# Privacy Policy This Privacy Policy describes how **MONACOM AG** ("Monacom", "we", "us", or "our") collects, uses, stores, and shares personal information when you access or use our website and services (the "Services"). **Company details:**\ MONACOM AG\ Oberwiler Kirchweg 20\ 6300 Zug\ Switzerland\ Website: If you do not agree with this Privacy Policy, please do not use our Services. *** ### SUMMARY OF KEY POINTS * We collect business and personal information necessary to onboard, assess, and service business clients. * We do **not** sell personal data. * We do **not** use personal data for advertising profiling. * We process data primarily for compliance, security, operational, and contractual purposes. * We store and protect data using organizational and technical safeguards. * Users have rights under GDPR, Swiss data protection law, and other applicable regulations. *** ### 1. WHAT INFORMATION DO WE COLLECT? #### Information you provide to us We collect information that you voluntarily submit when you apply for, access, or use Monacom Services. This may include: **Business information** * Company name * Business registration details (e.g. EIN, company ID) * Registered address * Business activity description * Website and public online presence * Ownership and control information **User and contact information** * Full name * Email address * Login credentials * Communication records with Monacom **Compliance-related information** * Information required for internal risk assessment * Information necessary to meet legal, regulatory, or contractual obligations We do **not** intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data, or biometric data. *** #### Information collected automatically When you visit or use our Services, we may automatically collect: * IP address * Browser type and version * Device information * Operating system * Usage data (pages viewed, actions taken, timestamps) * Log and security data This information is used to maintain security, prevent fraud, and ensure proper system operation. *** ### 2. HOW DO WE PROCESS YOUR INFORMATION? We process personal information for the following purposes: * Reviewing and approving business applications * Providing access to the Monacom console * Issuing and managing payment details * Processing deposits, balances, conversions, and withdrawals * Maintaining internal accounting and records * Ensuring platform security and fraud prevention * Complying with legal and regulatory requirements * Communicating with clients regarding their accounts or services We do not use your data for automated decision-making without human review. *** ### 3. LEGAL BASES FOR PROCESSING We process personal data based on one or more of the following legal grounds: * **Performance of a contract** – to provide Monacom Services * **Legal obligation** – compliance with applicable laws and regulations * **Legitimate interests** – fraud prevention, security, operational integrity * **Consent** – where explicitly provided For users in Switzerland, the EEA, and the UK, processing is conducted in accordance with GDPR and applicable Swiss data protection laws. *** ### 4. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION? We may share personal information only in limited circumstances, including: * With service providers supporting payment processing, custody, infrastructure, or compliance * When required by law, regulation, or legal process * In connection with a corporate transaction (e.g. merger, acquisition, restructuring) All third parties are bound by contractual confidentiality and data protection obligations. We do **not** sell or rent personal data. *** ### 5. COOKIES AND TRACKING TECHNOLOGIES We may use cookies and similar technologies to: * Maintain platform functionality * Improve security * Analyze usage patterns Cookies are not used for behavioral advertising or profiling. You may control cookie settings through your browser. *** ### 6. SOCIAL LOGINS Monacom does **not** currently support social media login or authentication. *** ### 7. DATA RETENTION We retain personal information only as long as necessary to: * Provide Services * Fulfill legal, regulatory, and accounting obligations * Resolve disputes * Enforce agreements When data is no longer required, it is securely deleted or anonymized. *** ### 8. DATA SECURITY We implement appropriate technical and organizational measures to protect personal data, including: * Access controls * Secure storage systems * Internal segregation of client data * Cold wallet custody for digital assets where applicable No system is completely secure, and we cannot guarantee absolute security, but we continuously work to mitigate risks. *** ### 9. MINORS Monacom Services are intended exclusively for individuals aged **18 or older**.\ We do not knowingly collect data from minors. *** ### 10. YOUR PRIVACY RIGHTS Depending on your jurisdiction (Switzerland, EEA, UK, Canada, certain US states), you may have the right to: * Access your personal data * Correct inaccurate data * Request deletion of data * Restrict or object to processing * Request data portability * Withdraw consent where applicable Requests can be submitted using the contact details below. *** ### 11. DO-NOT-TRACK SIGNALS We do not currently respond to browser Do-Not-Track signals due to the lack of a standardized framework. *** ### 12. INTERNATIONAL USERS If you access Monacom from outside Switzerland, your information may be processed and stored in jurisdictions with different data protection laws. We take steps to ensure appropriate safeguards are in place. *** ### 13. UPDATES TO THIS POLICY We may update this Privacy Policy from time to time.\ The revised version will be posted on our website with an updated date. Continued use of the Services constitutes acceptance of the updated policy. *** ### 14. CONTACT US If you have questions about this Privacy Policy or your personal data, contact us at: **MONACOM AG**\ Oberwiler Kirchweg 20\ 6300 Zug\ Switzerland\ Email: **** *** ### 15. DATA ACCESS & DELETION REQUESTS You may request access, correction, or deletion of your personal data by contacting us at ****.\ We will respond in accordance with applicable data protection laws.