1. What is this Privacy Notice about? 

The Hashgraph Group AG, Zentrum Staldenbach 5, CH-8808 Pfäffikon SZ ("THG", "we", "us") collects and processes personal data that concern you but also other individuals ("third parties"). We use the word "data" here interchangeably with "personal data". 

In this Privacy Notice, we describe what we do with your data when you visit https://www.hashgraph-group.com or other websites or apps maintained by us (collectively "website"), use any of our digital and other services ("Services"), interact with us in relation to a contract, communicate with us, or otherwise deal with us.  

In addition, we may inform you about the processing of your data separately, if needed. 

If you disclose data about other persons (e.g. work colleagues) to us, we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.  

This Privacy Notice is aligned with the Swiss Data Protection Act ("DPA"), the Ordinances associated with it and the EU General Data Protection Regulation ("GDPR"). However, the application of these laws depends on each individual case. 

2. Who is the controller for processing your data? 

The Hashgraph Group AG, Zentrum Staldenbach 5, 8808 Pfäffikon SZ, Switzerland ("THG") is the controller for the processing activities under this Privacy Notice, unless we tell you otherwise in an individual case,  
You may contact us for data protection concerns and to exercise your rights as follows: 

The Hashgraph Group AG  
Zentrum Staldenbach 5 
CH-8808 Pfäffikon SZ 
info@hashgraph-group.com 
+4155 415 01 81

3. What data do we process? 

We process various categories of data about you. The main categories of data are the following:  

• Master data: This is the basic data (e.g. name, contact details), additional information about you (e.g. your role and function) as well as details of your relationship with us (user of our Services, supplier, visitor, or employee of such etc.), your date of birth, copies of ID cards, payment and financial information (e.g. credit card and account numbers), signature authorizations and declarations of consent and information about third parties (e.g. contacts, representatives).  

• Registration data: This is data that is generated in the course of creating an account with us (e.g. online or newsletter) or that you provide to us in this context (e.g. user name, e-mail, password). This also includes the ID assigned to you by the Service that you register for.  

• Contract data: This is data that is collected in connection with a contract concluded by us or in the context of the provision of our Services, such as information about the type of contract, date of conclusion of the contract, duration of the contract, contractual services, data that was collected during the period leading up to the conclusion of the contract, information required or used for processing (e.g. information regarding invoicing), information about reactions, financial data (e.g. information about solvency/creditworthiness, about reminders and debt collection).  

• Communication data: When you are in contact with us or with third parties (e.g. by e-mail, telephone or by letter or other means of communication) we collect the data exchanged between you and us (e.g. content of e-mails or letters or of your posts), including your contact details and the metadata of the communication or if necessary the copy of an ID document. This includes audio and video recordings of calls. 

• Technical data: When you use our digital communication channels (e.g. website) or digital services (e.g. apps), we collect technical data e.g. the IP address, information about the operating system of your device, the location and the access time. Technical data in itself does not permit us to draw conclusions about your identity. However, technical data might be linked with other categories of data and thus possibly with your person. 

• Behavioral and preference data: This is data about your behavior and your preferences (e.g. your response to electronic communications, navigation on our website, interactions with our social media pages and your participation in sweepstakes, competitions etc.) we may also supplement this information with third-party information, including from public sources. We describe how tracking works on our website in Section 12. 

• Application data: This refers to data that we process as part of an application to us and which is contained, among other things, in your application documents (e.g. professional background, education and training, references). We may also obtain data from public sources, such as professional social networks, the internet or the media. 

• Other data: This may include the following data: Data collected in connection with administrative or legal proceedings (e.g. actions, evidence, etc.), photographs, videos or sound recordings that we produce or receive from third parties and in which you are recognizable (e.g. at events, through security cameras, etc.), access data or rights (e.g. visitor list, when you enter certain buildings or which access rights you have), participation in events or campaigns (e.g. sweepstakes), when you use our infrastructure and systems as well as data in connection with your status as a shareholder or investor of ours (e.g. information for various registers, the exercise of your rights and the holding of events such as general meetings).  

  
  

4. What is the source of the data? 

• From you: Much of the data set out in Section 3 is provided to us by you (e.g. when you communicate with us, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases (e.g. because of legal requirements or legally required identification). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contract. When using our website and apps and other digital services, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent. 

• From third parties: As far as it is lawful we can also collect data from public sources (e.g. debt collection registers, commercial registers, the media, or the internet including social media) or receive data from public authorities and from other third parties (e.g. credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.). This includes the following categories of data: master data, contract data and other data according to Section 3 as well as data from correspondence and discussions with third parties. If you work for an employer, client or someone else who has a business relationship or other dealings with us, they may also provide us with information about you. 

5. For what purposes do we process your data?  

• Communication: In order to be able to communicate with you (e.g. to answer inquiries as well as the execution of a contract which includes the provision of support), we need to process data (in particular communication, master data and registration data) from you. If we need or want to establish your identity, we collect additional data (e.g. a copy of an ID document).  

• Initiation, administration and execution of contracts: In connection with the conclusion or execution of contracts with our suppliers, subcontractors or other contractual partners (e.g. project partners), we process related personal data. For this purpose, we also process data for checking creditworthiness. This also includes the enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.), accounting, termination of contracts and public communication. For this purpose, we use in particular master data, contract data and communication data, as well as technical data (e.g. in the case of digital offers). 

• Marketing purposes and relationship management: For marketing purposes and relationship management, we process data, for example, to send the users of our digital services and other contractual partners and interested parties personalized advertising (e.g. in print, by e-mail, via app, or on other digital channels) about services and other news from us and from third parties (e.g. from business partners), in connection with free services (e.g. invitations, vouchers, etc.) or as part of individual marketing campaigns (e.g. events, competitions, etc.). You can refuse such contacts at any time or refuse or revoke your consent to be contacted for advertising purposes by notifying us (Section 2). With your consent, we can target our online advertising on the Internet more specifically to you (see Section 12). This also includes interaction with existing counterparties and their contacts, which can be personalized on the basis of behavioral and preference data. As part of relationship management, we may also operate a counterparty relationship management (CRM) system in which we store the data of participants to our competitions and other events and applicants to our programs and business partners. Finally, we also enable contractual partners of ours to contact our contractual partners for advertising purposes (see Section 7). For marketing purposes and relationship management, we process in particular communication, registration, behavioral and preference data. 

• Website: In order to operate our website and digital services (including ensuring security and stability), we process technical data, such as IP address, information about the operating system of your terminal device, browser type and version, region and time of use, the name of the retrieved file, the amount of data transferred and the message about a successful retrieval. As a rule, this information does not contain any personal data. However, personal data that we or providers commissioned by us store from you (e.g., if you have a user account with us) may be linked to the technical data and thus possibly to your person.  

• Registration and security purposes as well as technical and physical access controls: In order to use certain Services (e.g. login areas), you must register (directly with us or via our external login service providers), for which we process data. Furthermore, we also collect additional personal data about you during the use of the Service. We continuously check and improve the appropriate security of our IT and our other infrastructure (e.g. buildings). We therefore process data, for example, for monitoring, controls, analyses and tests of our networks and IT infrastructures, for system and error checks, for documentation purposes and as part of security copies. Access controls include, on the one hand, controlling access to electronic systems (e.g. logging into user accounts), and on the other hand, physical access control (e.g. building access). For security purposes (preventive and incident investigation) we also keep access logs or visitor lists and use surveillance systems (e.g. security cameras). We inform you of surveillance systems at the relevant locations by means of appropriate signs. For this purpose, we process registration data (including biometric data) and technical data in particular, but also other data mentioned in Section 3. 

• Compliance with laws, directives and recommendations from authorities and internal regulations («Compliance»): We may process personal data as part of our compliance with laws (e.g. anti-money laundering, tax law obligations or for the implementation of health and safety concepts). In addition, data processing may take place in the course of internal investigations as well as external investigations (e.g. by a law enforcement or supervisory authority or an appointed private body). For this purpose, we process in particular master data, contract data and communication data, but under certain circumstances also behavioural data, technical data and data from other data categories. The legal obligations may be Swiss law, but also foreign regulations to which we are subject, as well as self-regulations, industry standards, our own «corporate governance» and official instructions and requests. 

• Risk management and corporate governance: We may process personal data as part of our risk management (e.g. to avoid becoming victims of crime and abuse) and corporate governance, including our business organization (e.g. resource planning) and corporate development (e.g. acquisition and sale of business units or companies). For this purpose, we process in particular master data, contract data, registration data and technical data, but also behavioral and communication data. 

• Application process: If you apply for a job with us, we collect and process the relevant data for the purpose of reviewing the application, conducting the application process, and, for successful applications, for the preparation and conclusion of a corresponding contract. Data processing in connection with the employment relationship is the subject of a separate privacy policy. 

• Organization and conduct of webinars and online events: We process personal data (e.g. name, contact details, company affiliation, interaction data during the event) to organize and conduct webinars and other online or hybrid events, including registration management, technical administration, participant communication and follow-up. Participants of webinars and online events may be included in our relationship management systems for the purpose of follow-up communication, business development and potential partnership discussions. The legal basis for this processing is our legitimate interest in maintaining and developing professional relationships pursuant to Art. 6(1)(f) GDPR. You have the right to object to such processing at any time. 

• Further purposes: These other purposes include, for example, training and educational purposes, administrative purposes (e.g. master data management or accounting), safeguarding our rights, and evaluating and improving internal processes. We may record telephone or video conferences for training, evidence, and quality assurance purposes. In such cases, we will notify you separately (e.g. by displaying a notice during the video conference in question) and you are free to tell us if you do not want to be recorded or to terminate the communication (if you simply do not want your image recorded, please turn off your camera). In general, such recordings may only be made and used in accordance with our internal guidelines. The protection of other legitimate interests is also one of the other purposes, which cannot be named exhaustively. We also process data in connection with your position as a shareholder or investor of ours (e.g. information for various registers, the exercise of your rights and the holding of events such as general meetings). If webinars or online events are recorded, participants will be informed prior to recording. Recordings may include names, profile images, voice contributions and shared content. Recording will only take place where legally permitted and, where required, based on consent. 

6. On what basis do we process your data? 

To the extent necessary and depending on the situation and processing purpose, we base the processing of your data on the following legal basis:

• Contract: Insofar as we process data for the conclusion and execution of contracts that we conclude or have concluded for you or with you or your employer, client or other persons for whom you work, this is also the legal basis on which we process your data. 

• Legal Obligations: We may further process your data based on applicable legal, regulatory and professional requirements with which we must comply. 

• Legitimate interest: We may process your data based on our legitimate interest or a legitimate interest of a third party. This applies in particular in relation to the achievement of the purposes and objectives set out in Section 5 and for the implementation of related measures. Among other things, we have a legitimate (and overriding) interest in marketing our Services and in gaining a better understanding of the markets relevant to us and our activities (in particular, in the efficient and secure handling of our processes and the further development of our activities), in the efficient and effective management of our company and in safeguarding the security of our systems and our interests vis-à-vis third parties.  

• Consent: If we ask for your consent to process data from you, this is the legal basis on which we process your data. In doing so, we will inform you of the purpose of the processing. You may revoke your consent at any time by notifying us in writing (by mail or, unless otherwise specified or agreed, by email), with effect for the future (see Section 2 regarding our contact details and Section 12 regarding revocation of your consent in the area of online tracking). Once we have received and processed your withdrawal, we will no longer process your data for the purposes to which you originally consented (unless further processing may be carried out on the basis of another legal basis).  

• Other legal bases: In specific cases, we may also carry out data processing based on other legal bases. If this is the case, we will inform you in each individual case. 
  
  

7. With whom do we share your data? 

In relation to our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes set out in Section 5, we may disclose your personal data to third parties, in particular to the following categories of recipients: 

• Group companies: Companies affiliated with us may use your data for the same purposes as we do, as described in this Privacy Policy (see Section 5). The recipients process the data under their own responsibility.  

• Service providers: We work with service providers locally and abroad (third parties) who process data about you (i) on our behalf, (ii) under joint responsibility with us or (iii) data they have received from us under their own responsibility (e.g. IT providers, advertising service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit agencies, address checkers, consulting companies or lawyers). For the service providers used for the website, see Section 13. For the conduct of online events and webinars, we use Microsoft Teams (Microsoft Ireland Operations Limited / Microsoft Corporation). Microsoft processes personal data on our behalf as a processor in accordance with Art. 28 GDPR. 

• Contractual partners: Recipients include contractual partners with whom we cooperate or who advertise on our behalf. Contractual partners receive, for example, master data of the participants to our competitions or other events or to our programs. The recipients process the data under their own responsibility or, in exceptional cases, in joint responsibility with us. 

• Authorities: We may disclose personal data to offices, courts and other authorities locally and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The recipients process the data under their own responsibility. 

• Other persons: This refers to other cases where the inclusion of third parties results from the purposes pursuant to Section 5. Other recipients are, for example, persons involved in official or legal proceedings. If we cooperate with the media and transmit material to them (e.g. photos), you may also be affected by this under certain circumstances. In the course of business development, we may sell or acquire businesses, operations, assets or companies, or enter into partnerships, which may also result in the disclosure of information (including information about you, for example, as a participant to our competitions or other events or as a applicant or participant to one of our programs) to the persons involved in those transactions. In the course of communication with our competitors, industry organizations, associations and other bodies, data may also be exchanged which may affect you. 

All these categories of recipient may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.). 

We also allow certain third parties to collect personal data from you on our website and Services and at events organized by us (e.g. media photographers, providers of tools that we have embedded on our website, etc.). Insofar as we are not decisively involved in these data collections, these third parties are solely responsible for them. If you have any concerns or wish to assert your data protection rights, please contact these third parties directly. See Section 12 for the website. 

8. Is your personal data disclosed abroad? 

We process and store personal data mainly in Switzerland and the European Economic Area (EEA). However, we may occasionally disclose data to service providers and other recipients (see Section 7) that are located or process data outside of this area, generally in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on a derogation. A derogation may apply for example in the event of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if the data has been made generally available by you and you have not objected to the processing. Where applicable, we rely on adequacy decisions of the European Commission (e.g. the EU-U.S. Data Privacy Framework) or on Standard Contractual Clauses supplemented by appropriate technical and organizational safeguards. 

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country. 

9. How long do we process your data? 

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically required (e.g. in the case of backups or document management systems). If there are no legal or contractual obligations to the contrary, we will delete or anonymize your data after the storage or processing period has expired as part of our normal processes.

If no legal retention requirements exist in individual cases, we generally process data for the duration of the business relationship or contract term and then, depending on the applicable legal basis, for a further five, ten or more years. This corresponds to the period during which we can assert legal claims against third parties or third parties can assert legal claims against us. Ongoing or anticipated legal proceedings may result in processing beyond this period.  

10. How do we protect your data? 

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorized or unlawful processing and to protect it against the risks of loss, accidental loss or alteration, unauthorized disclosure or access. However, security risks cannot be completely eliminated in general - a certain residual risk is unavoidable. 

11. What are your rights? 

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing. 

To help you control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:  

• The right to request information from us as to whether and what data we process from you; 

• The right to have us correct data if it is inaccurate; 

• The right to request erasure of data; 

• The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller; 

• The right to withdraw consent, where our processing is based on your consent; 

• The right to receive, upon request, further information that is helpful for the exercise of these rights; 

If you wish to exercise any of the above rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by e-mail; you will find our contact details in Section 2. In order for us to rule out any misuse, we must identify you (e.g. by means of a copy of your ID card, if this is not possible by less extensive means). 

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 7 and additional information in Section 12.  

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable. 

If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officers (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can also contact the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. 

12. Do we use online tracking, online advertising and similar techniques? 

On websites operated by us, we use various technologies (e.g. cookies, fingerprinting, tracking pixels and similar technologies), with which we and third parties engaged by us can recognize you during your use and, under certain circumstances, track you over several visits. 

We use our own tools and sometimes third-party services, in particular to improve the functionality or content of our website (e.g. integration of videos or maps), to compile statistics and to display advertisements. This enables us and authorized third parties to provide you with a personalized web experience (e.g. personalized advertising, interactions on social media sites, etc.). 

For further information on our use of cookies and similar technologies, please see our Cookie Policy. 

You can manage your preferences regarding the use of cookies and similar technologies on our Website by accessing the Consent Management System, which is available under "Cookie Settings" on our Website. 

13. What data do we process on our social media pages? 

We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and process the data about you described in section 3 and below. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms' providers may analyze your use of our online presence (e.g. how you interact with us, how you use our online presence, what you view, comment on, or «like») and process this data along with other data they have about you (e.g. information about your age and gender and other demographic information). In this way, they create profiles about you and statistics about the use of our online presences. They use this data and profiles to display our or other advertisements and other personalized content on the platform and to drive behavior on the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. To the extent that we are jointly responsible with the provider for certain types of processing, we will enter into a corresponding contract with the provider. You can find out about the main content of this contract from the provider. They also process this data for their own purposes, in particular for marketing and market research purposes (e.g. to personalize advertising) and to manage their platforms (e.g. to decide what content to show you), and act as separate controllers for this purpose.  

We are entitled, but not obliged, to review content before or after it is published on our online presences, to delete content without notice and, if necessary, to report it to the provider of the relevant platform. In the event of violations of decency and conduct rules, we may also notify the provider of the platform on which the user account in question is located for blocking or deletion. 

For further information on processing by the platform providers, please refer to the data protection notices of the respective platforms. There you can also find out in which countries your data is processed, what rights of access and deletion you have and how you can exercise these or obtain further information. We currently use the following platforms: 

• Facebook: On Facebook we operate the page www.facebook.com/ thehashgraphassociation/?locale=de_DE . The controller for the operation of the platform for users from Europe is Meta Platforms Ireland Limited, Dublin, Ireland. Their privacy notice is available at www.facebook.com/privacy/policy. Some of your data will be transferred to the United States. You can object to advertising here: www.facebook.com/settings?tab=ads. With regard to the data collected and processed when visiting our site for «page insights», we are joint controllers with Facebook Ireland Ltd., Dublin, Ireland. As part of page insights, statistics are created about the actions visitors perform on our site (comment on posts, share content, etc.). This is explained at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us understand how our page is used and how to improve it. We receive only anonymous, aggregated data. We have agreed our data protection responsibilities according to the information on www.facebook.com/legal/terms/page_controller_addendum. 

• LinkedIn: We operate the following LinkedIn pages: THG LinkedIn: https://www.linkedin.com/company/hashgraphgroup The controller for users in Europe is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. When you visit our LinkedIn pages, LinkedIn processes personal data to provide us with aggregated statistics (“Page Analytics”) regarding the use of our pages. To the extent such analytics are provided to us, we and LinkedIn may act as joint controllers for the processing of page insight data pursuant to Art. 26 GDPR. LinkedIn assumes primary responsibility for fulfilling data subject rights in relation to such processing. Further information on data processing by LinkedIn, including international transfers, can be found in LinkedIn’s privacy policy: 
  https://www.linkedin.com/legal/privacy-policy LinkedIn may transfer personal data to the United States and other third countries. Such transfers are carried out on the basis of adequacy decisions (where applicable), Standard Contractual Clauses or other appropriate safeguards. For all other processing carried out by LinkedIn (e.g. profiling, personalized advertising, platform analytics), LinkedIn acts as an independent controller. 

• X (formerly Twitter): We operate the following X accounts: THG X: https://x.com/hashgraphgroup The controller for the processing of personal data in connection with the X platform is X Corp. and/or its relevant European entity. When you interact with our X accounts (e.g. view posts, like, repost, comment), personal data may be processed by X for analytics, advertising and profiling purposes. X may provide us with aggregated statistical information regarding engagement with our content. X processes personal data under its own responsibility. Further information on data processing by X, including international transfers, is available at: 
  https://x.com/en/privacy .Please note that X may transfer personal data to countries outside Switzerland and the EEA, including the United States. 

• YouTube: We operate the following YouTube channel: THG YouTube: https://www.youtube.com/@TheHashgraphGroup. YouTube is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When you visit our YouTube channels or view embedded videos, personal data may be processed by Google for analytics, advertising and personalization purposes. To the extent YouTube provides us with aggregated channel analytics, Google and we may act as joint controllers for such statistical data processing. Further information is available at: 
  https://policies.google.com/privacy . Google may transfer personal data to the United States and other third countries. Transfers are based on adequacy decisions (where applicable) or Standard Contractual Clauses. For all further processing beyond channel administration and aggregated statistics, Google acts as an independent controller. 

14. Can we update this Privacy Notice? 

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.  

Last updated: March 3, 2026