Privacy Policy of Reconciliachain AG (in process of founding)

Version effective as of 05.12.2024

With this Privacy policy we, the Reconciliachain AG, having its registered office in Zurich, Switzerland (in the course of being incorporated) (hereinafter Reconciliachain, we or us), describe how we collect and further process personal data. This Privacy policy is not necessarily a comprehensive description of our data processing. It is possible that other privacy policies or General Terms and Conditions, Conditions of Participation or similar documents are applicable to specific circumstances.

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 (such as family members, work colleagues), 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») and the Swiss Data Protection Act («DPA»). However, the application of these laws depends on each individual case.

1. Controller / Data Protection Officer / Representative

The "controller" of data processing as described in this privacy policy (i.e. the responsible person) is Reconciliachain. You can notify us of any data protection related concerns using the following contact details: info@reconciliachain.com.

2. 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, software, apps and other applications. The personal data we process include in particular:

• First name
• Last name
• Address (residence)
• Email address
• Bank account number

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., debt registers, land registries, commercial registers, press, internet) or we may receive such information 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 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.), 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).

3. Purpose of Data Processing and Legal Grounds

We primarily use collected data in order to conclude and process contracts with our clients and business partners, in particular in connection with the usage of Reconciliachain’s automated and AI-aided data integrity software by our clients and business partners as well the provision of services by Reconciliachain 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. You may be affected by our data processing in your capacity as an employee of such a client or business partner.

In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:

• Providing and developing our products, technologies, services and websites, apps and other platforms, on which we are active
• 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
• Ensuring our operation, including our IT, our websites, apps and other appliances

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.

4. Cookies / Tracking and Other Techniques Regarding the Use of our Website

We typically use "cookies" and similar techniques on our websites, software and apps, 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 or install our software or apps...

5. Data Transfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, 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...

6. Retention Periods for 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...

7. Data Security

We have taken adequate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as IT and network security solutions, access controls and restrictions, and encryption of data carriers and transmissions.