Privacy Policy in accordance with the Swiss Data Protection Act (DSG)

AlpsCon GmbH (hereinafter “AlpsCon”), based in Switzerland, operates a decentralized platform that provides access to a KI-based trading infrastructure. This platform is based on Smart Contracts and is fully integrated with the Binance Smart Chain (BSC).

TRAI, the token used on the platform, is purely a Utility Token intended solely for interaction with the platform. Although there is a swap function (see Section 5.4), no financial returns or profit distributions are made through TRAI.

The data protection guidelines comply with the Swiss Data Protection Act (DSG) and the EU Markets in Crypto-Assets Regulation (MiCA).

The entity responsible for data processing:

Data is processed solely for the following purposes:

• Technical operation of the platform
  • Provision and maintenance of decentralized infrastructure
  • Managing and tracking blockchain transactions
  • Conducting security checks (e.g., Smart Contract audits)
• Enabling TRAI functionality
  • Using TRAI for Smart Contract execution, license activation, and fee payment
  • An optional swap feature allows users to exchange TRAI for other cryptocurrencies (see Section 5.4)
• Compliance with legal and regulatory requirements
  • Ensuring TRAI is used solely as a Utility Token
  • Providing transparency on all transactions, as required by MiCA
  • Conducting KYC checks (with Sumsub) to fulfill AML and other relevant obligations
• KYC Procedure
  • Every user registering on the platform must undergo a KYC procedure. Only upon successful verification can the user fully utilize all platform features, including the swap function.
• User protection
  • Apart from the information required for KYC (see Section 4.1) and technical data necessary for operation, AlpsCon collects no additional personal data.
  • AlpsCon does not store any security-critical information such as private keys or wallet passwords.

4.1 KYC Data (Sumsub)

• Personal data such as name, date of birth, address, nationality, ID documents, etc., required for identity verification
• These data are collected directly by Sumsub, processed, and only passed on to AlpsCon to the extent necessary (e.g., “verified”/“not verified” status).
• Sumsub acts as a processor/service provider. Their data processing is subject to Sumsub’s privacy policy available on their website.

4.2 Technical Data

• Wallet addresses
• Transaction details (e.g., hash, block number, timestamp)
• Metadata such as network status and gas fees

4.3 Blockchain Data

All interactions with Smart Contracts are permanently stored on the Binance Smart Chain and are publicly visible. Subsequent deletion or modification of this data is not possible.

4.4 Server and Operational Logs

To ensure platform operation, AlpsCon may temporarily record logs (e.g., access times, IP addresses in anonymized or truncated form). These logs are kept only as long as necessary to provide services and fulfill legal obligations.

5.1 Use of TRAI

• Activating platform features (e.g., KI services)
• Paying fees for using the platform and Smart Contracts
• Controlling specific technical processes through Smart Contract interactions

5.2 No Profit Distribution

• No profit distributions or refunds are made through TRAI itself.
• Any profits generated by the KI are distributed exclusively in neutral cryptocurrencies (e.g., USDT) directly to user wallets, independent of TRAI.

5.3 Regulatory Assurance

• TRAI meets all criteria of a Utility Token according to MiCA and is not classified as a financial instrument or security.
• The platform does not offer any features that allow speculative or financial use of TRAI as an investment product.

5.4 Swap Function

• The platform provides a swap function, enabling users to exchange TRAI for other cryptocurrencies (and vice versa).
• No Guarantee: AlpsCon does not guarantee that sufficient liquidity or a particular exchange rate will be available at all times.
• User Risk: The swap process is automated. Users bear sole risk for losses, price fluctuations, or technical errors during swapping.
• Despite this function, TRAI remains primarily a Utility Token: The ability to swap does not change its fundamental nature as an access token.

The platform ensures a high level of security and transparency:

• Decentralization: All platform functions are fully decentralized and run directly via Smart Contracts.
• No central storage of wallet data: No private keys, wallet passwords, or similar access data are stored.
• Locking mechanisms: TRAI tokens placed in the Smart Contract can only be released under the conditions set forth in the code.
• User responsibility: Users are solely responsible for securing their wallet credentials. AlpsCon is not liable for losses due to improper use or safeguarding errors.
• Technical security measures: Regular review and updating of Smart Contracts (e.g., security audits), usage of common encryption and backup methods (e.g., email communication, backups), monitoring for suspicious activities.
• Incident response: Internal emergency plans, cooperation with external security experts and authorities if needed.
• Cooperation with Sumsub: KYC verification is carried out through Sumsub. AlpsCon implements organizational and technical measures to ensure secure data transfer.

7.1 User Rights

• Transparency: Users can trace their transactions on the blockchain at any time.
• Data Protection: Users have the right to request information about the personal data processed about them. Since KYC data is collected by Sumsub, users may contact Sumsub or AlpsCon for data inquiries.
• Contact options: Users can contact AlpsCon GmbH directly with any questions.
• Right to Complain: If users believe their personal data is being processed in violation of applicable data protection law, they have the right to lodge a complaint with a competent supervisory authority (EDÖB in Switzerland, national authorities in the EU).

7.2 User Obligations

• Adherence to Terms of Use: Users may only use TRAI for the intended technical purposes.
• KYC Requirement: Every user must successfully complete the KYC process via Sumsub before fully using the platform and especially before using the swap function.
• Wallet Responsibility: Users are responsible for securing and managing their wallet data.
• Prohibition of Abuse: Any attempts at manipulation or misuse of the platform are prohibited.
• Own Risk for Trading Decisions: Users bear sole responsibility for their trading decisions and use of KI services, as well as for performing swaps.

The data processing is based on the following legal foundations:

• Swiss Data Protection Act (DSG): Permitting the processing of technical data to provide platform functions.
• MiCA (Markets in Crypto-Assets Regulation): Ensuring transparency and compliance with requirements for Utility Tokens.
• Consent: By using the platform (and undergoing the KYC process), users consent to the processing of their personal data.
• AML/FINMA Requirements: KYC verification is required to prevent money laundering and terrorist financing.

The platform is provided #as is# in its current state.

• No Guarantee: AlpsCon GmbH does not guarantee uninterrupted availability or freedom from errors, nor the correct and complete function of Smart Contracts.
• Liability: AlpsCon is not liable for losses due to technical errors, network problems, or improper use. Liability for indirect, incidental, or consequential damages is excluded to the extent permitted by law.
• User Responsibility: Users assume full risk for any transactions made through their wallet.
• Market Risks: AlpsCon is not responsible for cryptocurrency market fluctuations or volatility. Users are solely responsible for their investment decisions. In particular, swapping TRAI for other cryptocurrencies may be subject to price fluctuations and liquidity risks.

AlpsCon reserves the right to update this Privacy Policy to reflect new regulatory requirements or technical changes. Changes will be announced at least 30 days before they take effect via the platform.

Since transactions take place on a public blockchain, data stored on the Binance Smart Chain may be accessed internationally.

• No active transfer of personal data to third parties or to countries outside Switzerland/EU/EEA by AlpsCon, except within the scope of KYC via Sumsub.
• Publicly viewable blockchain data is subject to the transparency and immutability features of BSC.
• Sumsub may process data in states outside Switzerland/EU/EEA if appropriate data protection safeguards (e.g., standard contractual clauses) are in place.

12.1 Blockchain Transactions

On BSC, technical data is stored permanently. Subsequent deletion or modification is practically impossible.

12.2 Internal Logs

AlpsCon GmbH only retains server logs as long as necessary to ensure operation and meet legal obligations. These logs are then securely deleted or anonymized.

12.3 KYC Data

The personal data held by Sumsub is processed and stored in accordance with Sumsubs privacy policy. AlpsCon only receives the necessary information (e.g., verified status) to manage the user’s access to the platform. For inquiries regarding retention and deletion of identity data, users may contact Sumsub or AlpsCon directly.

If there is reason to believe that personal data is being processed by AlpsCon or Sumsub, the following rights apply:

• Right of Access: Users have the right to request information about the personal data stored and processed about them.
• Rectification: Users may request the correction of inaccurate personal data.
• Erasure: Users may request the deletion of their personal data unless legal or contractual retention obligations prevent this.
• Restriction of Processing: Under certain conditions, users may request the restriction of data processing.
• Objection: Users may object to the processing of their personal data if legal requirements are met.

Please direct such requests to:
AlpsCon GmbH
Bösch 67, 6331 Hünenberg, Switzerland
E-mail: admin@alpscon.ai

Or contact Sumsub directly for questions regarding KYC-related data (details at sumsub.com).

• Dispute Resolution: In the event of disputes related to this Privacy Policy, Swiss law applies. The place of jurisdiction is Zug, unless otherwise required by law.
• Cooperation with Authorities: Where legally required, AlpsCon GmbH cooperates with competent authorities, providing necessary KYC or technical data upon request.
• No Profiling or Analysis Measures: No profiling or automated decision-making is performed based on personal data, except for Sumsub’s integrated identity checks and fraud prevention methods.
• Integration of External Services: If further external services (e.g., analytics or security) are integrated in the future, users will be informed, and this Privacy Policy will be updated accordingly.
• Risk Notice: Users are advised that trading in cryptocurrencies is highly speculative and involves risks, including total loss. The use of KI-based trading infrastructure does not relieve users of the obligation to act responsibly. The same applies to the swap function, where significant price fluctuations may occur.

For questions or concerns about using the platform or about data protection:

Additional notes: If specific scenarios or requirements arise, such as further emergency procedures or technical measures, this Privacy Policy may be expanded accordingly.

Effective Date: January 2025