DATENSCHUTZ

ALTRIUM AG, Sonnenfeldstrasse 2, 8702 Zollikon, Switzerland, UID: CHE-106.678.230, Commercial Register No.: CH-020.3.919.549-7 (hereinafter referred to as the “Company”, “Developer”, “we”, “us” or “our”) provides the digital platform, applications, interfaces, products and services made available under the LICOVIA name.

This Privacy Policy explains how personal data may be collected, used, processed, stored and shared in connection with access to and use of LICOVIA.

This Privacy Policy applies to the LICOVIA website and, where applicable, LICOVIA applications, interfaces, accounts, products and services.

Where separate privacy information applies to a particular product, service or third-party provider, that information may supplement this Privacy Policy.

For the purposes of this Privacy Policy:

LICOVIA or Platform

The digital platform, website, applications and interfaces made available under the LICOVIA name.

User or you

A person accessing or using LICOVIA, including persons acting on behalf of a company or other legal entity.

Personal Data

Information relating to an identified or identifiable natural person.

Services

The products, functions and services made available through LICOVIA.

Service Providers

Third parties involved in providing technical, payment, verification, compliance, digital-asset, infrastructure or other supporting services.

Depending on the Services used and the applicable verification requirements, LICOVIA may process categories of Personal Data including:

• name and contact information;
• date and place of birth;
• nationality and country of residence;
• residential or business address;
• identity-document information;
• company and business information;
• information concerning directors, representatives and beneficial owners;
• occupation or business activity;
• purpose and intended use of Services;
• source-of-funds or source-of-wealth information where required;
• transaction and payment information;
• wallet addresses and blockchain transaction information;
• supported fiat and digital-asset activity;
• information submitted during customer or business verification;
• communications with LICOVIA;
• documents or files voluntarily submitted by Users; and
• other information reasonably required to provide Services or meet applicable legal and compliance requirements.

When Users access the LICOVIA website or Platform, certain technical information may be processed automatically.

This may include:

• IP address;
• device type;
• browser type and version;
• operating system;
• session information;
• security and authentication information;
• technical logs;
• actions performed within the Platform;
• diagnostic information; and
• aggregated usage information.

Such information may be used for operation, security, fraud prevention, troubleshooting, analytics and service improvement where permitted by applicable law.

Cookies and similar technologies are addressed separately below and through the applicable LICOVIA cookie-consent mechanism.

Personal Data may be collected:

• directly from Users;
• when a User registers or creates an account;
• when information or documents are submitted;
• during identity or business verification;
• when Users make or receive transactions;
• when Users use wallet or digital-asset functionality;
• through communications with LICOVIA;
• automatically through use of the Platform;
• from relevant Service Providers;
• from verification, compliance or fraud-prevention providers; and
• from lawful public or regulatory sources where appropriate.

Personal Data may be processed where necessary and legally permitted for purposes including:

1. providing and operating LICOVIA Services;
2. registering and administering User accounts;
3. identity and business verification;
4. processing payments, transfers and transactions;
5. providing wallet and supported digital-asset functionality;
6. providing account, transaction and service information;
7. fraud prevention and security;
8. AML/CFT, sanctions and other compliance procedures;
9. transaction and blockchain risk monitoring where applicable;
10. responding to User requests and providing support;
11. maintaining and improving Platform functionality;
12. detecting and resolving technical issues;
13. risk management, auditing and internal administration;
14. meeting legal, regulatory, accounting and tax requirements;
15. establishing, exercising or defending legal claims;
16. protecting the rights, security and property of Users, LICOVIA, ALTRIUM AG and relevant third parties;
17. analytics and service improvement where legally permitted; and
18. marketing communications where an appropriate legal basis exists.

Depending on the circumstances and applicable data-protection law, Personal Data may be processed on one or more legal bases, including:

• performance of a contract or steps taken before entering into a contract;
• compliance with legal obligations;
• legitimate interests pursued by ALTRIUM AG or relevant third parties, where those interests are not overridden by applicable individual rights;
• consent where consent is required; and
• other legal grounds available under applicable law.

Where processing relies on consent, Users may withdraw that consent in accordance with applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Certain LICOVIA Services may require identity verification, business verification, customer due diligence or other compliance procedures.

Relevant Personal Data may therefore be processed for:

• KYC and KYB procedures;
• identification of beneficial owners and authorised representatives;
• AML/CFT procedures;
• sanctions screening;
• fraud prevention;
• transaction monitoring;
• blockchain monitoring where applicable;
• source-of-funds or source-of-wealth verification where required; and
• other legally or operationally required compliance procedures.

Relevant Service Providers may process Personal Data for these purposes where necessary.

Where necessary and legally permitted, Personal Data may be shared with relevant recipients including:

• technology and infrastructure providers;
• payment and processing providers;
• financial institutions involved in providing applicable Services;
• digital-asset infrastructure providers;
• verification and compliance providers;
• fraud-prevention and security providers;
• professional advisers;
• auditors;
• contractors and service providers;
• competent courts, authorities or regulatory bodies where legally required;
• potential successors in connection with a legitimate corporate transaction; and
• other recipients authorised by the User or permitted by applicable law.

Only information reasonably necessary for the relevant purpose should be shared.

Third-party providers may process Personal Data according to their own applicable privacy policies and legal obligations.

LICOVIA Services may rely on international technology, payment, verification, compliance and digital-asset infrastructure.

As a result, Personal Data may be processed in countries other than the country in which a User is located.

Where required by applicable data-protection law, appropriate safeguards will be used for international transfers of Personal Data.

Acceptance of this Privacy Policy does not constitute blanket consent to all international data transfers.

Reasonable technical and organisational measures are used to protect Personal Data against unauthorised access, disclosure, alteration, loss or destruction.

No internet-based system can be guaranteed to be completely secure.

Users are responsible for taking reasonable precautions to protect their credentials, accounts and devices.

Where a personal-data breach occurs, applicable legal requirements concerning assessment, mitigation and notification will be followed.

Personal Data is retained only for as long as reasonably necessary for the purposes for which it was collected and as required by applicable legal, regulatory, compliance, accounting, tax, fraud-prevention or dispute-resolution requirements.

Different categories of information may therefore be subject to different retention periods.

Depending on applicable data-protection law and individual circumstances, Users may have rights including the right to:

• request information about processing of their Personal Data;
• request access to Personal Data;
• request correction of inaccurate Personal Data;
• request deletion where legally applicable;
• request restriction of processing;
• object to certain processing;
• withdraw consent where processing relies on consent;
• request data portability where applicable; and
• exercise other rights available under applicable data-protection law.

Certain information may need to be retained despite a deletion request where required by law or necessary for compliance, fraud prevention, transaction records, legal claims or other legitimate legal purposes.

Identity verification may be required before a data-rights request can be fulfilled.

LICOVIA may provide information concerning products, services, developments or promotions where permitted by applicable law.

Where consent is legally required for marketing communications, such communications will only be sent following the required consent.

Users may withdraw or modify applicable marketing preferences.

Merely accepting this Privacy Policy does not constitute automatic consent to promotional marketing.

The LICOVIA website may use cookies and similar technologies for purposes such as:

• essential website functionality;
• security;
• remembering User preferences;
• analytics; and
• other optional functionality where applicable.

Where legally required, non-essential cookies or similar technologies will only be activated after the User has made the relevant choice through the LICOVIA cookie-consent mechanism.

Users will be provided with appropriate controls to manage their cookie preferences.

Further information may be made available through the cookie settings and this Privacy Policy.

LICOVIA may contain or rely upon functionality supplied by third-party providers.

Use of such services may involve processing of Personal Data by those providers under their own applicable terms and privacy policies.

ALTRIUM AG is not responsible for third-party privacy practices that fall outside its legal responsibility or reasonable control.

LICOVIA Services are not intended for persons who do not meet the applicable minimum legal age or eligibility requirements for the relevant Service.

ALTRIUM AG does not knowingly seek to provide regulated financial or digital-asset Services to persons who are not legally eligible to use them.

This Privacy Policy may be updated from time to time to reflect changes to Services, technology, legal requirements or data-processing practices.

The current version will be made available through the LICOVIA website or Platform.

Where required by applicable law, Users will be informed of material changes through appropriate means.

Questions concerning this Privacy Policy or Personal Data may be submitted through the official LICOVIA support channels.

Contact details will be added once the official LICOVIA contact channels have been confirmed.