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    © 2026 Eti-Tech AG. All rights reserved.

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    Eti-Tech AG offers its services from Switzerland to clients in Switzerland. We do not market, advertise or offer services in your country, and nothing on this website is an offer, solicitation or invitation directed at residents of your jurisdiction.

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    www.eti-tech.ch — Version 2.0 — 29 July 2026

    Privacy Policy

    The website www.eti-tech.ch is produced and published by Eti-Tech AG, Müligässli 1, 8598 Bottighofen, Switzerland ("Eti-Tech", "we", "us"), registered in the Commercial Register of the Canton of Thurgau. Eti-Tech AG is a member of the VQF Self-Regulatory Organisation (SRO) since November 2023 and is a Virtual Asset Service Provider (VASP) within the meaning of Art. 2 para. 3 of the Swiss Federal Act on Combating Money Laundering and Terrorist Financing (AMLA), supervised in that capacity through its VQF membership. Eti-Tech AG takes its data protection obligations with the utmost seriousness.

    We are responsible for the collection, processing and use of your personal data in accordance with applicable law, including the Swiss Federal Act on Data Protection (revDSG/nDSG) and, where applicable, the EU General Data Protection Regulation (GDPR). We are committed to protecting your personal data and your privacy.

    This Privacy Policy explains how Eti-Tech AG collects, uses, and discloses your personal data. Please read it carefully. Where the processing of your personal data requires your consent (for example, for marketing communications or non-essential cookies), we will request this separately and explicitly. Your access to or use of the website does not in itself constitute consent to any processing of personal data.

    1. Controller / Responsible Person

    The data controller responsible for the processing of your personal data is:

    Eti-Tech AG

    Müligässli 1, 8598 Bottighofen, Switzerland

    Email: compliance@eti-tech.ch

    Website: www.eti-tech.ch

    For data protection enquiries, including in your capacity as a data subject, please contact us at compliance@eti-tech.ch. This address is monitored by our compliance team and can be used by data subjects and supervisory authorities to raise data protection questions or concerns.

    2. What Personal Data We Collect

    2.1 Data Collected During Website Use

    When you visit our website for informational purposes only, our systems automatically collect the following technical data:

    • IP address
    • Date, time and time zone of your request
    • Pages accessed and content requested
    • HTTP status code and data volume transferred
    • Referring website
    • Browser type, version, language and operating system
    • Device, cookie and pixel identifiers and information on your interactions with our website, emails and advertisements (only where you have consented, see Section 8)
    • Error and diagnostic data (e.g. error reports processed via Sentry)

    2.2 Data Collected During Registration and Onboarding

    As a VASP and VQF SRO member, Eti-Tech AG is legally required to verify the identity of its customers (KYC – Know Your Customer) before providing services. When you register or place an order, we collect the following data depending on your account type:

    Individual Accounts:

    • Full legal name, date and place of birth, nationality
    • Residential address and proof of address
    • Geolocation data (GPS location of your device, only after you grant your device's location permission, and IP address) captured by our identity verification provider Sumsub during onboarding to verify your residential address
    • Phone number and email address
    • If you log in via Google or Apple (single sign-on): the name, email address and account identifier provided by that provider
    • Profession, employer, place(s) of business activity
    • Financial background: declaration of estimated income and assets, source(s) of income (employment, savings, inheritance, investment, own business, other)
    • Government-issued photo ID (passport, national ID or driver's licence)
    • Images of your identity document and data read from its machine-readable zone (MRZ) and, where offered in future, from its biometric chip (NFC)
    • Biometric verification data (facial photograph and liveness check via our identity verification provider, Sumsub) — this data constitutes special category / sensitive personal data under GDPR Art. 9 and revDSG Art. 5(c), processed for identity verification under GDPR Art. 9(2)(g) (substantial public interest — AML/CTF obligations under AMLA and FINMA Circular 2016/7), subject to enhanced safeguards including strict access controls and data minimisation
    • Responses to AML/compliance questionnaire
    • Results of identity, document, liveness, PEP, sanctions and adverse-media checks carried out by Sumsub
    • Bank details of your Verified Bank Account(s) (account holder name, IBAN, bank) obtained from the verification payment (penny transfer)
    • Your beneficial owner declaration (Form A) and the record of its electronic confirmation (TAN / confirmation checkbox, timestamp)
    • Intended use and planned transaction volumes
    • Where required for enhanced due diligence, ongoing transaction monitoring or the periodic review and updating of your client file: additional information and documents, for example evidence of the source of your funds or wealth (e.g. salary statements, bank statements, sale or inheritance documents, tax returns); information on the background and purpose of specific transactions; confirmation or update of your personal details (e.g. address, occupation, nationality, tax residence); a valid identity document if yours has expired; and an updated beneficial owner declaration (Form A)

    2.3 Data Collected During Transactions

    When you use our exchange, conversion, and non‑custodial wallet services, we collect:

    • Transaction details (amounts, currencies, timestamps, order IDs, exchange rates)
    • Wallet addresses and blockchain transaction data (public keys, transaction hashes, chain/network information)
    • Results of Wallet ownership/control verification checks — see Section 6.3 below
    • Payment method information (bank transfer reference, IBAN for verification purposes)
    • Order history and account activity
    • Data relating to the self-custodial wallets we create for you with our wallet provider Privy (one wallet per blockchain family; wallet addresses, creation date). To link your wallets to your account, we pass only a pseudonymous account identifier to Privy
    • Records of pending settlements (orders for which we have received your funds or crypto assets but have not yet delivered the output)

    Note on wallet addresses and blockchain data: Public wallet addresses and transaction hashes, when held by Eti-Tech in combination with your KYC identity information, constitute personal data and are treated as such throughout this Privacy Policy. Blockchain transactions are recorded on public, immutable ledgers beyond our control. The right to erasure applies to data held in Eti-Tech's systems but cannot extend to public blockchain records, which we have no technical ability to modify or delete.

    2.4 Communication Data

    If you contact us by email, chat or other channels, we retain the content of your messages together with your contact details in order to respond to your enquiry and maintain our compliance records. This includes communication via Telegram, via the chat function of a P2P platform and via our AI-based chat assistant (see Section 6.1).

    2.5 Data from P2P Platforms

    If you transact with us via a peer-to-peer platform on which we act as merchant, we receive from the platform your username, the order details (order ID, amount, price, timestamps), the messages you exchange with us in the platform chat and, after verification, the name associated with your platform account. Our bank also provides us with the payer name and IBAN of your payment.

    2.6 Data from Other Sources

    Where we do not collect data from you directly, we obtain it from: sanctions, PEP and adverse-media databases (via Sumsub); blockchain analytics providers; our banking partners; P2P platforms; and, where required for enhanced due diligence under our AML obligations, publicly available sources such as internet searches, company registers, social media and street-view services.

    2.7 Data About Other Persons

    If you provide us with personal data about other persons (for example in payment references, support requests or source-of-funds documents), you must ensure that you are entitled to do so and that these persons are aware of it. We process such data in accordance with this Privacy Policy.

    3. How We Use Your Personal Data

    We use your personal data for the following purposes:

    • To provide and operate our cryptocurrency exchange, conversion and non-custodial wallet services
    • To fulfil our legal obligations as a VASP and VQF SRO member, including AML/KYC compliance, transaction monitoring and suspicious activity reporting
    • To verify your identity and assess your risk profile in accordance with the Swiss Anti-Money Laundering Act (AMLA) and FINMA guidance
    • To assign and maintain your AML risk category as required by our AML procedures, and to apply corresponding monitoring and due diligence measures
    • To verify ownership and control of virtual asset wallet addresses associated with your account, in accordance with the Travel Rule and our AML standards
    • To process your orders, transactions and payments
    • To manage your user account
    • To communicate with you about your account, orders, and important service updates
    • To improve and develop our platform, products and services
    • To create and manage the self-custodial wallet provided to you through our wallet infrastructure provider
    • To onboard and serve customers who approach us via P2P platforms
    • To measure the effectiveness of our advertising and to show you relevant advertising on third-party platforms (e.g. Meta), where you have consented
    • To monitor the stability and security of our platform and to detect and fix errors
    • To calculate commissions owed to referral or affiliate partners (see Section 6.9)
    • To send you newsletters or marketing communications, where you have consented
    • To comply with applicable Swiss and international legal and regulatory obligations, including mandatory reporting to MROS, SECO and VQF
    • To detect, prevent and investigate fraud, money laundering and other illegal activities

    4. Legal Basis for Processing

    We process your personal data on the following legal bases:

    • Contract performance (Art. 6(1)(b) GDPR / revDSG): Processing necessary to provide our services and fulfil our contractual obligations to you.
    • Legal obligation (Art. 6(1)(c) GDPR / revDSG): Processing required to comply with Swiss AML/KYC law (AMLA, AMLO, AMLO-FINMA), FINMA guidance and circulars, VQF SRO rules, and applicable sanctions regulations.
    • Legitimate interests (Art. 6(1)(f) GDPR / revDSG Art. 31): Processing necessary for our legitimate business interests, including fraud prevention, platform security, blockchain analytics (where not mandated by law), and service improvement, where our interests are not overridden by your fundamental rights. Note: AML risk scoring and mandatory transaction monitoring are processed primarily on the basis of legal obligation (see above), not legitimate interests.
    • Consent (Art. 6(1)(a) GDPR / revDSG): Where you have provided specific consent, for example for marketing communications or optional features. You may withdraw consent at any time without affecting the lawfulness of prior processing.
    • Geolocation and biometric data: GPS location is captured only after you grant your device's location permission; if you refuse, we verify your address by other means (e.g. a utility bill). Biometric data (facial photograph, liveness check and face comparison) is processed primarily because we are legally required to identify you (see Section 2.2). In addition, at the start of the identity verification flow and before any data is captured, we ask for your explicit consent to the processing of your personal data, including biometric data, as described in this Privacy Policy, which you give by continuing past the consent notice on the first screen of the verification flow (Art. 6 para. 7 revDSG; Art. 9(2)(a) GDPR). As we identify customers exclusively online, onboarding is not possible without this consent. You may withdraw it at any time with effect for the future; data already collected must nevertheless be retained for the statutory AML retention period (Section 5).

    Providing your personal data: by law (AMLA), you must provide the identification and due diligence data described in Sections 2.2 and 2.3 before we can open or maintain an account for you; without it we cannot enter into or continue a business relationship with you. The same applies to any additional information we request during the business relationship for enhanced due diligence, transaction monitoring or the periodic review of your client file (see Section 2.2). If you do not provide it within the period we set, we may restrict our services and, if necessary, terminate the business relationship. Providing data for marketing purposes and consenting to non-essential cookies is voluntary; refusing has no effect on your use of our services.

    5. Data Retention

    We retain your personal data only for as long as necessary for the purposes for which it was collected, and in strict accordance with our legal obligations under Swiss AML law (Art. 7 AMLA, Art. 64 VQF-Regulation, Art. 958 CO):

    Customer identification and KYC records: Retained for a minimum of 10 years following the termination of the business relationship, as required by Art. 7 para. 3 AMLA and Art. 64 VQF-Regulation.

    Transaction records and documentation: Retained for a minimum of 10 years after the end of the financial year in which the relevant transaction was executed or the report was made, in accordance with Art. 958 CO and Art. 7 para. 3 AMLA. This may therefore extend beyond 10 years from the end of the business relationship depending on when transactions occurred.

    Other records:

    • Account data: retained for the duration of your account and thereafter for the applicable legal retention period
    • Communication records: retained for as long as necessary to respond to your enquiry and satisfy applicable record-keeping requirements
    • General website server logs: retained for a maximum of 6 months unless required longer for security or legal purposes
    • Technical data collected during identity verification and transactions (e.g. IP address, device and geolocation data), whether held by us or by our identity verification provider on our behalf: retained as part of the AML file for the same period as customer identification records
    • Rejected applications: 10 years from rejection, as documentation of the rejection under our AML obligations
    • Marketing data: until you unsubscribe or withdraw your consent
    • Cookie and pixel data: Google Analytics up to 2 years, Meta Pixel up to 3 months, Klaviyo up to 2 years; necessary cookies for the duration of the session or up to 12 months

    After the applicable retention period, data is securely deleted or anonymised.

    6. Data Sharing and Disclosure

    We do not sell, rent or trade your personal data to third parties. We may share your data in the following limited circumstances:

    6.1 Service Providers and Processors

    We engage carefully selected third-party providers to assist with identity verification (Sumsub), blockchain analytics and wallet screening, IT infrastructure, and compliance tooling. These providers act as data processors under contractual data protection agreements and are subject to confidentiality obligations. We currently use the following categories of providers:

    • Identity verification and screening: Sumsub (Sum and Substance Ltd., United Kingdom). Data may be processed in the United Kingdom, the EEA and other countries where Sumsub or its sub-processors operate. Sumsub retains data on our behalf no longer than our retention periods (Section 5), unless it is itself legally required to retain it longer. Where Sumsub processes data for its own purposes (e.g. its own legal obligations or fraud prevention), it acts as an independent controller under its own privacy notice, which is shown to you at the start of the verification flow.
    • Wallet infrastructure: Privy (USA) for customer wallets; Privy receives only a pseudonymous account identifier to link your wallets to your account, and no name, email address, password or 2FA secrets
    • Blockchain node infrastructure: QuickNode (USA)
    • Hosting, database and account authentication: Amazon Web Services (region eu-central-2, Zurich, Switzerland), including Amazon Cognito for login
    • Blockchain analytics and wallet screening: Chainalysis (USA) and/or Scorechain (Luxembourg)
    • Office, email and document tools: Google Workspace (Google)
    • Error monitoring: Sentry (Functional Software, Inc., USA)
    • Messaging: Telegram, for communication you initiate via Telegram
    • Web analytics: Google Analytics (Google); email marketing: Klaviyo (USA); advertising measurement: Meta (see Section 8)
    • AI-based chat assistant: Teticum (Italy), using its own AI model; chat content may be used to train the model operated for Eti-Tech only

    6.2 Regulatory and Law Enforcement Authorities

    We are required by Swiss law to disclose data to our supervisory authority, the VQF Self-Regulatory Organisation, and to the Money Laundering Reporting Office Switzerland (MROS), upon lawful request or where we have a legal obligation to report. This includes mandatory reporting under Art. 9 AMLA and sanctions reporting to SECO. FINMA, as the authority recognising VQF, may receive information indirectly through VQF's supervisory process, or directly where required by law.

    International Tax Reporting (AEOI/CRS): Switzerland participates in the OECD Automatic Exchange of Information (AEOI) framework (Common Reporting Standard / CRS) via the AEOI Act (AEIA). Depending on your country of residence, Eti-Tech may be required to report your account information to the Swiss Federal Tax Administration (FTA), which may onward-transmit this to the competent tax authority in your country of residence. The legal basis is legal obligation (GDPR Art. 6(1)(c) / revDSG).

    FINMA International Supervisory Cooperation: FINMA, as the authority recognising VQF and overseeing the Swiss financial market, has the power under AMLA Art. 29 to share supervisory information with foreign financial market authorities. Where information originates from Eti-Tech, it flows to FINMA via VQF's supervisory process; Eti-Tech has no control over such onward sharing by regulatory bodies once transmitted.

    Important limitation on your rights: Your rights of access, rectification, and information under data protection law may be restricted or delayed to the extent required by applicable Swiss law, including anti-money-laundering legislation. This limitation applies for as long as the underlying legal obligation subsists. See Section 9 for how this affects your data subject rights generally.

    6.3 Wallet Ownership Verification and Blockchain Screening

    We provide access to a non-custodial Wallet environment through a third-party Wallet infrastructure provider. When you provide a virtual asset wallet address or initiate a crypto transaction, we take steps to verify that the wallet is genuinely owned and controlled by the relevant party, as required by the Crypto Travel Rule (Art. 14 VQF-Regulation).

    Where a wallet was provisioned through our Wallet service for a customer who has completed KYC, that provisioning constitutes evidence of that customer's ownership and control of the wallet in accordance with our AML/CTF Policy; we may nevertheless require additional verification on a risk-based basis. Where verification is required, we verify ownership and control of the relevant wallet using one or more recognised methods, which may include digital-signature / message-signing verification, micro-transaction ("Satoshi test") verification, or equivalent blockchain-analytics proof-of-control checks. This involves processing your wallet address together with the verification data produced by these methods.

    Where you receive virtual assets from a wallet you do not own (for example, from a third party), we may request additional information about the source of those funds as part of our AML review, in accordance with Section 8.1A of our General Terms and Conditions.

    6.4 Travel Rule: Inter-VASP Data Transfers

    As required by the Crypto Travel Rule (Art. 14 VQF-Regulation and FATF Recommendation 16), where we ourselves transfer virtual assets to, or receive them from, a wallet or account held at another VASP, we are required to transmit the following information to the receiving or sending VASP via a secure communication protocol:

    • Your full name
    • Your public wallet address
    • Your residential address
    • The name and public address of the beneficiary

    This data transfer is a legal obligation and constitutes a disclosure to a third party (the counterpart VASP) that we are required to make regardless of your consent. We may reject, delay, or hold any incoming transaction where the Travel Rule information required from the sending side is insufficient, cannot be validated, or is not provided in a form we can process. The safeguards applicable to this transfer — including the legal basis under Swiss and EU data protection law where the receiving VASP is located outside Switzerland or an adequate jurisdiction — are set out in Section 6.7 below.

    6.5 Banking and Payment Partners

    Limited transaction data is shared with our banking and payment partners (including details required under Art. 10 AMLO-FINMA for fiat transfers: customer name, account number, address or date of birth) as required to process your transactions. Our banking partners are currently Relio and Maerki Baumann & Co. AG, both in Switzerland. They act as independent controllers and may request information from us where required by their own AML obligations.

    6.6 Legal Proceedings

    Where necessary to establish, exercise or defend legal claims.

    6.7 International Data Transfers

    Certain processing activities require the transfer of personal data outside Switzerland. The following summarises the transfer categories and applicable safeguard mechanisms:

    (a) Travel Rule transfers to foreign VASPs: mandatory legal obligation under FATF R16 / Art. 14 VQF-Regulation. Transfer basis: Art. 17(2)(c) revDSG / GDPR Art. 49(1)(c) (important public interest — AML/CTF compliance).

    (b) Identity verification (Sumsub): where Sumsub processes data outside Switzerland or the EEA, transfers are conducted under Standard Contractual Clauses (SCCs) and a Data Processing Agreement imposing GDPR/revDSG-equivalent obligations. The United Kingdom and the EEA are recognised as providing adequate data protection under Swiss law.

    (c) Analytics (Google Analytics / Google LLC, USA): EU-US Data Privacy Framework (DPF) for GDPR purposes and Swiss-US DPF for revDSG purposes, based on Google LLC's certification. See Section 8.1.

    (d) Regulatory and law enforcement disclosures: transfers to foreign authorities pursuant to AMLA Art. 29, AEOI/CRS, or other mandatory legal obligations are conducted on the basis of legal obligation (GDPR Art. 6(1)(c) / revDSG).

    (e) Other service providers outside Switzerland (in particular Privy, QuickNode, Sentry, Klaviyo, Meta and Google Workspace): transfers are based on the provider's certification under the Swiss-US and EU-US Data Privacy Framework where available, and otherwise on SCCs.

    Where data is transferred outside Switzerland, we ensure appropriate safeguards are in place. Our AMLA files are kept on our administration system in Switzerland, in accordance with Art. 63 VQF-Regulation and Art. 9/10 of the Swiss Accounts Ordinance.

    Data storage location: In accordance with Art. 63 VQF-Regulation, the authoritative copy of all customer records, AMLA files and transaction documentation is kept on servers located in Switzerland. Certain data is also processed by the service providers listed in Section 6.1, including outside Switzerland, subject to the safeguards described above.

    6.8 P2P Platforms

    If you transact with us via a P2P platform, the platform processes your data as an independent controller under its own privacy policy. We do not transfer your KYC data to the P2P platform.

    6.9 Referral and Affiliate Partners

    If you come to us via a partner's referral link, we record the referral identifier with your account in order to calculate the partner's commission based on your transactions and fees. The partner receives no personal data about you.

    6.10 Corporate Transactions

    If Eti-Tech AG is merged, sold or transfers all or part of its business, your personal data may be transferred to the acquirer or successor to the extent necessary to continue the business relationship. Before such a transaction, we may disclose data to potential acquirers and their advisers to the extent necessary for their assessment, under confidentiality obligations and, where possible, in anonymised or pseudonymised form. The successor will continue to process your data in accordance with this Privacy Policy or will inform you of any changes.

    7. Automated Decision-Making and Risk Profiling

    As part of our AML/CTF compliance obligations, we use automated tools (including sanctions, PEP, and watchlist screening software) to support the assignment of a risk category to each customer, based on criteria defined in our AML standards. These tools flag relevant factors, but the resulting risk classification — and any decision to accept, restrict, continue, or terminate your business relationship — is always made or approved by a trained member of our compliance staff, and every automated result is reviewed by such a person (see the next paragraph for automated results in onboarding). Consequently, this processing does not constitute a decision “based solely on automated processing” within the meaning of GDPR Art. 22 / revDSG Art. 21.

    During onboarding, our identity verification provider produces automated results (for example, a proposed approval or rejection of a verification step). These results are preliminary only: they do not by themselves trigger any decision or further process on our side. The decision to accept or reject your application is always taken by a member of our staff after reviewing the result. If you nevertheless believe that a decision concerning you was based solely on automated processing, you may state your position and request a review by a natural person (Art. 21 revDSG; Art. 22(3) GDPR).

    This risk scoring affects:

    • The level of due diligence applied to your account
    • The frequency of periodic reviews of your account records

    Risk categorisation is a legal requirement under Swiss AML law. Because it is not a solely automated decision, it is not, strictly speaking, subject to a right to object under Art. 21 GDPR; however, if you believe your risk category has been incorrectly assigned, you may always contact us at compliance@eti-tech.ch to request a review.

    Your rights regarding risk decisions (offered as a transparency measure, consistent with the spirit of GDPR Art. 22 / revDSG Art. 21):

    • Right to information about the logic: The main factors include your country of residence, the source of your funds and your planned transactions.
    • Significance and consequences: Your risk classification determines the level of due diligence applied to your account and the frequency of periodic review.
    • Right to a further human review: Even though a human is always involved in the original decision, you may request that it be reviewed again by a different, more senior member of our compliance team. Contact compliance@eti-tech.ch with your account details and the decision to be reviewed. We will acknowledge within 2 business days and complete the review within 10 business days. You may submit additional information in support of your request.
    • Limitations: AML risk categorisation is a legal obligation under AMLA and cannot be waived. Rights under this section may also be restricted where required by applicable law, including in connection with regulatory reporting obligations (see Section 6.2).

    Cookies, analytics, and other automated data collection on our website (see Section 8 below) rest on a separate legal basis (consent under applicable cookie/ePrivacy rules) and do not, on their own, result in any decision with a legal or similarly significant effect on you.

    Marketing and usage profiling: where you have consented, we use data collected via Google Analytics, the Meta Pixel and Klaviyo to analyse your use of our website and emails and to tailor advertising and communications to your interests. This profiling does not result in decisions with legal or similarly significant effects on you. You can withdraw your consent at any time (see Sections 8 and 12).

    8. Cookies and Tracking

    8.1 Cookies

    Our website uses cookies – small text files stored on your device – to improve your experience. We use:

    • Session cookies: to maintain your session and carry information across pages without you having to re-enter data.
    • Persistent cookies: to recognise returning visitors and measure website usage patterns.
    • Analytics cookies: we use Google Analytics (Google LLC, USA) to analyse website usage. Google Analytics involves the transfer of personal data to Google's servers in the United States. This transfer relies on Google LLC's certification under the Swiss-US and EU-US Data Privacy Framework (DPF). Analytics cookies are non-essential and are only set after you provide explicit consent via our cookie consent banner. You may withdraw consent at any time or opt out at https://tools.google.com/dlpage/gaoptout.
    • Advertising (Meta Pixel): with your consent, we use the Meta Pixel of Meta Platforms Ireland Ltd. (with transfers to Meta Platforms, Inc., USA) to measure the effectiveness of our advertising and to show you relevant ads. Meta receives your IP address, browser data, pixel identifiers and events on our website (e.g. page views, start of registration). We and Meta are joint controllers for the collection and transmission of this data (Art. 26 GDPR); Meta is solely responsible for its further processing. We do not transmit KYC data, identity documents or transaction amounts to Meta.
    • Email and on-site tracking (Klaviyo): with your consent, Klaviyo, Inc. (USA) records whether you open our emails, click on links and which pages you visit after doing so.
    • Strictly necessary technologies: including storage used for login (Amazon Cognito) and by our identity verification provider Sumsub during onboarding. These do not require consent.

    8.2 Managing Cookies

    You may configure your browser to refuse or delete cookies. Please note that disabling cookies may affect the functionality of our website. We implement cookie banners to obtain your consent for non-essential cookies in accordance with applicable law. Our cookie banner names the tools we use and their purpose, links to this Privacy Policy and allows you to accept or reject all non-essential cookies. You can change your choice at any time by reopening the banner via the link in the website footer.

    8.3 Social Media Pages

    We maintain pages on X, LinkedIn, YouTube, Reddit, Instagram and Telegram and a profile on Trustpilot. When you interact with these pages, the respective operator processes your data under its own privacy policy. For page statistics (insights) we may be joint controller with the operator. We do not currently send review invitations; if you post a review on Trustpilot, Trustpilot processes your data under its own privacy policy.

    9. Your Rights

    Subject to applicable law (revDSG / GDPR), you have the following rights regarding your personal data:

    • Right of access: to obtain confirmation of whether we process your data and receive a copy
    • Right to rectification: to request correction of inaccurate or incomplete data
    • Right to erasure: to request deletion of your data, subject to our legal retention obligations
    • Right to restriction: to request that we restrict processing of your data in certain circumstances
    • Right to data portability: to receive personal data you provided to us and that we process by automated means on the basis of consent or a contract, in a structured, machine-readable format (CSV or JSON). In scope: account profile data, transaction history, and order history. Not in scope: data processed solely on the basis of legal obligation (including AML/KYC records subject to mandatory retention)
    • Right to object: to object to processing based on legitimate interests
    • Right to withdraw consent: at any time, where processing is based on consent

    Important limitations:

    The exercise of certain rights is limited or overridden by our legal obligations as a regulated entity:

    • Mandatory AML/KYC record retention (minimum 10 years) limits the right to erasure.
    • AML risk categorisation is a legal requirement and is not subject to the right to object.
    • Your rights of access and information may be further limited where required by applicable law, including in connection with the regulatory reporting obligations described in Section 6.2 above.

    To exercise any of the above rights, or to raise a data protection concern, please contact us at: compliance@eti-tech.ch

    Response timeframes: We will respond to data subject rights requests within 30 calendar days. Where a request is complex, we may extend by up to a further 60 days, notifying you within the initial 30-day period with reasons for the extension.

    Identity verification: To protect your data, we will verify your identity before processing any rights request. We may ask you to confirm information on file (registered email, account number, or other identifying details).

    How to submit: Data protection, compliance, and AML requests should all be directed to compliance@eti-tech.ch. Please specify the right you are exercising and include your account details.

    Right to lodge a complaint: You have the right to lodge a complaint with a data protection supervisory authority. If you are resident in Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC), www.edoeb.admin.ch. If you are resident in an EU/EEA member state, you may instead or additionally lodge a complaint with the data protection supervisory authority of your country of residence; a list of EU/EEA supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

    10. Data Security

    Eti-Tech AG implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

    • SSL/TLS encryption for all data transmitted to and from our website
    • Two-factor authentication (2FA) for user accounts (TOTP; optional, can be activated in your profile)
    • Self-custodial wallets: Eti-Tech holds no key share or signing permission for your wallet. If you view or export your private key, you are responsible for keeping it secure.
    • Access controls limiting data access to authorised personnel on a strict need-to-know basis
    • Secure, encrypted data storage; AMLA files kept in Switzerland
    • Regular review and updating of our security measures
    • Confidentiality classification of all AMLA files as “Confidential”

    Despite our best efforts, no system can guarantee complete security against all threats. In the event of a personal data breach posing risk to individuals: (a) where the breach is likely to result in a high risk to you, we will notify the FDPIC as soon as possible (Art. 24 revDSG) and, where the GDPR applies and requires it, the competent EU supervisory authority within 72 hours; (b) where this is necessary for your protection or required by law, we will also inform you directly without undue delay, describing the breach, its likely consequences, and remedial measures taken; (c) we maintain an internal data breach register; (d) where a breach occurs at a third-party processor, our data processing agreements require them to notify us without undue delay.

    11. Children

    Our services are not directed at persons under the age of 18. This reflects both our own policy and the age of legal capacity to enter into binding contracts under Art. 14 of the Swiss Code of Obligations (CO/OR), which our KYC and account-opening processes require. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately at compliance@eti-tech.ch and we will take steps to delete it.

    12. Newsletter and Marketing Communications

    If you subscribe to our newsletter or opt in to marketing communications, we will use your name and email address to send you updates about our products, services and the crypto ecosystem. Your consent forms the legal basis for this processing. We collect this consent through a separate opt-in that is not pre-ticked. We use Klaviyo, Inc. (USA) to send newsletters and to measure opens and clicks. If you are a customer, we may also send you information about our own similar services by email without prior consent (Art. 3 para. 1 lit. o UWG); you can object at any time, including via the link in every such email.

    You may unsubscribe at any time by clicking the unsubscribe link in any communication or by contacting us at compliance@eti-tech.ch. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

    13. Changes to This Privacy Policy

    We may update this Privacy Policy from time to time. A material change includes: introduction of a new data category, new processing purpose, new recipient category, or change to retention periods. We will provide at least 30 days' advance notice of material changes by email and via a prominent notice on the Platform. The version published on our website at the relevant time applies. Minor updates (formatting, clarifications, contact details) may take effect immediately.

    This Privacy Policy is drafted in English and may be made available in German, French and Italian. In the event of any discrepancy, the English version prevails.

    14. Contact Us

    For any questions, requests or concerns regarding this Privacy Policy or the processing of your personal data, please contact us:

    Eti-Tech AG

    Müligässli 1, 8598 Bottighofen, Switzerland

    Email: compliance@eti-tech.ch (contact point for all data protection matters)

    Website: www.eti-tech.ch

    Eti-Tech AG is a member of the VQF Self-Regulatory Organisation (SRO) and is a Virtual Asset Service Provider (VASP) within the meaning of Art. 2 para. 3 AMLA, supervised in that capacity through its VQF membership. | Version 2.0 — 29 July 2026 | Supersedes Version 1.9