Privacy Policy

General

Last Updated: Oct 6, 2024

Thank you for visiting our webpages, which are at least https://swisstechcapital.com, https://globalforce.io, https://dev.globalforce.io, https://wiki.globalforce.io and also additional ones and using our Services.

When you visit our pages and use our products, you entrust us with your personal data.

We are absolutely committed to treating your personal data with care and respect.

This Privacy Policy describes how Swiss Tech Capital and Global Force collects and uses your personal data in relation to our websites, services, events, and experiences that reference this Privacy Policy (together, the "Services").

This Notice does not apply to job applicants. If you are a job-applicant, please ask directly for our candidates' privacy policy.

This Privacy Notice also does not apply to any products, services or content that are offered by third parties having their own privacy policies, including other entities of the Swiss Tech Capital AG.

When you use Swiss Tech Capital and Global Force, the controller of the personal data you provide is Swiss Tech Capital AG, an enterprise incorporated under the laws of Switzerland, with the registered office at Bann 7, 6312 Steinhausen, Switzerland. Place of jurisdiction is Zug, Switzerland and Swiss Law is bindingly and irrevocably agreed.

In the following referred to as: "STC", “Global Force”, “us”, “we”, “our”.

How to contact us: Swiss Tech Capital Privacy Office: privacy@swisstechcapital.com

I. Sources of personal data

1.1 STC processes personal data provided by data subjects themselves or collected when they use our Services: Registration information required for registering the Services. When you choose to sign up for our Service through your Google account (or any other third-party account permitted by STC), you are also authorizing us to receive, store, and use such information that you have agreed that Google or such other third parties could provide to us through their application programming interface.

1.2 Information you may provide when you communicate with us by phone, e-mail, or otherwise. Provided you have been duly informed by us, we may monitor and record phone calls, e-mails, live chats, or other communications between you and our Service representatives or other STC's representatives, to improve and monitor the quality of our Services:You may provide your information through web forms to be contacted by us or to submit your request or query to us.

(1) You may provide us information we need to check your identity as part of our KYC procedures.

(2) You may provide information on behalf of another person or entity. If you completed the registration on behalf of another entity or if you otherwise provide information regarding another person or entity, you represent to us that you were authorized by that person or entity to use the submitted information.

(3) You may provide your personal information such as your mobile device information, action history, transaction history, wallet address, etc.

(4) When you are directed to a third-party DApp, the DApp will collect personal information from you and you may provide these data. GlobalForce does not keep the personal information collected by the third-party DApp. We need to access your camera when you save an image to your photo library or scan a QR code. Your refusal to agree means that you will not be able to scan or save images to a photo library. Please turn on the corresponding access when you need to scan or save again.

(5) When you visit or access our Services, upon your consent, we may use (and authorize 3rd parties to use) pixels, cookies and other technologies (collectively, "Cookies") as further detailed in Paragraph 8 of this policy.

II. Personal data we process

2.1 STC processes personal data related to its potential and current customers (individuals or representatives of legal entities), individuals who actually use the services (users), and users of the Website. The categories of processed personal data include:

(1) Full name;

(2) Contact information such as email address, phone number;

(3) Job title;

(4) Company name;

(5) Company size;

(6) Company industry;

(7) Other information provided by the customer in the registration form;

(8) Payment and billing details;

(9) Authentication or authorization data;

(10) Information contained in support requests;

(11) Metadata: personal data STC collects or generates during the provision and administration of any decentralized service and cloud services, information about user's preference and usage of the Service, including user identifiers, authentication credentials, resource identifiers and attributes, IP-addresses, cloud settings and configurations. We collect information about operational status, software errors and crash reports, quality and performance metrics, and other technical details necessary for us to operate and maintain cloud services and related software;

(12) Type and device ID, identifiers from cookies or tokens;

(13) your personal information such as your mobile device information, action history, transaction history, wallet address, etc.

(14) Browser type and version;

(15) Geographical location based on the IP address;

(16) Statistics on page views and time spent on pages;

(17) Information about usage of the Website obtained through Cookies or similar technologies;

(18) Your direct communications. We may keep records of your communications and interactions with us, for example, when you provide feedback or contact information, ask questions or seek technical support;

(19) Partially obscured copies of your ID document (when this is requested, only the following field being visible: picture, name and surname, nationality place and type of document, first 4 digits of the document number), in specific cases of our KYC process.

(20) When you are directed to a third-party DApp, the DApp will collect personal information from you. GlobalForce does not keep the personal information collected by the third-party DApp.

2.2 You acknowledge that your wallet password, private key, mnemonics, and Keystore on GlobalForce are not stored in or uploaded to our servers. We do not provide any service to recover your wallet password, private key, mnemonics or Keystore.

2.3 Sensitive personal data: We do not intentionally collect sensitive personal data (for example, information revealing race, ethnic origin, political opinions, religion, etc.) and we ask our users not to provide us with such information.

III. Why we process your personal data

3.1 We only collect and use personal data for the scopes which are necessary in connection with the processing of your request/query, to verify your identity if you contact us, to send you our newsletter, enhance both the performance and the content of our websites, to tailor our services and our websites to our customers' and users' preferences, to analyze trends and to comply with any law in accordance with the applicable legislation, to protect us and our users/customers, from fraud or other illegal activities. More specifically to:

(1) To provide appropriate feedback to your questions and requests, and/or to fulfill the necessary steps to conclude an agreement with you;

(2) To provide our services, specifically to create/update and personalize your account, enabling accessibility features, process payments, perform the necessary operations to deliver and maintain our services, support requests and any other inquiries about our Services, send notifications about changes to our Services and provide information that is relevant to the use of the Services and take the necessary steps to conclude an agreement with you, when applicable;

(3) To allow the provision of the Services of a third party, when you request this Service.

And also:

(4) To develop, improve the performance of, and secure our Services;

(5) To determine the effectiveness of our promotional campaigns, so that we can better tailor these campaigns to your interests;

(6) For analytics, statistical, development and research purposes, including providing our business partners and affiliates with aggregated statistical data.

3.2 All this based on our legitimate interest to provide you with a better experience and product and fine tune our offers to your needs. Moreover we may process your personal data:

(7) To comply with legal obligations and judicial enforcement and administrative orders, that we or our customers are or may be subject to under any applicable law;

(8) To protect and enforce our rights, our privacy and security, as well as our safety, systems and property, or those of other persons we are responsible for, and to resolve disputes;

(9) To verify your identity during onboarding as part of our KYC (Know-Your-Customer) checks, to authenticate you as an authorised user of the Services, or to detect and prevent possible frauds;

(10) To perform audits and (internal) checks aimed at verifying that our internal processes are indeed operated in compliance with applicable legal, contractual and regulatory requirements;

(11) To use the unique serial number of your mobile device to match you with your wallet.

(12) To send you important notices promptly, such as software updates and changes to the Service Agreement and this Policy.

(13) In accordance with GlobalForce User Agreement, this Privacy Policy and our Terms and conditions and other associated documents, we will use user information to manage and handle user activities.

(14)To meet legal and regulatory requirements and cooperate with regulatory agencies.

3.3 Moreover, we engage in notifications and promotional communications, (marketing): subject to your approval, we may send you notifications, either via email/SMS notification and web notifications or via WhatsApp - messages and other promotional updates about new features, offerings, events and special opportunities or any other information we think our customers and users will find valuable.

IV. Your consent when requested by applicable law

4.1 Some non-EEA legislations, require your consent in order for us to process the personal data. Where and when this is the case, please consider that by accessing, viewing and using the websites you consent to the processing of Personal Information as described in this Privacy Notice. You have the right to withdraw your consent at any time, which will not affect the lawfulness of the processing until that time.

V. To whom we disclose your personal data

5.1 We may disclose certain personal data to the following recipients to the extent required or permitted by applicable law and/or based on our legal interests. More specifically:

(1) Affiliate entities which are a part of the same group of companies, that are involved in operating business activities or providing our services, also for support and technical maintenance purposes;

(2) Third party vendors providing services to us, to facilitate or evaluate our services, such as: ITSM, CRM, ERP, billing and other systems required for administrating STC business processes, legal advisers, accountants, suppliers of payment services;

(3) Various public authorities, if and exclusively when this is strictly necessary to fulfill our legal obligations and/or to respond to law enforcement orders and requests;

(4) Other third parties to enforce our Terms and Conditions and protect our rights, privacy and our properties;

(5) In the event that STC goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal data may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations.

5.2 Where we use WhatsApp or Telegram as a mean of communication for our communications with customers, we will share your Personal data with this provider.

Please consider that the Privacy Notice of WhatsApp will apply to this processing activities, we recommend you to get acquainted with it at:

https://www.whatsapp.com/legal/privacy-policy and

5.3 Upon having obtained your consent, we may share your Personal data with third parties - marketing and analytics vendors, which analyze the activities of our webpage Users, (such as Google LLC providing Google Analytics service).

5.4 We will never use your data other than described in this Policy except with your prior consent.

5.5 You acknowledge that neither you nor we have control over whether your transaction records are made public or not. As the blockchain trading system is open source, your transaction records are publicly available in the entire blockchain system.

VI. We may share or transfer your information

6.1 Personal information collected and generated by us in the People's Republic of China will be stored on servers in the aforementioned country. If we do need to transfer your personal information outside of China, we will obtain your approval beforehand and conduct cross-border data transmission in compliance with applicable laws, regulations, and policies, and fulfill the obligation of confidentiality for your personal information.

6.2 We will not share or transfer your personal information to any third party without your prior consent, except for the following circumstances:

(1) We have obtained explicit prior consent or approval from you;

(2) The personal information collected is disclosed by yourself to the public;

(3) The personal information is collected from lawfully and publicly disclosed sources, such as lawful news reports and disclosure channels of government information;

(4) We only share the necessary user information with our related parties, which is subject to the purposes stated in this Policy;

(5) The information is provided in accordance with applicable laws, regulations or legal process, or as required by administrative or judicial authorities;

(6) In the event of a merger or acquisition involving the transfer of personal information, we will require the recipient to continue to abide by this Policy.

VII. Data transfer

7.1 We store your Personal data in Data Centers in the European Union and Switzerland. However, we do operate globally and may process and transfer your personal data to other Companies of the same Group worldwide, or to third parties around the world, for the purposes described in this Notice and specifically to ensure we can materially fulfill our agreement with you and/or answer to your requests, or – when applicable – upon your consent.

7.2 When we transfer your personal data outside the EU, EEA or Switzerland, we are fully committed to ensure the safeguard and the protection of your personal data, this includes implementing appropriate measures in this regard, including:

(1) adopting Standard Contractual Clauses adopted by the European Commission (and their approved equivalent for Switzerland and the UK), or other safeguard mechanisms;

(2) securing personal data when in transit;

(3) implementing internal policies to limit access to personal data and ensure awareness;

7.3 For an overview on the level of data protection in each country, please see https://www.cnil.fr/en/data-protection-around-the-world.

VIII. Retention of your personal data

8.1 We retain your Personal data only for as long as it is necessary to fulfil the scopes described in this Policy. The exact length of time may vary depending on the type of data, the scope of the processing, the category of users involved and -most importantly- whether we are compelled to retain certain Personal Data due to - most frequently and as an example - tax requirements or other legal requirements under applicable law, fraud prevention or safety. When we process the partially obscured copies of your ID, we retain it for a maximum of 18 months, in order to maintain the necessary records for our yearly audits.

8.2 Please consider that non-Personal data may be retained and used by STC without limitation in particular for archiving purposes, public interest, statistical, historical or scientifical research purposes. Also remind that your personal information such as your mobile device information, action history, transaction history, wallet address, etc. will be stored on the blockchain permanently.

IX. Cookies

9.1 We use cookies and similar tracking technologies to track the activity on the Website and store certain information. Cookies – when not necessary for the functioning of the websites- are collected and stored upon your consent. For more information on how we use cookies and which cookies we utilize, please see our Cookie Policy.

9.2 What cookies are and why STC and Global Force uses them?

9.3 Types of cookies we use STC uses the following types of cookies:

9.4 How long cookies are stored on your device?

STC uses session cookies to provide a comfortable user experience on the Services.

For example, the file yс_session memorizes your authorization on the Services, so that when you switch to another domain within the Services, you do not need to go through the authorization process again. Session cookies expire at the end of each session when you close the page or browser window.

STC may also use cookies that stored for a longer period, for example, to remember your preferences on the Services, such as language or location. How long collected data will be stored on your device depends on the type of cookies, which are automatically removed from your system as soon as their task is performed.

STC uses information contained in cookies only according to the terms and during the period specified in this Policy and the Privacy Policy.

9.5 How to manage cookies?

9.6 Who else can access cookies information?

Information collected through cookies is stored in accordance with applicable law and provisions of our Privacy Policy. STC partners may also collect information about users on the Services using cookies, tags and pixels in the course your usage of the Services. The use of cookies and other technologies allows STC and its partners to analyze the use of the Services, to count the number of visits, and to display ads tailored to the Services.

9.7 Third party services.

Certain Services on the Website are managed by third parties. It is possible that these parties use information about your online activity, among others in order to provide advertisements for products and services which may interest you. Without derogation to the foregoing, you please be aware your activity on the Website may enable third parties, such as online search engines, to rely on the nature of your activity, in order to present to you adapted advertisements in the framework of your online activities. The activity of these third parties is subject to the privacy policy used by them alone, and is done in their full and exclusive responsibility, without STC having any responsibility whatsoever for it. Please consult the privacy policies of these third parties.

X. Security:

10.1 STC has a team dedicated to ensuring the security of your personal data. We have implemented technical, administrative and physical security measures meant to protect the personal data we process, and we make a point of making sure that these measures are always state-of-the -art and are adequately tested by us.

10.2 How we protect your information:

(1) If we cease operations, we will stop collecting your personal information in a prompt manner, announce our cessation of operations on GlobalForce, and delete or anonymize the personal information we keep about you within a reasonable period of time.

(2) In order to protect your personal information, we will take data-security-related technical measures, improve our compliance by training employees about information security, and set data permissions to protect your private information.

(3) We will send you messages about information security in "Message Center" on GlobalForce and update "Help Center" from time to time for your reference on wallet usage and information protection.

XI. Children

Our websites and/or services are not intended for use under the age of 18.

We do not knowingly process Personal data from anyone under the age of 18. If you are a parent or guardian of someone under that age limit, you may contact us in order to exercise their rights on their behalf as detailed in this Privacy Notice.

XII. Specific jurisdictions

We provide additional information about the processing of your data to our visitors located in some specific jurisdictions:

12.1 US: The information contained under paragraphs 2 and 3 are meant to provide the necessary disclosures and to serve as a Notice at Collection under the California Privacy Rights Act, as are required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act, Delaware Privacy Act: Your Rights: You may have certain data rights under state privacy laws, including to request information about the collection of your personal information, to access your personal information in a portable format, and to correct or delete your personal information. If you wish to exercise any of your rights please contact our Privacy Office at privacy@swisstechcapital.com. Additionally, you have the right to appeal a possible denial of any of these rights by submitting a form that will be provided to you in case of such a denial.

To ensure the security of your STC/Global Force account, we will generally ask you to verify your request using the contact information you have already provided. If you are an authorized agent making a request on behalf of a consumer pursuant to applicable state law, we may ask you to provide information verifying you have proper authority to make the request on behalf of the consumer or we may ask the consumer to verify their identity with us directly.

We will verify your identity and provide you with an answer within 4 weeks. Please consider that we may need to request additional Personal data to verify your identity and protect us against fraudulent requests. If you perform your request through an authorized agent, we will need a power of attorney or a written permission for you authorizing the agent to perform the request on your behalf.

You have the right to be free from unlawful discrimination or retaliation for exercising your rights.

We do not sell your personal data (included your personal information) and not engage in profiling.

12.2 Canada: Your rights:

(1) you may request copies of your personal information and information about how it is processed;

(2) you may request that inaccurate personal information is corrected;

(3) you may request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements; and

(4) you may lodge a complaint about the manner we process your personal information. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time. You can exercise your rights by contacting us at: privacy@swisstechcapital.com.

XIII. Your Rights

As STC is subject to the General Data Protection Regulation (GDPR), all our visitors and website users, notwithstanding their location, enjoy the following rights:

(1) The right to request STC to provide you access to, correct or delete your Personal data;

(2) The right to request to restrict how STC processes your Personal data

(3) The right to object to such processing and to withdraw the consent you previously provided.

(4) The right to request that STC provides you with a machine-readable copy of your Personal data and not to be subject to automated decisions. Moreover, you can make a complaint to the supervisory authority of your place of residence. Please see: for the EU – https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.html

XIV. Updates

Our business is constantly developing and changing and our Privacy Notice may also change. We may update this Privacy Notice from time to time and publish a new version on our websites. We recommend you keep an eye on possible updates. If we plan any material changes, we will – of course – inform you.

XV. Questions?

If you have any query or question about this Privacy Notice or about the manner we process Personal data, please contact our Office at Swiss Tech Capital, Bann 7, 6312 Steinhausen, Kanton Zug, Switzerland privacy@swisstechcapital.com. Publication date: July 25th, 2024

Anti-Money Laundering Policy

1. Introduction

Swiss Tech Capital AG is committed to combating money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy outlines the company's framework to identify, mitigate, and manage the risks associated with money laundering and terrorist financing. Swiss Tech Capital AG recognizes the importance of adhering to legal and regulatory obligations to prevent the misuse of its services.

2. Purpose

The purpose of this Policy is to establish a comprehensive approach to detect, deter, and report money laundering and terrorist financing activities. This Policy aims to protect Swiss Tech Capital AG's reputation, ensure regulatory compliance, and safeguard the integrity of the financial system.

3. Scope

This Policy applies to all employees, directors, officers, consultants, agents, and any other individuals or entities associated with Swiss Tech Capital AG. This includes all business units, branches, and subsidiaries of Swiss Tech Capital AG, both domestic and international.

4. Definition of Money Laundering

Money laundering is the process by which individuals or entities attempt to conceal the origins of illegally obtained funds. The process typically involves three stages:

1. Placement: Introducing illicit funds into the financial system.

2. Layering: Engaging in a series of complex transactions to obscure the origin.

3. Integration: Reintroducing the laundered funds into the economy as legitimate money.

5. AML Compliance Program

Swiss Tech Capital AG will maintain an AML Compliance Program that includes:

1. A designated AML Compliance Officer: Swiss Tech Capital AG will appoint a qualified AML Compliance Officer responsible for overseeing the implementation and updating of this Policy.

2. Internal controls: Swiss Tech Capital AG will establish robust internal controls to ensure the effective de-tection and prevention of money laundering.

3. Policies and procedures: Swiss Tech Capital AG will develop and implement detailed procedures consistent with this Policy.

4. Regular training: Swiss Tech Capital AG will provide ongoing training to employees to ensure awareness and understanding of AML regulations and company policies.

6. Risk-Based Approach

Swiss Tech Capital AG will employ a risk-based approach to AML compliance by:

1. Conducting a risk assessment: Swiss Tech Capital AG will regularly conduct comprehensive risk assessments to iden-tify the level of exposure to money laundering threats.

2. Applying due diligence measures: Swiss Tech Capital AG will tailor due diligence measures according to the risk profile of each customer.

3. Implementing enhanced measures: Where higher-risk customers or transactions are identified, Swiss Tech Capital AG will employ enhanced monitoring and additional verification procedures.

7. Customer Due Diligence (CDD)

Swiss Tech Capital AG will ensure thorough Customer Due Diligence (CDD) by:

1. Identifying and verifying customers: Swiss Tech Capital AG will obtain sufficient information to establish the identity of cus-tomers depending on their risk profil, including individuals and entities.

2. Understanding the nature of the business relationship: Swiss Tech Capital AG will gather information about the purpose and intended nature of the business relationship.

3. Ongoing review: Swiss Tech Capital AG will conduct regular reviews of existing customers’ information to ensure it remains current and accurate.

4. Enhanced Due Diligence (EDD): For high-risk customers, Swiss Tech Capital AG will perform Enhanced Due Diligence (EDD), including verifying the source of funds and obtaining senior management ap-proval.

8. Ongoing Monitoring

Swiss Tech Capital AG will implement processes for ongoing monitoring of transactions and accounts by:

1. Systematic review: Swiss Tech Capital AG will utilize automated systems and manual processes to monitor customer transactions continuously.

2. Red-flag indicators: Swiss Tech Capital AG will establish and update red-flag indicators to identify unusual or suspicious activities.

3. Review and escalation: Swiss Tech Capital AG will ensure that any unusual transactions are reviewed in ac-cordance with internal policies and, where necessary, escalated to the AML Compli-ance Officer.

9. Suspicious Activity Reporting

Swiss Tech Capital AG will ensure proper reporting of suspicious activities by:

1. Internal reporting: Swiss Tech Capital AG requires employees to report any suspicious activities to the AML Compliance Officer immediately.

2. External reporting: The AML Compliance Officer will evaluate reports and, if deemed necessary, file Suspi-cious Activity Reports (SARs) with the relevant regulatory authorities.

3. Confidentiality: Swiss Tech Capital AG will maintain the confidentiality of Suspicious Activity Reports (SARs) and ensure information is shared only with those who need to know.

10. Record-Keeping

Swiss Tech Capital AG will maintain comprehensive records by:

1. Retention period: Swiss Tech Capital AG will store all transaction records permanently in the Blockchain Global Force. customer identification, and due diligence documents for a minimum peri-od required by law.

2. Accessibility: Records will be organized and accessible for prompt retrieval upon request by regula-tory authorities.

3. Secure storage: Swiss Tech Capital AG will ensure all records are securely stored to prevent unauthor-ized access and tampering.

11. Training and Awareness

Swiss Tech Capital AG will provide continuous Anti-Money Laundering (AML) education by:

1. Regular training programs: Swiss Tech Capital AG will conduct mandatory training sessions for all employees to familiarize them with Anti-Money Laundering (AML) laws, typologies, and company poli-cies.

2. Specialized training: Relevant departments will receive specialized training appropriate to their function and level of exposure to Anti-Money Laundering (AML) risks.

3. Training records: Swiss Tech Capital AG will maintain records of all Anti-Money Laundering (AML) train-ing sessions, including attendance and the content covered.

12. Independent Audit and Review

Swiss Tech Capital AG will ensure evaluations through:

1. Internal audits: Swiss Tech Capital AG will regularly perform internal audits to assess the effectiveness of its Anti-Money Laundering (AMLy9 program and identify any areas needing im-provement.

2. Independent reviews: Swiss Tech Capital AG will engage external auditors or consultants to conduct inde-pendent reviews of the Anti-Money Laundering (AML) program on a periodic basis.

3. Audit findings: Swiss Tech Capital AG will promptly address any deficiencies identified in audits and implement corrective actions.

13. Responsibilities

Swiss Tech Capital AG will define clear responsibilities by:

1. Management: Senior management at Swiss Tech Capital AG is responsible for supporting and ensur-ing compliance with this Policy.

2. AML Compliance Officer: The AML Compliance Officer will oversee the Anti-Money Laundering (AML) program, provide guidance to employees, and act as the primary liaison with regulatory bodies.

3. Employees: All employees of Swiss Tech Capital AG must adhere to this Policy and report any sus-picious activity to the Anti-Money Laundering (AML) Compliance Officer.

14. Disciplinary Actions

Swiss Tech Capital AG will enforce compliance through:

1. Accountability: Swiss Tech Capital AG will hold employees accountable for non-compliance with Anti-Money Laundering (AML) policies and procedures.

2. Consequences: Any failure to comply with this Policy, whether due to negligence or deliberate action, may result in disciplinary actions, including termination.

3. Whistleblower protection: Swiss Tech Capital AG will support employees who report suspicious activities in good faith.

15. Regulatory Reporting and Cooperation

Swiss Tech Capital AG will comply with legal requirements by:

1. Regulatory reporting: Swiss Tech Capital AG will submit all required Anti-Money Laundering (AML) related re-ports to regulatory authorities in a timely and accurate manner according to Swiss Law.

2. Cooperation: Swiss Tech Capital AG will cooperate fully with law enforcement agencies and regulato-ry bodies in Anti-Money Laundering (AML) investigations and inquiries according to Swiss Law. If necessary Swiss Tech Capital AG will block accounts by the decision of Swiss Court or the order of Swiss law enforcement agencies.

3. Information sharing: Swiss Tech Capital AG may share information with other financial institutions where ap-propriate and permitted by Swiss law to enhance its Anti-Money Laundering (AML) ef-forts.

4. Blocking of the account by the decision of the Court or the order of law enforcement agencies.

16. Policy Review and Updates

Swiss Tech Capital AG will ensure this Policy remains current by:

1. Regular review: The Anti-Money Laundering (AML) Compliance Officer will review this Policy annually or whenever there are significant changes in legal requirements or the company’s opera-tional environment.

2. Updates: Swiss Tech Capital AG will update the Policy to reflect any changes in Anti-Money Laundering (AML) laws, regulations, and best practices.

3. Communication: Any amendments to this Policy will be communicated to all relevant stakeholders within Swiss Tech Capital AG.