Privacy Policy

1. Introduction

This Privacy Policy describes how MFG Consulting SA, headquartered at Corso Elvezia 16, 6900 Lugano, Switzerland (hereinafter, "the Company"), collects, uses, and protects the personal data of users who access the website 

https://www.route-crypto-training.org/ 

(hereinafter, "the Site") and take advantage of the e-learning courses offered through the Thinkific platform, based in Canada.

2. Data Controller

The Data Controller for the processing of personal data is MFG Consulting SA, represented by Mr. Maurizio Camponovo. For any inquiries or clarifications regarding the processing of personal data, you can contact the Data Controller at the e-mail address: 

[email protected]

3. Legal Basis of Treatment

The Company processes personal data shared directly by users or retrieved from external public and authoritative sources, where processing:

1. necessary for the performance of the contract to provide the services you have requested, including course registration and payment processing; or 

2. Is necessary to fulfill a legal obligation incumbent on the Company; or 

3. Is based on your express consent for sending promotional communications or newsletters; or

4. is based on the legitimate interest of the Company to improve the services offered and ensure the security of the Site. 

It is specified that personal information spontaneously shared with the Company is assumed to be collected with consent (e.g. through e-mail, event registration, website, etc.), likewise as information made public.

4. Methods of data processing through e-mail and digital systems

As part of the mandate, the Company will communicate with users by electronic means without encryption. The user's consent to the use of such means shall be presumed unless the user expressly gives instructions to the contrary in writing.

The Company uses commonly used IT systems and adopts data security measures that comply with industry standards. You agree that the Company will outsource the maintenance and management of its IT systems to a third-party professional services company.

5. Type of Data Collected

The Company collects and processes the following personal data of users:

• Identifying data: first and last name.

• Contact information: e-mail address.

• Payment data: information needed to process payments through third-party Stripe and PayPal services.

6. Purpose of Treatment

Personal data collected are used for the following purposes:

• Course enrollment and management: to register users for e-learning courses and monitor their progress.

• Communications: to send emails regarding courses, updates, changes to terms of service, or other relevant information.

• Marketing: with explicit consent, to send newsletters or promotional communications about the services offered.

• Payment processing: to manage economic transactions related to the purchase of courses.

7. Consent to Treatment

By providing your personal information to register for courses or to make a purchase, you consent to its processing for the purposes stated above. Consent for marketing purposes is optional and can be revoked at any time by contacting the Company at the above e-mail address.

8. Transfer of Data Abroad

Courses are delivered through the Thinkific platform, based in Canada. Both the European Union and Switzerland recognize Canada, limited to companies that adhere to the Personal Information Protection and Electronic Documents Act, as a country that provides an adequate level of protection for personal data, allowing data to be transferred to that country without the need for additional safeguards. 

9. Thinkific's Compliance with Data Protection Regulations.

Thinkific is a company based in the province of British Columbia, Canada, and is subject to federal and provincial data protection laws. Specifically:

• PIPEDA (Personal Information Protection and Electronic Documents Act): Thinkific complies with this Canadian federal law that regulates the collection, use and disclosure of personal information in the private sector. 

• PIPA (Personal Information Protection Act): Being located in British Columbia, Thinkific also adheres to this provincial law governing the protection of personal information at the local level. 

10. Data retention.

Personal data, processed for the purposes indicated above, are retained for the period of the duration of the contract and, thereafter, for as long as the Company is subject to retention obligations for tax purposes or for other purposes stipulated by laws or regulations applicable to the Company. Barring exceptions, data are retained for ten years following the conclusion of the contractual relationship; thereafter, and in the absence of valid reasons for retaining them, the Company will delete and destroy them. 

11. Third Party Services

For payment processing, the Company uses the services of Stripe and PayPal. These providers process your personal data in accordance with their own privacy policies. It is recommended that you consult their respective policies to understand how your personal data will be handled by these vendors.

12. Data Security

The Company takes appropriate technical and organizational measures to protect users' personal data from unauthorized access, loss, misuse or alteration. However, please note that no method of transmission over the Internet or electronic storage is completely secure.

13. Rights of Interested Parties

In accordance with the GDPR and the DPA, users have the right to:

• Access your personal data.

• Rectify inaccurate or incomplete data.

• Delete your own data ("right to be forgotten").

• Limit the processing of one's own data.

• Oppose processing for legitimate reasons.

• Request data portability.

To exercise these rights, you can contact the Company as per the contact information in Section 13.

14. Changes to the Privacy Policy

The Company reserves the right to change this Privacy Policy at any time. Changes will be posted on the Site and, where appropriate, notified by e-mail. Please check this page periodically to be updated on any changes.

15. Contact

If you have any questions or where you believe that the handling of your personal data does not comply with this Privacy Policy and the related data protection framework outlined in this Privacy Policy, please contact us at:

[email protected]

[email protected]

Under the DPA, you can also contact the Federal Data Protection and Information Commissioner] Feldeggweg 1 CH - 3003 Bern.