In this privacy statement, we explain how mcw-consulting GmbH collects and processes personal data. This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation and similar documents may regulate specific circumstances. By personal data we mean all information relating to a specific or identifiable person. If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of the present data protection declaration and provide us with their personal data only if you are allowed to do so and if this personal data is correct.

This Privacy Policy is based on the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union, it is of importance to us. The Swiss Data Protection Act (DSG) is strongly influenced by EU law, and companies outside the European Union or the EEA must comply with the GDPR under certain circumstances.

1. Responsible Person / Data Protection Officer / Representative
The person responsible does not have a data protection officer according to Art. 37 GDPR. mcw-consulting GmbH is responsible for the data processing described here, unless otherwise stated in individual cases. If you have any concerns regarding data protection, you can send them to us at the following contact address: info@mcw-consulting.

2. Collection And Processing Of Personal Data
We primarily collect and store personal data for example, data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages called up and contents, functions used, referring website, location information).

3. Purposes Of Data Processing And Legal Bases
We use the personal data collected by us primarily to conclude and process our contracts with our customers and business partners, in particular within the scope of all services that we provide within the scope of Finny apps and Finny Digital Moneybox, and the purchase of products and services from our suppliers and subcontractors, as well as to fulfil our legal obligations at home and abroad. If you work for such a customer or business partner, you may of course also be affected in this function with your personal data. In addition, we process personal data from you and other persons, to the extent permitted and as we deem appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest:

• Offer and further development of our offers, services and websites, apps and other platforms on which we are present;
• Communication with third parties and processing of their enquiries (e.g. applications, media enquiries);
• Advertising and marketing (including the execution of events), as long as you have agreed to the use of your data for these purposes (you can object at any time, we will put you on a blacklist against further advertising mailings);
• Market and opinion research, media monitoring;
• Assertion of legal claims and defence in connection with legal disputes and official proceedings;
• Prevention and clarification of criminal offences and other misconduct (e.g. conducting internal investigations, data analyses to combat fraud);
• Warranties of our operations, in particular IT, our websites, apps and other platforms;
• Safeguarding the right of domicile through access controls and visitor lists and other measures for IT, building and plant security and protection of our employees and other persons and assets belonging to or entrusted to us (e.g. network and mail scanners);
• Purchase and sale of business units, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and insofar as compliance with legal and regulatory obligations as well as internal regulations of Mcw-consulting GmbH is required. If you have given us permission to process your personal data for certain purposes (e.g. to receive advertising for new products), we will process your personal data within the scope and on the basis of this permission, unless we have another legal basis and we need one. A given consent can be revoked at any time, but this has no effect on data processing that has already taken place.

4. Who Has Access To The Personal Data?
Access to your data may be gained both inside and outside our company. Within the company, only positions or employees may process your data if they need it to fulfil our contractual or legal obligations and to safeguard legitimate interests.

5. Cookies / Tracking And Other Technologies Related To The Use Of Our Website
We typically use “cookies” and similar techniques on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser used when you visit our website. When you return to this site, we may recognize you even if we do not know who you are. In addition to cookies, which are only used during a session and are deleted after your visit to our website (“session cookies”), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) (“permanent cookies”). However, you can set your browser so that it rejects cookies, saves them only for one session or otherwise deletes them prematurely. Most browsers by default accept cookies. We use permanent cookies so that you save user settings (e.g. language, autologin) so that we can better understand how you use our offers and content and so that we can display offers and advertising tailored to you (which can also happen on websites of other companies; however, we will not tell them who you are if we ourselves know this, because they only see that on their website is the same user who was on a particular page with us). Some of the cookies are set by us, some by contractors with whom we work. If you block cookies, certain functions (e.g. language selection, shopping cart, ordering processes) may no longer work.
In our newsletters and other marketing e-mails, we include visible and invisible picture elements to some extent and to the extent permitted. By retrieving these elements 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 can use our offers and tailor them to you. You can block this in your email program; most are preset to do so. By using our websites and consenting to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not wish to do so, you must set your browser or email program accordingly.

6. Google Analytics
We sometimes use Google Analytics or comparable services on our websites. This is a service provided by third parties, which may be located in any country of the world (in the case of Google Analytics, it is Google LLC in the USA, www.google.com), with which we can measure and evaluate the use of the website (not personal). Permanent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us (nor does it keep any IP addresses), but can track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by service providers, and use this information for its own purposes (e.g. advertising control). If you have registered with the Service Provider yourself, the Service Provider will also know you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider merely informs us how our respective website is used (no information about you personally).

7. Social Media
We also use so-called plug-ins from social networks such as Facebook, Twitter, Youtube, LinkedIn or others, on our websites. This can be seen in each case (typically via corresponding symbols). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

8. Duration Of The Storage Of Personal Data
We process and store your personal data for as long as it is necessary for the fulfilment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond that in accordance with the legal storage and documentation obligations. It is possible that personal data may be stored for the period in which the claim is made. It is possible that personal data may be stored for the period in which claims can be asserted against our company and to the extent that we are otherwise legally obliged to do so or justified business interests require it (e.g. for purposes of proof and documentation). If the data are no longer required for the fulfilment of contractual or legal obligations or for the protection of our legitimate interests (achievement of purpose) or if a consent given is revoked, they will be deleted, unless further processing is necessary due to the contractual or legal retention periods and documentation obligations or for reasons of preservation of evidence during the duration of the applicable statute of limitations.

9. Data Security
We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, controls.

10. Obligation To Provide Personal Data
As part of our business relationship, you must provide the personal information necessary to establish and conduct a business relationship and to fulfil the contractual obligations associated therewith (you do not normally have a legal obligation to provide us with information). Without this information, we will generally not be able to enter into or complete a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

11. Profiling And Automated Decision-Making
In principle, we do not use fully automated automatic decision-making for the establishment and implementation of the business relationship or otherwise (as regulated in Art. 22 GDPR, for example). Should we use such procedures in individual cases, we will inform you of this separately, insofar as this is prescribed by law, and inform you of the rights associated with it. 12 Rights Of The Data Subject You have the right to information, correction, deletion, the right to restrict data processing and otherwise object to our data processing and to the surrender of certain personal data for the purpose of transfer to another location (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the statutory restrictions on our part, for example if we are obliged to store or process certain data, if we have an overriding interest in it (to the extent that we may invoke it) or if we need it for the assertion of claims. If you incur any costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that the exercise of these rights may conflict with contractual agreements and this may have consequences such as premature termination of the contract or cost consequences. In this case, we will inform you in advance if this has not already been contractually agreed. As a rule, the exercise of such rights requires that you prove your identity unambiguously (e.g. by means of a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To exercise your rights you may contact us at the address set out in paragraph 1. In addition, every data subject has the right to assert his or her claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner ( https://www.edoeb.admin.ch ).

13. Amendments
We may change this privacy statement at any time without notice. The current version published on our website applies.

mcw-consulting GmbH

Stationsstrasse 35
8606 Nänikon
Switzerland

The impressum can be found here: https://mcw-consulting.ch/impressum/