EMPOWERING ONLINE PAYMENTS

DATA PROTECTION DECLARATION

Mandato Financial Services

We are very pleased about your interest in our company. The management of Mandato Financial Services GmbH attaches great importance to data protection. The use of the Mandato Financial Services GmbH website is basically possible without any indication of personal data. However, if a person would like to use special services of our company via our website, it might be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the basic data protection regulation and in compliance with the country-specific data protection regulations applicable to Mandato Financial Services GmbH. By means of this data protection declaration, our company wishes to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, this data protection declaration informs affected persons about their rights.

Mandato Financial Services GmbH, as the data controller, has implemented numerous technical and organizational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, for example by telephone or e-mail.

1. Definitions

The data protection declaration of Mandato Financial Services GmbH is based on the terminology used by the European directive and regulation authorities when the basic data protection regulation (DS-GVO) was issued. Our data protection declaration should be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms in this privacy policy:

1. Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, on-line identification, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Person Concerned

Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

3. Processing

Processing is any operation or set of operations, performed upon personal data, whether or not by automatic means, such as collection, recording, organization, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, processing or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

5. Profiling

Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the job performance, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location of that natural person.

6. Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data is not attributed to an identified or identifiable natural person.

7. Supervisor or controller

Controller or data controller shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or by the law of the Member States, the controller or the specific criteria for his nomination may be provided for by Union law or by the law of the Member States.

8. Order Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

9. Receiver

The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not it is a third party. However, authorities which may receive personal data in the context of a specific investigation mandate under Union or national law shall not be considered as recipients.

10. Third party

Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

11. Consent

Consent shall mean any freely given, informed and unequivocal expression of the data subject's will in a specific case, in the form of a statement or any other unequivocal affirmative act by which the data subject signifies his or her consent to the processing of personal data relating to him or her.

2. Name and address of the controller

The person responsible within the meaning of the Basic Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Mandato Financial Services GmbH

Address:
Zugerstraße 46
6314 Unterägeri
Switzerland

E-Mail:
[email protected]

Website:
www.mandato.global

3. Name and address of the Data Protection Officer

The Data Protection Officer of the controller is:

Kostas Tsendekidis

Address:
Zugerstraße 46
6314 Unterägeri
Switzerland

E-Mail:
[email protected]

Website:
www.mandato.global

Every person concerned can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.

4. Cookies

The website of Mandato Financial Services GmbH uses cookies. Cookies are text files which are stored on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters which can be used to assign Internet pages and servers to the specific Internet browser in which the cookie was stored. This enables the Internet pages and servers visited to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified by means of the unique cookie ID.

By using cookies, Mandato Financial Services GmbH can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimized in the interest of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter his or her access data each time he or she visits the website, as this is done by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in the online shop. The online shop uses a cookie to remember the articles that a customer has placed in the virtual shopping cart.

We also use cookies on our website, which enable an analysis of the surfing behaviour of the users.

In this way the following data can be transmitted:

• Frequency of page views
• Entered search terms
• Use of website functions

User data collected in this way is pseudonymised by technical precautions. Therefore, it is no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users.

When accessing our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this data protection declaration.

The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 a DSGVO if the user has given his/her consent to this effect.

The person concerned can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, it is possible that not all functions of our website can be fully used.

5. Collection of general data and information

The Mandato Financial Services GmbH website collects a range of general data and information every time a data subject or automated system accesses the website. This general data and information is stored in the server log files. The following can be recorded: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of an access to the Internet site, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information which serve to avert danger in the event of attacks on our information technology systems.

Mandato Financial Services GmbH does not draw any conclusions about the person concerned when using this general data and information. This information is rather required to (1) deliver the contents of our website correctly, (2) optimize the contents of our website as well as the advertising for it, (3) ensure the permanent operability of our information technology systems and the technology of our website as well as (4) to provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyberattack. These anonymously collected data and information are therefore statistically evaluated by Mandato Financial Services GmbH on the one hand and also with the aim of increasing data protection and data security in our company, in order to also ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.

In addition, the following personal data is also collected, provided that the express permission of the users concerned has been obtained and in compliance with the applicable data protection regulations:

Users first and last name, IP address, e-mail address and details of their place of residence (postcode etc).

Personal data is processed on the basis of our legitimate interest in fulfilling our contractually agreed services and optimizing our offer.

You can also visit this website without providing any personal information. However, to improve our offer we store (without personal reference) your access data to this website. This access data includes, for example, the file you requested or the name of your Internet provider. By making the data anonymous, it is not possible to draw conclusions about your person.

6. SSL- Encryption

To protect the security of your data during transmission, we use state-of-the-art encryption procedures (e.g. SSL) via HTTPS.

7. Registration on our website

The data subject has the possibility to register on the website of the controller by providing personal data. The personal data transmitted to the controller is determined by the input mask used for registration. The personal data entered by the data subject are collected and stored solely for internal use by the data controller and for his or her own purposes. The controller may arrange for the personal data to be transferred to one or more processors, such as a parcel ervice provider, which shall also use the personal data exclusively for internal use attributable to he controller.

By registering on the website of the data controller, the IP address assigned to the data subject by the Internet Service Provider (ISP), the date and time of registration are also saved. The storage of this data is carried out against the background that this is the only way to prevent the misuse of our services and, if necessary, to enable the clarification of criminal offenses committed. To this extent, the storage of this data is necessary to protect the person responsible for processing. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to do so or the passing on of the data serves criminal prosecution.

The registration of the data subject with voluntary provision of personal data serves the purpose f the data controller to offer the data subject content or services which, by their very nature, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have them completely deleted from the data stock of he data controller.

The controller shall at any time upon request provide any data subject with information as to hich personal data relating to the data subject are stored. Furthermore, he or she shall correct r delete personal data at the request or notice of the data subject, provided that this does not conflict with any statutory storage obligations. The entire staff of the data controller is available to he data subject as contact persons in this connection.

8. How to contact us via the website

Due to legal requirements, the Mandato Financial Services GmbH website contains information that enables rapid electronic contact with our company and direct communication with s, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the data controller by e-mail or a contact form, the personal data transmitted by he data subject is automatically stored. Such personal data transmitted by a data subject to the controller on a voluntary basis are stored for the purposes of processing or for contacting the data subject. Such personal data shall not be disclosed to third parties.

9. Routine deletion and blocking of personal data

The controller shall process and store personal data of the data subjects only for the period of time necessary to achieve the purpose of storage or where provided for by the European legislator or other legislator in laws or regulations to which the controller is subject.

If the purpose of storage ceases to apply or if a storage period prescribed by the European Directives and Regulations or any other competent legislator expires, the personal data will be locked or deleted as a matter of routine and in accordance with legal requirements.

10. Rights of the data subject

1. Right of confirmation

Every data subject has the right, granted by the European Directive and Regulation, to obtain from the controller confirmation as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.

2. Right of access

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain at any time and free of charge from the data controller information on personal data relating to him/her and a copy thereof. The European Data protection Supervisor has also granted the data subject access to the following information:

• the processing purposes
• the categories of personal data processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or international organizations
• if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
• the existence of a right of rectification or erasure of personal data relating to him or her or of a restriction on processing by the controller or a right to object to such processing
• the existence of a right of appeal to a supervisory authority
• if the personal data are not collected from the data subject: All available information on he origin of the data
• the existence of automated decision-making, including profiling, in accordance with Article 2(1) and (4) of the DPA and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject

The data subject shall also have the right to obtain information as to whether personal data have been transferred to a third country or to an international organization. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards relating to he transfer. If a data subject wishes to exercise this right of access, he or she may at any time contact an employee of the controller.

3. Right of rectification

Any person affected by the processing of personal data has the right, granted by the European legislator, to request the rectification without delay of inaccurate personal data concerning him. The data subject shall also have the right to obtain the completion of incomplete personal data, including by means of a supplementary declaration, having regard to the purposes of the processing. If a data subject wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.

4. Right of cancellation (right to be forgotten)

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the immediate erasure of personal data elating to him/her, where one of the following reasons applies and where the processing is not necessary:

• The personal data has been collected or otherwise processed for purposes for which it is o longer necessary.
• The data subject withdraws the consent on which the processing was based pursuant to article 6(1)(a) of the DPA or Article 9(2)(a) of the DPA and there is no other legal basis for he processing.
• The data subject lodges an objection to the processing pursuant to Article 21 (1) DPA and here are no overriding legitimate reasons for the processing, or the data subject lodges n objection to the processing pursuant to Article 21 (2) DPA.
• The personal data were processed unlawfully.
• The deletion of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
• The personal data was collected in relation to information society services offered in accordance with Article 8 (1) of the DS-GVO.

If any of the above reasons apply and a data subject wishes to have personal data stored by Mandato Financial Services GmbH deleted, he/she can contact an employee of the data controller at any time. The employee will ensure that the request for deletion is complied with immediately. If the personal data has been made public by Mandato Financial Services GmbH and our company as the responsible party is obliged to delete the personal data in accordance with Art. 17 Paragraph 1 of the DS-GVO, Mandato Financial Services GmbH will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested these other data controllers to delete all links to his personal data or copies or replications of this personal data, insofar as the processing is not necessary. The employee of Mandato Financial Services GmbH will arrange for the necessary n individual cases.

5. Right to restrict processing

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the restriction of the processing if one of he following conditions is met

• The accuracy of the personal data is contested by the data subject, for a period of time hat allows the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject refuses to have the personal data deleted and instead requests that the use of the personal data be restricted.
• The controller no longer needs the personal data for the purposes of the processing, but he data subject needs them in order to assert, exercise or defend legal claims.
• The data subject has lodged an objection to the processing pursuant to Article 21 (1) of he DPA and it is not yet clear whether the legitimate reasons of the controller outweigh hose of the data subject

If one of the above-mentioned conditions is met and a data subject wishes to request the restriction of personal data stored by Mandato Financial Services GmbH, he/she can contact an employee of the data controller at any time. The employee of Mandato Financial Services mbH will arrange for the restriction of the processing.

6. Right of data transferability

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to receive the personal data concerning him/her which have been made available to a controller by the data subject in a structured, common and machine-readable format. He or she also has the right to have this data communicated to another controller without hindrance by the controller to whom the personal data has been made available, provided that he processing is based on the consent pursuant to Article 6 paragraph 1 letter a DPA or Article 9 paragraph 2 letter a DPA or on a contract pursuant to Article 6 paragraph 1 letter b DPA and that he processing is carried out by means of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, when exercising their right to data transfer pursuant to Art. 20 Para. 1 DPA, the data subject has the right to request that personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and provided that this does not adversely affect the rights and freedoms of other persons. In order to assert the right to data transfer, the person concerned can contact an employee of Mandato Financial Services GmbH at any time.

7. Right of appeal

Every person concerned by the processing of personal data has the right, granted by the European legislator, to object at any time, for reasons arising from his or her particular situation, o the processing of personal data concerning him or her carried out pursuant to Article 6(1)(e) or f) of the DPA. This also applies to profiling based on these provisions. In the event of an objection, Mandato Financial Services GmbH will no longer process the personal data unless e can prove compelling reasons for processing that are worthy of protection and outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. If Mandato Financial Services GmbH processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing f personal data for the purpose of such marketing. This also applies to profiling, insofar as it is connected with such direct advertising. If the data subject objects to Mandato Financial Services GmbH processing for the purpose of direct marketing, Mandato Financial Services mbH will no longer process the personal data for these purposes. In addition, the data subject as the right to object, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her which is carried out at Mandato Financial Services GmbH or scientific or historical research purposes or for statistical purposes in accordance with Article 9 (1) of the DS-GVO, unless such processing is necessary for the performance of a task carried out in the public interest. In order to exercise the right of objection, the data subject may directly contact any Mandato Financial Services GmbH employee or any other employee. The data subject is also free to exercise his/her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures involving technical specifications.

8. Automated decisions in individual cases including profiling

Every person concerned by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or significantly affects him/her in a similar way, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or national legislation to which the controller is subject and such legislation provides for adequate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is made with the explicit consent of the data subject. Where the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is taken with the express consent of the data subject, Mandato Financial Services GmbH shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to obtain the intervention of a person from the controller, to put forward his point of view and to challenge the decision. If the data subject wishes to exercise rights relating to automated decisions, he or she may at any time consult a member of the controller's staff.

9. Right of revocation of a data protection consent

Every person affected by the processing of personal data has the right, granted by the European Directive and Regulation Giver, to revoke his or her consent to the processing of personal data at any time. If the data subject wishes to exercise his or her right to withdraw consent, he or she may at any time contact an employee of the controller.

11. Use of Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. (following: Google). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymization on these websites, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide further services to the website operator in connection with website and internet use. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other data from Google.

The purposes of the data processing are to evaluate the use of the website and to compile reports on activities on the website. Based on the use of the website and the Internet, further related services will then be provided. The processing is based on the legitimate interest of the website operator.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link Browser Add On to deactivate Google Analytics.

In addition or as an alternative to the browser add-on, you can prevent tracking by Google Analytics on our pages by clicking on this link. Thereby a opt-out cookie installed on your device. This will prevent Google Analytics from recording data for this website and for this browser in the future as long as the cookie remains installed in your browser.

12. Use of libraries (webfonts)

In order to display our content correctly and graphically appealing across browsers, we use website libraries and font libraries such as Google Web Fonts (https://www.google.com/webfonts). Google Web fonts are cached in your browser to prevent multiple downloads. If your browser does not support Google Web Fonts or prevents access, content will be displayed in a default font. Accessing libraries or font libraries automatically riggers a connection to the library operator. It is theoretically possible - although it is currently unclear whether and for what purposes - that the operators of such libraries collect data. The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy

13. Legal basis of the processing

Art. 6 I a DS-GVO serves our company as a legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations necessary for the supply of goods or provision of other services or consideration, the processing is based on Art. 6 I b DS-GVO. The same applies to such processing operations which are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which makes it necessary to process personal data, for example to fulfill tax obligations, the processing is based on Art. 6 I c DS-GVO. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our company were to be injured and his or her name, age, health insurance details or other vital information had to be disclosed to a doctor, hospital or other third party. The processing would then be based on Art. 6 I d DS-GVO. Finally, processing operations could be based on Art. 6 I f DS-GVO. Processing operations which are not covered by any of the above legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party, unless the interests, fundamental rights and freedoms of the data subject prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 DS-GVO).

14. Legitimate interests in the processing

If the processing of personal data is based on Article 6 I f DS-GVO, our legitimate interest is to conduct our business activities for the benefit of the well-being of all our employees and our shareholders.

15. Duration for which the personal data are stored

The criterion for the duration of storage of personal data is the respective legal retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment or initiation of the contract.

Legal or contractual provisions providing the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the data

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him/her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the person concerned makes personal data available, the person concerned must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

17. Amendment of the data protection provision

We reserve the right to adapt this data protection declaration so that it always meets the current egal requirements or to implement changes to our services in the data protection declaration, .g. when introducing new services. The new data protection declaration then applies to your ext visit.

18. Existence of automated decision making

As a responsible company, we avoid automatic decision making or profiling.