Imprint & Data Protection

Finoa Aktiengesellschaft (“FinoaAG”) respects and protects the privacy of the visitors to FinoaAG’s website and FinoaAG’s clients who use FinoaAG’s Services. To ensure transparency, this Privacy Policy describes FinoaAG’s (and its subsidiaries) information handling practices when you access content of FinoaAG’s website located at finoa.io (https://finoa.io/), and when you are a client of FinoaAG.

Acceptance of the privacy policy

By accessing and using FinoaAG’s Services, you signify that you have reviewed the terms of this Privacy Policy. Where FinoaAG requires your consent to process your personal information, FinoaAG will ask for your consent to the collection, use, and disclosure of your personal information as described further below. FinoaAG may provide additional “just-in-time” disclosures or additional information about the data collection, use, and sharing practices of specific Services. These notices may supplement or clarify FinoaAG’s privacy practices, or may provide you with additional choices about how FinoaAG processes your data.

If you do not agree with, or you are not comfortable with, any aspect of this Privacy Policy, you should immediately discontinue access or use of FinoaAG’s Services.

Changes to this privacy policy

FinoaAG reserves the right to modify this Privacy Policy at any time, and when required by law, FinoaAG will notify you of changes to this Privacy Policy. If FinoaAG makes any material changes, FinoaAG will notify you by email (sent to the email address specified in our database), or by means of a notice on FinoaAG’s Services prior to the change becoming effective.

Personal information collected by FinoaAG

Personal information is data that can be used to identify you directly or indirectly, or to contact you. FinoaAG’s Privacy Policy covers all personal information that you voluntarily submit to FinoaAG and that FinoaAG obtains from FinoaAG’s partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you.

You may be asked to provide personal information at any time that you are in contact with FinoaAG.. Finoa AG may also combine your personal information with other information to provide and improve FinoaAG’s products, services, and content (see the section below).

Except as described in this Privacy Policy, FinoaAG will not give, sell, rent, or loan any personal information to any third party.

Personal information collected

FinoaAG collects personal information to provide you with FinoaAG’s Services. When FinoaAG requires specific personal information from users, it is because such information is relevant for certain purposes. Any information you provide to FinoaAG that is not required is voluntary.

For example, FinoaAG collects personal information when you use or request information about FinoaAG’s Services, subscribe to marketing communications, request support, complete surveys, or sign up for a FinoaAG event or webinar. FinoaAG may also collect personal information from you offline, such as when you attend one of FinoaAG’s events, or when you contact FinoaAG employees. FinoaAG may use this information in combination with other information FinoaAG collects about you.

You are free to choose whether to provide FinoaAG with the types of personal information described below, but FinoaAG may not be able to serve you as effectively, or offer you some or all of FinoaAG’s Services, when you choose not to share certain information with FinoaAG.

Here are some examples of the types of personal information FinoaAG collects and how FinoaAG may use it:

• When you become a Client of FinoaAG, FinoaAG, or FinoaAG’s external service provider may collect personal information. The following information may be collected: your name, date of birth, driver number, personal ID or passport, address, phone, email, full bank account details, tax or corporate identification number, company legal status, information that FinoaAG needs for establishing the controlling person of operating legal entities and partnerships or regarding the identity of the beneficial owner of non-operating entities or information regarding individuals with signatory powers (first and last name, address, email, curriculum vitae), or authorised traders (first and last name, nationality, date of birth, etc.). FinoaAG will use this information to fulfil your requests and provide the relevant Services.

• Whenever you contact FinoaAG or respond to FinoaAG’s communications (e.g., email, telephone, in writing), FinoaAG will receive your contact information and any other personal information you choose to provide FinoaAG. FinoaAG will use such information to fulfil your requests or to provide Services.

How personal information is used

FinoaAG’s primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, FinoaAG uses personal information to create, develop, operate, deliver, and improve FinoaAG’s Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how FinoaAG may use this information include:

• To provide you with FinoaAG Services and the client support that you request.
• To process transactions and send notices about your transactions.
• To verify your identity by comparing your personal information against third-party databases.
• To send administrative or account-related information to you.
• To better understand FinoaAG’s clients and the way they use and interact with FinoaAG-owned and/or FinoaAG-operated websites and Services.
• To provide a personalised experience, and to implement the preferences that you request.
• To customise, measure, and improve FinoaAG and the content and layout of FinoaAG’s website and applications.
• To enhance security, prevent fraud, monitor and verify identity or service access, and to combat spam or other malware or security risks.
• To deliver marketing, service update notices, and promotional offers based on your communication preferences.
• To communicate with you about FinoaAG’s events and/or FinoaAG’s partner events.
• To prevent and investigate potentially prohibited or illegal activities, and/or violations of FinoaAG’s posted user terms.
• To resolve disputes, collect fees, and troubleshoot problems.
• To comply with legal obligations.
• To enforce FinoaAG’s agreements with third parties.
• For quality control and staff training.

FinoaAG will not use your personal information for purposes other than those FinoaAG has disclosed to you without your permission. From time to time, FinoaAG may request your permission to allow FinoaAG to share your personal information with third parties. You may choose not to have your personal information shared with third parties where FinoaAG relies on consent as the lawful basis for processing your personal information. You may also choose not to allow FinoaAG to use your personal information for any purpose that is incompatible with the purposes for which FinoaAG originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or FinoaAG Services may not be available to you.

Information from third party sources

From time to time, FinoaAG may obtain information about you from third party sources as permitted by applicable law, such as public databases and ID verification partners: FinoaAG obtains information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. The legal basis for such processing is to comply with FinoaAG’s legal obligations, such as anti-money laundering laws. In some cases, FinoaAG may process additional data about you based on public interest grounds to ensure FinoaAG’s Services are not used fraudulently or for other illicit activities.

FinoaAG also processes such information to provide support to you as part of FinoaAG’s contractual obligations to you. Lastly, FinoaAG processes such information in the public interest because it helps FinoaAG monitor, prevent, and detect fraud.

Once FinoaAG obtains such information from third parties, FinoaAG will not subsequently share it with any other third parties except as described in this Privacy Policy. This information is shared with FinoaAG’s processors and corporate group, as necessary, to perform the Services.

Collection and use of information collected automatically

FinoaAG receives and stores certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer, among other), and your Internet Protocol (IP) address/MAC address/device identifier.

For example, FinoaAG automatically receives and records information on FinoaAG’s server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g., country or city-level location), and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. FinoaAG may also collect information about how your device has interacted with FinoaAG’s website, including pages accessed and links clicked. FinoaAG may use identifiers to recognise you when you arrive at the website via an external link, such as a link appearing on a third-party site.

Please refer to the FinoaAG Cookie Policy ( https://finoa.io/) for more information about FinoaAG’s use of cookies.

How FinoaAG protects and stores personal information

FinoaAG understands how important your privacy is, which is why FinoaAG maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to FinoaAG.

FinoaAG may store and process all or part of your personal and transactional information, including certain payment information, in Switzerland, and elsewhere in the world, where FinoaAG’s service providers are located. FinoaAG protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

However, FinoaAG cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with FinoaAG’s Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to notify FinoaAG immediately if you become aware of any unauthorised access to or use of your account.

Furthermore, FinoaAG cannot ensure or warrant the security or confidentiality of information you transmit to FinoaAG or receive from FinoaAG by Internet or wireless connection, including email, phone, or SMS, since FinoaAG has no way of protecting that information once it leaves and until it reaches FinoaAG. If you have reason to believe that your data is no longer secure, please contact FinoaAG at the email address, mailing address, or telephone number listed at the end of this Privacy Policy.

How FinoaAG protects and stores personal information

FinoaAG takes care to allow your personal information to be accessed only by those who really need to to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. FinoaAG will never sell or rent your personal information. FinoaAG will only share your data in the following circumstances:

• FinoaAG may share your information with service providers under contract who help with parts of FinoaAG’s business operations such as marketing and technology services. FinoaAG’s contracts require these service providers to only use your information in connection with the services they perform for FinoaAG, and prohibit them from selling your information to anyone else.
• FinoaAG shares your information with financial institutions with which FinoaAG partners to process payments you have authorised.
• FinoaAG may share your information with companies, or other entities that FinoaAG plans to merge with or be acquired by. Should such a combination occur, FinoaAG will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.
• FinoaAG may share your information with any third parties where required to do so by applicable law or any court or other authority to which FinoaAG is subject in any jurisdiction; or FinoaAG believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the FinoaAG Agreements and any other applicable policies.
• FinoaAG may share your information with other third parties with your consent or direction to do so.

How FinoaAG share personal information with other parties

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting FinoaAG employees. However, this right is limited where personal information is needed for regulatory purposes.

If you decide to end your client relationship, FinoaAG will mark your account in FinoaAG’s database as “Closed,” but will keep your account information in FinoaAG’s database for a period of time as allowed by applicable law. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by FinoaAG for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

Rights in the relation to the use of your personal information

You have a right of access to the personal information that FinoaAG holds about you under the Federal Act on Data Protection (and the General Data Protection Regulation) and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

You can object to FinoaAG’s use of your personal information for direct marketing purposes at any time, and you may have the right to object to FinoaAG’s processing of some or all of your personal information (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please contact FinoaAG as set out below.

Retention of personal information

FinoaAG will retain your personal data for as long as is necessary for the purposes of FinoaAG’s business relationship with you, to perform FinoaAG’s contractual obligations to you, or if longer, as required for legal and regulatory purposes.

FinoaAG has established internal policies for the deletion of data from client accounts following termination of a client’s subscription to a Service.

Changes to this privacy policy

FinoaAG may periodically post changes to this Privacy Policy on this page. FinoaAG encourages you to visit this page often. When required by law, FinoaAG will notify you of any changes to this Privacy Policy. If FinoaAG makes any material changes FinoaAG will notify you by email (sent to the email address specified in your account), or by means of a notice on FinoaAG’s Services prior to the change becoming effective.

How to contact us

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you may contact at any time your client relationship manager, or you may contact FinoaAG via hello@finoa.io.

Terms and Conditions of Use

Consent

Please read the following legal notice / terms and conditions of use (“Terms and Conditions of Use”) carefully before accessing the website of Finoa AG (“FinoaAG”). By accessing the website of FinoaAG, you confirm that you have read and understood the Terms and Conditions of Use and agree to all of the terms set out herein. If you do not understand, or do not agree to any of the terms contained in the Terms and Conditions of Use, please exit the website of FinoaAG.

Restricted access

The website of FinoaAG must not be accessed by any person subject to a jurisdiction (e.g., due to that person’s nationality and/or place of residence) in which publication of the content of the website of FinoaAG or access to it is prohibited for any reason. Persons to whom these restrictions apply are prohibited from accessing this website.

No offer

Information and opinions published on this website shall not be construed as any form of promotion, recommendation, inducement, offer, or solicitation to (i) purchase or sell any cryptocurrencies, (ii) transact any other business, or (iii) enter into any other legal transactions. Information and opinions published on this website are provided for information purposes only. Services described may not be suitable for you or may be unavailable.

No advice

Information and opinions published on this website do not constitute, nor are they intended to provide or be construed as investment advice, or any legal, tax, financial, or other advice. Such information and opinions should not be relied upon or used as a basis for decision-making. Please consult an expert in the appropriate field before deciding to take any specific action. No information contained on or accessed from the website of FinoaAG should be construed as creating any contractual relationship between the providers of such information and website users.

No warranty

FinoaAG has exercised the utmost care in compiling the information contained on this website. Information provided on this website is constantly updated and checked for accuracy. However, neither FinoaAG nor its contracting partners makes any representation or warranty (whether express or implied) that any information published on the website of FinoaAG is accurate, reliable, up-to-date, or complete. In particular, FinoaAG is under no obligation whatsoever to update or remove outdated information or opinions from this website or to mark them as being outdated. The information and opinions contained on this website are subject to change at any time without notice.

Moreover, no warranty is given that this website will operate error free or without interruption, that any faults will be corrected, or that this website and servers from which information is accessible will be free of viruses, trojan horses, worms, software bombs, or other harmful components and programs, and FinoaAG accepts no liability in respect thereof.

All information available on this website, including but not limited to financial market data, price data, reports, research, and other financial information is based on carefully selected sources that are deemed to be reliable. All information is provided to users on an “as is” and “as available” basis without any representation or warranty either express or implied as to quality, originality, non-infringement of intellectual property rights, or fitness for a particular purpose.

Risk Disclosure

Investing in cryptocurrencies entails risks. If you are not familiar with the risks, we kindly ask you to leave this website. If you understand the risks involved in investing in cryptocurrencies, you confirm that you are able to take these risks. Trading in cryptocurrencies bears the risk of total loss of the amount invested. Cryptocurrencies are very volatile and therefore may fluctuate extremely in a short period of time.

No liability

FinoaAG gives no warranty that the information provided on its website is up-to-date, accurate or complete, and accepts no liability in respect thereof. FinoaAG shall not be liable for any direct or indirect loss or damage, including but not limited to loss of profit, that may be suffered as a result of information provided on this website, or for any loss or damage resulting either directly or indirectly from use of this website and the information contained therein or from risks associated with the financial markets. FinoaAG shall only be liable for loss or damage attributable to ordinary negligence if such loss or damage was foreseeable. Liability for consequential loss and loss of profit is hereby excluded.

Intellectual property, copyright, and trade mark rights

All components of the website of FinoaAG are protected by intellectual property laws and are the property of FinoaAG or third parties. Users shall not acquire any rights, including rights in or to any software, trademarks or components of the FinoaAG website, by downloading or printing any material from this website. Copyright notices and trademarks may not be changed or removed. Components of this website may not be reproduced in whole or in part in any manner or form (including electronic or printed form) without the prior written consent of FinoaAG and unless full acknowledgement of the source is provided.

Users are not permitted to create hyperlinks or inline links from other websites to the website of FinoaAG without the prior written consent of FinoaAG.

Potential conflicts of interest

FinoaAG, its founders/directors or employees may have previously invested, may be currently investing, or may in future invest in cryptocurrencies in respect of which information or opinions are provided on the website of FinoaAG. It is also possible that FinoaAG has previously provided, is currently providing, or will in future provide services to the issuers of such cryptocurrencies. Furthermore, it is possible that employees or directors of FinoaAG have previously performed, are currently performing, or will in future perform certain functions on behalf of the issuers of such cryptocurrencies.

Links to other websites

The website of FinoaAG may contain links to the websites of other providers and information supplied by such providers (“External Links”). FinoaAG provides links to external websites in addition to its own information solely with a view to enhancing user-friendliness and providing information to users. FinoaAG has no control over the content of such external websites and accepts no responsibility or liability in respect of the accuracy, reliability, completeness, truth, or currency of such material or its fitness for a particular purpose. FinoaAG excludes all liability, including but not limited to liability for any direct or indirect loss or damage or any consequences that may arise out of or in connection with the use of content on external websites. Although linked sites are carefully selected, FinoaAG has no control over the content of such sites. Accordingly, FinoaAG accepts no liability in respect of the content of External Links, including in particular any content that is altered after the link was created. FinoaAG is not responsible for transferring such information, selecting the information sent or the recipients thereof, or altering any information provided. Such External Links are not automatically stored by FinoaAG on a temporary basis due to the method used for creating and accessing links. Operators of websites accessible through the External Links are therefore solely responsible for the content of linked sites.

Moreover, FinoaAG gives no warranty that such websites or the contents thereof do not or will not infringe any third-party copyright, trademark or other rights, or that such websites or the contents thereof are free of viruses or other harmful components. No warranty is given as to the authenticity of any documents available on the Internet.

Changes to the Terms and Conditions of Use

FinoaAG reserves the right to change these Terms and Conditions of Use from time to time. Please read these Terms and Conditions of Use whenever you access the website of FinoaAG to ensure that you agree to the terms of any amended version. If you do not understand, or do not agree with any of the terms contained in the Terms and Conditions of Use currently in effect, please exit the website of FinoaAG.

Assignment and delegation

Both FinoaAG and its legal successors and agents are entitled to rely on these Terms and Conditions of Use. FinoaAG may assign any rights accruing to it under these Terms and Conditions of Use. FinoaAG may also delegate its duties or assign any of its obligations under these Terms and Conditions to third parties.

Applicable law / place of jurisdiction

Access to and use of the website as well as the Terms and Conditions of Use shall be governed by and construed in accordance with Swiss law, with Zug as the place of jurisdiction.

Please also read our Privacy Policy, which explains how personal information you provide to us will be used.