Privacy Policy

Privacy Policy for Finoa Consensus Services (FCS)
Data Protection Notice in accordance with the EU General Data Protection Regulation (GDPR)
Finoa Consensus Services GmbH
Rosenstraße 2, 10178 Berlin
Germany
Commercial Register: Local Court of Charlottenburg HRB 241364 B
VAT-ID: DE353460060
Managing Director: Daniel Schrader
This Privacy Policy outlines how Finoa Consensus Services GmbH (FCS) collects, uses, and protects your personal information when you interact with our website, particularly through our contact forms. We are committed to safeguarding your privacy and processing data in accordance with the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). The following information provides an overview of the processing of your personal data by FCS and your rights under data protection law. Which data is processed in detail and how it is used depends largely on the services requested or agreed upon in each case.
1. Who is responsible for data processing and whom can I contact?
The responsible entity is Finoa Consensus Services GmbH.

Finoa Consensus Services GmbH
Rosenstraße 2, 10178 Berlin
Germany
E-Mail: contact@consensus.finoa.io

You can reach us about Data Protection at:
E-Mail: dataprotection@consensus.finoa.io
2. What sources and data do we use?
We, Finoa Consensus Services GmbH, process personal data that we receive from you in the course of business initiation and our business relationship.

When you contact FCS through our website forms (e.g., via the contact form, email, telephone, or fax), the relevant personal data collected in the context of business initiation, authorization, or joint obligation can include:
  • First and last name
  • Contact details (e.g., telephone number, e-mail address)
  • World region
  • Legal capacity
  • Company
  • Industry
  • Advertising and sales data
  • Any text or message you choose to provide in your inquiry.
In the context of a business relationship with FCS and the use of our products/services, relevant personal data may also include:
  • Account and transactions related to staking services: Information about the staked assets (e.g., currency, public keys, balance, transaction history, purpose of the transaction). Order data (e.g., staking orders, reward data). Information about other people connected to the institutional account (e.g., legal representatives, beneficial owners, authorized persons).
Additionally, during the business relationship, particularly through personal, written, or telephone contacts initiated by you or by FCS, other personal data is processed. This includes information on the contact channel, date of contact, reason, and the result of the contact, as well as (electronic) copies of correspondence.
3. What do we process your data for (purpose of processing) and on what legal basis?
We process the aforementioned personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). The processing is based on:
  • Your consent (Article 6 para. 1 a GDPR).
  • The fulfillment of contractual obligations (Article 6 para. 1 b GDPR).
  • Legal requirements (Article 6 para. 1 c GDPR) or in the public interest (Article 6 para. 1 e GDPR).
  • Within the scope of the balancing of interests (Article 6 para. 1 f GDPR).
Specifically, we use the information you provide for:
  • Responding to your inquiries: To understand your needs and respond effectively to your requests for information about FCS's staking services.
  • Communication: To contact you regarding your inquiry and provide relevant updates or information about our services.
  • Service improvement: To analyze broad trends in inquiries and improve our website and service offerings.
  • Fulfilling contractual and legal obligations related to providing staking infrastructure services.
4. Who gets my data?
Within Finoa Consensus Services GmbH, access to your data is granted to those departments that need it to fulfill our contractual and legal obligations (Art. 28 GDPR). Service providers and vicarious agents employed by us may also receive data for these purposes if they comply with the legal requirements of the EU General Data Protection Regulation/Federal Data Protection Act and our written data protection instructions. These are mainly companies from categories such as processing of service-related information, support/maintenance of IT applications, archiving, document processing, controlling, data screening for anti-money laundering purposes (where applicable to FCS's services), customer support and communication, marketing, media technology, reporting, research, risk controlling, telephone/video calls, video legitimation, website management, auditing services.

We are obliged to maintain confidentiality about all customer-related facts and business matters. We may only pass on information about you if this is required by law, if you have consented to this, if we are authorized to provide information, and/or if the processors commissioned by us guarantee compliance with the requirements of the EU General Data Protection Regulation/Federal Data Protection Act in the same way.

Under these conditions, recipients of personal data may be, for example:
  • Public bodies and institutions (e.g., tax authorities, Federal Central Tax Office) in the event of a statutory or regulatory obligation applicable to FCS.
  • Suppliers, service providers, and processors to whom we transfer personal data in order to carry out the business relationship with you for FCS services.
  • Other data recipients may be those entities for which you have given your consent to the transfer of data or for which you have released us from confidentiality pursuant to an agreement or consent.
Processors may include (but are not limited to):
  • Amazon Web Services (AWS).
  • Zendesk, Google Cloud EMEA Ltd, and Wire for business initiation and customer service communications.
5. Is data transferred to a third country or to an international organization?
Data is only transferred to countries outside the EU or the EEA (so-called third countries) if this is necessary for the purpose stated in the processing activity and/or is required by law (e.g., reporting obligations under tax law), you have given us your consent, or within the scope of data processing in accordance with Art. 46 et seq. of GDPR. Your personal data is generally transferred in accordance with Art. 46 para 1 GDPR adequacy decision of the European Commission and with Art. 46 para 2 lit. c of the GDPR, based on Standard Contractual Clauses ("SCC") accompanied by a conducted data transfer impact assessment in case of lack of adequacy decision. The appropriate safeguards are agreed upon under SCCs as an annex and can be demanded by making a request to us at dataprotection@consensus.finoa.io.
6. How long will my data be stored?
When you no longer wish to benefit from our services and send us a deletion request, we remove all personal data except some categories for the fulfillment of our legal storage obligations. This data will be deleted immediately upon the expiry of the period, without you having to request the deletion anew.

If the retention is necessary for your personal data, it is necessary for the following purposes and laws:
  • Performing commercial and tax retention periods, which relate to the following laws: Commercial Code (Handelsgesetzbuch), Fiscal Code (Abgabenordnung), VAT Act (UStG), and Money-laundering Act (Geldwäschegesetz), where applicable to FCS's operations. The statutory retention periods and documentation obligations are between two to ten years.
  • Ensure a proper disaster recovery, and conduct IT audits: GDPR and German Civil Code (BGB). The statutory periods and documentation obligations are three years.
  • Claim and evidence management: GDPR and German Civil Code (BGB). The statutory periods and documentation obligations are three years.
7. What data protection rights do I have?
You have the right of access to your information pursuant to Art. 15 GDPR, the right to rectification pursuant to Art. 16 GDPR, the right to erasure pursuant to Art. 17 GDPR, the right to restriction of processing according to Art. 18 GDPR, the right to data portability according to Art. 20 GDPR and the right to object pursuant to Art. 21 GDPR wherever we process your data on the basis of legitimate interests under Art. 6 para. 1 lit. f of GDPR.

In addition, you have the right to lodge a complaint with a data protection supervisory authority pursuant to Art. 77 GDPR if you believe that the processing of your personal data is not lawful. In principle, you can contact the supervisory authority of your place of residence, your place of work, or our office. The supervisory authority responsible for Finoa Consensus Services GmbH's Berlin office is typically the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), though you may contact your local authority.

Finoa Consensus Services GmbH, located at Rosenstraße 2, 10178 Berlin, the competent state data protection authority is the Berlin Commissioner for Data Protection and Freedom of Information.
The responsibility is determined by the company's location in the federal state of Berlin.

Contact Details of the Authority:
Name of the Authority: Berliner Beauftragte für Datenschutz und Informationsfreiheit
(Berlin Commissioner for Data Protection and Freedom of Information)
Address: Alt-Moabit 59-61 / 10555 Berlin Germany
Visitor Entrance: Alt-Moabit 60 10555
Berlin Phone: +49 30 13889-0
Fax: +49 30 2155050
E-Mail: mailbox@datenschutz-berlin.de
Website:https://www.datenschutz-berlin.de

Insofar as the processing of data is based on your consent, pursuant to Art. 7 GDPR you are entitled to revoke your consent to the use of your personal data at any time. Please note that the revocation is only effective for the future. Processing operations that took place before the revocation are not affected by this. Please also note that we may have to retain certain data for a certain period of time in order to comply with legal requirements (see section 6 of this policy).
8. Is there any automated decision-making (including profiling)?
For the establishment and implementation of the business relationship with Finoa Consensus Services GmbH, we generally do not use automated decision-making pursuant to Article 22 of GDPR. Should we use these procedures in individual cases, we will inform you separately, provided this is required by law.
9. Cookies declaration
When you interact with Finoa Consensus Services GmbH's online services or website sections dedicated to FCS, cookies may be used. Cookies are small text files that can be used by websites to make a user's experience more efficient.

Applicable law may state that we can store cookies on your device if they are strictly necessary for the operation of the online service you are using. For all other types of cookies, we would need your permission. FCS's online services or dedicated website sections may use different types of cookies. Some cookies may be placed by third-party services that appear on our pages.

You can usually manage your cookie preferences through a cookie consent tool provided on the relevant FCS online service or webpage, or through your browser settings. To provide this functionality, we use the Cookie Consent solution from our provider, Flow Appz. Learn more about who Finoa Consensus Services GmbH is, how you can contact us, and how we process personal data in this Privacy Policy. If you contact us regarding your cookie consent for FCS services, please state your consent ID and date, if applicable.
10. Social media
Finoa Consensus Services GmbH may maintain online presences within social networks and platforms to communicate with clients, interested parties, and users, and to inform them about our services. When accessing these networks and platforms, the terms and conditions and data processing guidelines of the respective operators apply. Unless otherwise stated in our privacy policy, FCS processes user data that is communicated to us within these social networks and platforms, e.g., contributions on our online presences or messages sent to us.

FCS X Account: https://x.com/FinoaConsensus

Our website includes features from the service X (formerly Twitter). Personal data, such as your IP address, may be transmitted to X. Processing only takes place with your consent (Art. 6(1)(a) GDPR). For more information, please see X’s privacy policy: https://twitter.com/en/privacy.
11. Information on your right of objection under Art. 21 of the General Data Protection Regulation (GDPR).
Right to object on a case-by-case basis
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) (data processing in the public interest) and Article 6(1)(f) (data processing on the basis of a balancing of interests) of the GDPR; this also applies to profiling based on these provisions. If you object, Finoa Consensus Services GmbH will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

Right to object to the processing of data for advertising purposes
In individual cases, Finoa Consensus Services GmbH may process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, Finoa Consensus Services GmbH will no longer process your personal data for these purposes.

Recipient of an opposition
Objections can be made without form and should be addressed to:
E-mail: dataprotection@consensus.finoa.io
12. Additional information
Contact us
If you have any questions regarding this Privacy Policy or Finoa Consensus Services GmbH's data practices, please contact us through any contact form available on FCS’s online presences or by using the contact details provided in Section 1.