Privacy Policy

1. Who is responsible

This privacy policy explains how MC2Fi AG, Grabenstrasse 7a, CH‑6340 Baar, Switzerland (“MC2Fi”, “we”, “our”, “us”) collects and uses personal data when you visit or interact with our website and platform, including pages that describe our exchange‑traded products (“ETPs”), our services for partners, and our blog and contact forms (together, the “Platform”).

We follow Swiss data protection law and, where it applies, European data protection law.

You can contact us at: team@mc2.fi.

2. What personal data we collect

Depending on how you use the Platform, we may collect:

• Contact details: your name, email address, company, role, and any information you include in contact forms, meeting requests, or emails.
• Technical data: your internet protocol address, browser type and version, operating system, device identifiers, pages you visit, time and date of your visits, and how you navigate the Platform.
• Usage and marketing data: information about how you interact with our pages, newsletters, and messages (for example, whether you open an email or click on a link).
• Business communication data: information shared in the context of discussions about ETP structuring, listing support, or other professional services.

We do not collect or store private keys, seed phrases, or similar access data for digital assets on the Platform.

3. Why we use personal data

We use personal data for the following purposes:

• Operating and securing the Platform: to provide access to the website, improve stability and security, detect misuse, and fix errors.
• Communication: to respond to your requests, schedule calls, send requested information (such as product decks or term sheets), and manage our relationship with you.
• Marketing and information: to send you newsletters, event invitations, and updates about our ETPs, services, and content, where permitted by law. You can opt out at any time.
• Analytics and improvement: to understand how the Platform is used, which pages are most visited, and how we can improve content and user experience.
• Legal and compliance: to comply with legal obligations, enforce our rights, and defend ourselves in case of disputes.

4. Cookies and similar tools

We may use cookies and similar tools (such as local storage or pixels) to:

• Enable core functions of the Platform (for example, to remember choices or keep a session active).
• Collect statistics about visits, page views, and user paths.
• Support limited marketing and performance measurement (for example, to see which articles are most read).

Where required by law, we will ask for your consent before using non‑essential cookies or similar tools. You can also control cookies in your browser settings.

5. Where we get personal data from

We obtain personal data mainly from:

• You directly, when you browse the Platform, submit a form, subscribe to a newsletter, or contact us by email or phone.
• Service providers who support us with hosting, analytics, communication tools, or email delivery.
• In some business‑to‑business situations, from professional contacts, events, conferences, or referrals.

6. Who we share personal data with

We may share personal data with:

• Service providers: companies that provide hosting, analytics, customer relationship management, email or marketing tools, or similar services. They act on our instructions and are bound by contract.
• Professional advisers: such as lawyers, auditors, and consultants, who are bound by confidentiality duties.
• Authorities and courts: where required by law, or where necessary to protect our rights or respond to legal processes.
• Corporate transaction partners: potential buyers or investors, if we undergo a merger, acquisition, or other restructuring, subject to appropriate safeguards.

We do not sell your personal data.

7. Data transfers to other countries

Some of our service providers or partners may be located outside Switzerland or the European Union. If personal data is transferred to a country that does not offer the same level of protection as Switzerland or the European Union, we will use appropriate safeguards, such as contractual protections, to protect your data.

8. How long we keep personal data

We keep personal data only for as long as necessary for the purposes described above, or as long as required by law. In particular:

• Technical and usage data is kept for a limited period needed for security, troubleshooting, and analytics.
• Contact and business communication data is kept for the duration of our relationship and for the retention periods required by commercial and tax laws.
• Newsletter and marketing data is kept until you unsubscribe or until we clean our mailing lists and remove inactive contacts.

When personal data is no longer needed, we delete or anonymise it.

9. How we protect personal data

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration. These measures include access controls, security monitoring, and, where reasonable, encryption and pseudonymisation. No system is completely secure, but we work to keep risks at a reasonable level.

10. Your rights

Depending on the law that applies, you may have the right to:

• Ask whether we process your personal data and to receive a copy of it.
• Ask us to correct inaccurate or incomplete personal data.
• Ask us to delete personal data, where the law permits this.
• Object to certain processing, in particular processing based on our legitimate interests or for direct marketing.
• Ask us to restrict processing of your data in certain circumstances.
• Receive certain data in a portable format and transmit it to another service provider, where applicable.
• Withdraw your consent at any time, where processing is based on consent. The withdrawal does not affect the lawfulness of processing that took place before you withdrew consent.

To exercise your rights, contact team@mc2.fi. We may ask you for additional information to confirm your identity. You may also have the right to lodge a complaint with a data protection authority if you believe your rights have been violated.

11. Automated decision‑making

We do not use personal data to make decisions about you that have legal effects or similarly significant effects, based only on automated processing.

12. Third‑party websites and ETP providers

The Platform may contain links to third‑party websites, including websites of exchanges, custodians, banks, or issuers of ETPs. This privacy policy does not apply to those third parties. We are not responsible for their content or their handling of personal data. We recommend that you read the privacy information on each third‑party website you visit.

13. Changes to this policy

We may update this privacy policy from time to time, for example to reflect changes in law, our services, or our use of service providers. The “Last Updated” date shows the latest version. If you continue to use the Platform after changes take effect, you are treated as having accepted the updated policy.