# Privacy Policy ## **Summit Fintech (Swiss) AG** Summit Fintech (Swiss) AG (“Summit Fintech”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal data in accordance with applicable data protection laws, including the **Swiss Federal Act on Data Protection (FADP)** and the **General Data Protection Regulation (GDPR)** where applicable. This Privacy Policy explains how we collect, use, and protect personal information when you use the website: \*\*; or any related services. ### 1. Data Controller The data controller responsible for processing personal data is: **Summit Fintech (Swiss) AG** \ Gubelstrasse 11 \ Zug, 6300 \ Switzerland Email: **** ### 2. Personal Data We Collect We may collect the following categories of personal data: #### 2.1 Website Data When you visit our website, we may collect: * IP address * Browser type * Device information * Pages visited * Date and time of access * Referring website This data is used for: * Security monitoring * System administration * Website improvement #### 2.2 Contact Information If you contact us, we may collect: * Name * Email address * Company name * Phone number * Message contents This data is used to: * Respond to enquiries * Provide services * Maintain business relationships #### 2.3 Business and Compliance Data If you use our services or request onboarding, we may collect: * Identification information * Corporate registration documents * Beneficial ownership information * Compliance documentation * Transaction-related information This data is processed to: * Perform Know Your Customer (KYC) * Perform Know Your Business (KYB) * Conduct Anti-Money Laundering (AML) checks * Meet regulatory requirements #### 2.4 Blockchain Data Our services may involve blockchain technology. Blockchain transactions may include: * Public wallet addresses * Transaction identifiers * Transaction metadata Blockchain records are permanent and publicly accessible. Summit Fintech does not control third-party blockchain networks. ### 3. Legal Basis for Processing We process personal data based on: #### Legal Obligations Including: * Swiss Anti-Money Laundering regulations * Regulatory compliance requirements * Financial reporting obligations #### Contractual Necessity Processing required to provide services. Legitimate Interests Including: * Business operations * Security monitoring * Fraud prevention * Service improvement #### Consent Where required, such as: * Cookies * Marketing communications ### 4. Sharing of Personal Data We may share personal data with: #### Regulatory Authorities Including: * Swiss regulatory authorities * Self-Regulatory Organisations (SRO) * Law enforcement agencies When legally required. #### Service Providers Including: * Cloud hosting providers * Compliance service providers * Identity verification providers * Payment service providers Service providers are contractually bound to protect data. #### Professional Advisors Including: * Auditors * Lawyers * Compliance consultants ### 5. International Data Transfers Personal data may be transferred to countries outside Switzerland or the European Economic Area. Where such transfers occur, we ensure appropriate safeguards, including: * Standard contractual clauses * Adequate jurisdictions * Contractual protections ### 6. Data Retention We retain personal data only as long as necessary. Compliance data may be retained for: **10 years or longer** where required by Swiss law. Website data is retained for a shorter period unless required for security. ### 7. Data Security We implement appropriate technical and organisational measures including: * Encryption * Access controls * Secure infrastructure * Monitoring systems ### 8. Your Rights Depending on your jurisdiction, you may have the right to: * Access your personal data * Correct inaccurate data * Request deletion * Restrict processing * Object to processing * Data portability Requests may be submitted to: **** ### 9. Cookies Our website may use cookies and similar technologies. Cookies may be used for: * Essential website functionality * Security * Analytics You may control cookies through your browser settings. Where required, cookie consent will be requested. ### 10. Third-Party Links Our website may contain links to third-party websites. We are not responsible for their privacy practices. ### 11. Changes to this Policy We may update this Privacy Policy periodically. The latest version will always be available on: ; ### 12. Contact For privacy enquiries, contact: **Summit Fintech (Swiss) AG** Email: **** ### 13. Regulatory Status Summit Fintech (Swiss) AG operates as a **Virtual Asset Service Provider (VASP)** under Swiss regulations. Personal data may be processed for regulatory compliance and financial crime prevention purposes.