter is stored until you are removed from the distribution list of the newsletter, and is deleted after the newsletter is unsubscribed from.
Your personal data is stored by us on the servers of the cloud-based database management services we engage in, located in Switzerland and the European Union.
Google- Analytics or other statistics providers
We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google Ireland Ltd. (located in Ireland), Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both «Google»), www.google.com) and which allow us to measure and evaluate the use of our website (on an anonymized basis). For this purpose, permanent cookies are used, which are set by the service provider.
We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals» option. Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not any personal information of you).
Google Tag Manager (GTM”) is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behaviour: to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our website for Google Analytics.
If you have performed deactivation, GTM takes this deactivation into account. For more information about GTM’s privacy practices can be found at
https://policies.google.com/privacy?hl=en
and terms of use at
https://www.google.com/analytics/tag-manager/use-policy/.
The legal basis for the processing of personal data by using cookies from Google Analytics is Art. 6, paragraph 1 f, GDPR.
In addition, we may use plug-ins from social networks such as Facebook, Twitter, Youtube, Pinterest or Instagram on our websites. This is visible for you (typically based on the respective symbols). We have configured these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks may record that you are on our website and where on our website you are exactly and may use this information for their own purposes. This processing of your personal data lays in the responsibility of the respective operator and occurs according to its data protection regulations. We do not receive any information about you from the respective operator.
Collection of personal data when onboarding
We will only collect the personal data that is submitted:
Desired category to be onboarded
Your declaration of beneficial ownership (in case you are a private qualified investor)
Your country of Incorporation (for legal entities)
Your country of Domicile (in case you are a private qualified investor)
Your person as a US person
Your declaration regarding fulfilment of technical requirements for digital onboarding
Full Name
Email Address
Phone Number
Type of legal entity (for legal entities)
The legal basis for the processing of personal data is Art. 6, paragraph 1 a, GDPR.
Your personal data shall be used to contact either by email or telephone for the purpose of onboarding.
Your personal data is stored by us on the servers of the cloud-based database management services we engage, located in Switzerland and the European Union.
Datatransfer and Transfer of Data Abroad
We store personal data on servers located in Switzerland. In the context of our business activities and in line with the purposes of the data processing, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes.We may transfer personal data to reputable third party organisations situated inside or outside Switzerland when we have a business reason to engage these organisations.
Each organisation is required to safeguard personal data in accordance with our contractual obligations and applicable data protection legislation. Such safeguards may include transfer to countries that have been deemed to provide an adequate level of protection according to lists of countries published by the Federal Data Protection and Information Commissioner; applying standard data protection model clauses, binding corporate rules or other standard contractual obligations which provide for appropriate protection of data.
In particular, the following categories of recipients may be concerned:
our service providers;
suppliers, subcontractors and other business partners;
clients;
domestic and foreign authorities or courts;
the media;
the public, including users of our websites and social media;
competitors, industry organizations, associations, organizations and other bodies;
other parties in possible or pending legal proceedings;
affiliates of The Hashgraph Group AG.
Retention Period of your Personal Data
We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes).
As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).
Data Security
We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as internal policies, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization.
We secure our website and other systems using suitable technical and organizational measures to prevent the loss, destruction, access, modification or distribution of your data by unauthorised people. Despite regular checks, complete protection against all hazards is, however, not possible.
Obligation to Provide Personal Data To Us
In the context of our business relationship you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).
Your Rights
In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent above. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.
In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.
In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
Your rights when using our website and/or submitting data
You are entitled to the following rights with regards to your personal data:
Right to information about the personal data we have saved about you
Right to the correction or deletion of data
Right to the restriction of data processing
Right to the objection to data processing
Right to data transferability
If you want to exercise any of the above rights, please email us at info@hashgraph-group.com
Amendments of this Privacy Policy
We regularly review this Privacy Policy and will post any updates to it on this webpage. We may amend this Privacy Policy at any time without prior notice. The current version published on our website shall apply. This Privacy Policy was last updated on August 14, 2024.