Version 0.1 - July 2023
The Website is operated by Anchored Coins AG, Gartenstrasse 6, 6300 Zug, Switzerland (the "Company", "we", "our", or "us"). The Company is the controller for the data processing described below.
For all questions on the subject of data protection, please contact us through the contact form provided by the Website or
by mail to: Anchored Coins AG, Gartenstrasse 6, 6300 Zug, Switzerland.
1 Personal data we collectWe may collect or receive personal information for a number of purposes connected with our business operations when you use this Website or our services. This may include the following:
- Personal details (e.g. full name, e-mail address, gender, home address, phone address, phone number, date of birth, nationality, signature, utility bills, photographs, government issued identity documents, country, region, and a video recording of you)
- Financial information (e.g. bank account information, payment card information, source of funding, source of wealth)
- Employment information (e.g. job title, salary wage rate, and company)
- Demographic data (e.g. income, family status, age bracket, interests)
- Payment details (e.g. billing information, credit card details, information about the transaction you make on our services)
- Sensitive and Biometric Personal Information
- Communications with us (e.g. survey responses, call recordings with our customer services team)
- Website visitor details (e.g. IP address, device ID, authentication information, security questions, logfiles, browser/web history data and preferences)
2 How we collect personal dataWe collect information about our users when they use our Website or our Services, including taking certain actions within it.
- When users correspond with us by electronic means.
- When users access, use, or otherwise interact with our Website.
- When users sign up to receive our newsletter and other marketing materials.
- When users submit their data to us.
- From public sources, such as public directories and the blockchain.
- From third parties, such as Affiliates, social media plugins and third-party cookies.
Contract: To perform our contractual obligations or take steps linked to a contract with you. In particular:
- To provide our Services.
- To communicate with you on service and transaction-related matters.
- To recruit you.
- To provide users with news, special offers, newsletters, and general information about goods and services which we offer.
- To collect sensitive personal data when permitted by law, in order to verify your identity by comparing the facial scan data extracted from your selfie or video with the photo in your government issued identity document.
- To maintain and improve our Website and Services.
- To develop new services.
- To comply with applicable regulations and legislation, in particular compliance with anti-money laundering laws.
- For the legal enforcement of claims and rights.
4 Service ProvidersThe Company may engage third party companies ("Service Providers") to facilitate the operation of our Website, assist in analyzing the usage of the Website, or perform Website and service-related services, such as payment and the provision of IT infrastructure services. These third parties have access to the user’s personal data only to the extent necessary to perform these tasks on behalf of the Company.
Type(s) of service providers who might access your personal data:
- Accounting firms
- Other group entities
- Marketing firms
- Public authorities
5 Data transfersThe Company and/or the Service Providers may transfer your personal data to and process it in the following countries:
We safeguard your personal data per our contractual obligations and applicable data protection legislation when transferring data abroad.
Such safeguards may include:
- the transfer to countries that have been deemed to provide an adequate level of protection according to lists of countries published by the Federal Data Protection and Information Commissioner, as well as to countries where there is an adequacy decision by the European Commission in place;
- applying standard data protection model clauses, binding corporate rules or other standard contractual obligations that provide appropriate data protection.
6 Data disclosureWe may disclose your personal data in the good faith belief that such action is necessary:
- To comply with a legal obligation (i.e., if required by law or in response to valid requests by public authorities, such as a court or government agency);
- To protect the security of the Website and defend our rights or property;
- To prevent or investigate possible wrongdoing in connection with us;
- To defend ourselves against legal liability.
7 Data securityWe take reasonable technical and organisational security measures that we deem appropriate to protect your stored data against manipulation, loss, or unauthorised third-party access. Our security measures are continually adapted to technological developments.
We also take internal data privacy very seriously. Our employees and the Service Providers that we retain are required to maintain secrecy and comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate.
The security of your personal data is important to us but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. We recommend using antivirus software, a firewall, and other similar software to safeguard your system.
8 Data on the blockchainWhen using our blockchain-related Services, you should be aware that any transactions on a public blockchain will be publicly and irrevocably archived on such blockchain once you sign them and send them to the network. These transactions typically include information about how many tokens have been bought, sold, transferred or otherwise interacted with, a timestamp, and the involved addresses. They do not include personal data such as your name or e-mail address. Nonetheless, once someone knows that a particular address belongs to you, they can connect all the transactions involving that address to you.
9 NewsletterWe may send newsletters and other notifications by email and through other communication channels. We may have newsletters and other notifications sent by third parties or send them with the help of third parties.
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. We use "double opt-in" for any consent in the case of e-mails, i.e. you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time.
Newsletters and other notifications may contain web links or tracking pixels that record whether an individual newsletter or notification has been opened and which web links were clicked (performance measurement). Such web links and tracking pixels record the use of newsletters and other notifications. We need this statistical recording of usage, including success and reach measurement, in order to be able to offer newsletters and other notifications effectively and in a user-friendly manner, as well as permanently, securely and reliably, based on the reading habits of the recipients.
You can unsubscribe from newsletters and other notifications at any time and thereby object in particular to the aforementioned collection of usage. You can do so by contacting us directly or following the link included in the footer of each newsletter we send you.
10 Your rightsYou have the below data protection rights. To exercise these rights, you may contact the above address or send an e-mail to the indicated address. Please note that we may ask you to verify your identity before responding to such requests.
- Right of access: You have a right to request a copy of your personal data, which we will provide to you in an electronic form.
- Right to amendment: You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Right to withdraw consent: If you have provided your consent to the processing of your personal data, you have the right to withdraw your consent with effect for the future. This includes cases where you wish to opt-out from marketing communications. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you initially consented unless there is another legal basis for processing. To stop receiving emails from us, please click on the 'unsubscribe' link in the email you received or contact us.
- Right to erasure: You have the right to request that we delete your personal data when it is no longer necessary for the purposes for which it was collected or when it was unlawfully processed.
- Right to restriction of processing: You have the right to request the restriction of our processing of your personal data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial purpose, but where we are not able to delete it due to a legal obligation or because you do not want us to delete it.
- Right to portability: You have the right to request that we transmit your personal data to another data controller in a standard format such as Excel, where this is data which you have provided to us and where we are processing it on the legal basis of your consent or to perform our contractual obligations.
- Right to object to processing: Where the legal basis for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have a compelling legal basis for the processing which overrides your interests or if we need to continue to process the personal data for the exercise or defence of a legal claim.
- Right to lodge a complaint with a supervisory authority: You have the right of appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch/edoeb/en/home.html).
11 Links to third-party apps and sitesOur Website may contain links to websites or apps that are not operated by us. When you click on a third party link, you will be directed to that third party's website or app. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party websites or services.
We maintain online presences on social networks to, among other things, communicate with customers and prospective customers and to provide information about our products and services. If you have an account on the same network, it is possible that your information and media made available there may be seen by us, for example, when we access your profile. In addition, the social network may allow us to contact you. The content communication via the social network and the processing of the content data is thereby subject to the responsibility of the social network. As soon as we transfer personal data into our own system, we are responsible for this independently. This is then done in order to carry out pre-contractual measures and to fulfil a contract. For the legal basis of the data processing carried out by the social networks under their own responsibility, please refer to their data protection declarations. Below is a list of social networks on which we may from time to time operate an online presence: