KYC Data Policy

KYC Records Data Privacy Policy

Introduction

This data privacy policy explains how Altcoinomy SA (“Altcoinomy” or the “Company”) collects and processes personal data in the context of the provision of our services with respect to the KYC-Records (“KYC-Records”). It also provides information about the data subjects rights and about how the data subject can contact us in the event of questions about how we handle the corresponding data in said context.

Contact


All contact addresses can be found at https://alt.co. If you have any questions regarding data protection, please do not hesitate to contact us:
Altcoinomy SA
Place des Florentins 1
1204 Geneva

Phone Number: + 41 22 707 73 99
E-Mail Address: hello@alt.co

Personal Data and the Performance of Clients Services

 

Our clients engage us on a wide range of matters including drafting of KYC for the opening of bank accounts, crypto to fiat, fiat to crypto, crypto to crypto conversions, token project fundraising, paymastering services, to name a few, by conducting due diligence and other screening activities to facilitate their onboarding. Effectively, our clients engage us to fulfill specific legal or regulatory obligations and risk management procedures carried out in the public interest, in particular Swiss, EU or EU-member state anti-money laundering regulations [inter alia GAFI, Swiss AMLA]. Altcoinomy  has a legitimate interest in processing data to support its clients in these objectives provided that the privacy rights of any data subject are not unduly affected.

In connection with our services and to maintain the KYC-Records, we collect various types of personal data from the data subject as well as from public records and registers including sanction and watch lists, online and print media, and the internet.

The personal data we collect and process in the performance of services for and on behalf of our clients includes but is not limited to any information relating to a living individual in which the individual is identified or identifiable, for example, the individual’s name, gender, date of birth, contact information, as well as, where necessary, data concerning criminal convictions and offences, etc.

We collect and process data in accordance with the purposes specified in this notice, namely to provide or perform the services requested by clients and individuals. This takes place on the basis of our legitimate business interests in conducting and managing our business as well as on the basis of obligations provided by laws, current national and international regulations which our clients are subject to.

Legal Background for the Collection of KYC Records

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  • Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector [Money Laundering Act, AMLA; SR 955.0] of 10 October 1997 (as at 18 February 2020) 
  • Ordinance on Combating Money Laundering and Terrorist Financing, [MLO; SR 955.01] of 11 November 2015 (as at 1 January 2020) 
  • Ordinance of the Swiss Financial Market Supervisory Authority on Combating Money Laundering and Terrorist Financing in the Financial Sector [FINMA Money Laundering Ordinance, MLO-FINMA; SR 955.033.0], dated 3 June 2015 (status as at 1 January 2020)
  • Agreement on the Swiss Banks’ Code of Conduct on Due Diligence [CDB 20] between the Swiss Bankers Association (“SBA”) on the one hand and the signatory banks (“banks”) on the other hand of 13 June 2018 
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  • International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation – the FATF Recommendations, February 2012, as amended June 2019 
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  • Federal Act on the Enforcement of International Sanctions [Embargo Act, EmbG, SR 946.231] of 22 March 2002 (Status as of 1 August 2004)
  • FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22), June 2013

Source for KYC Records

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  • Sanction lists/terrorist lists (Art. 22a GWG): Sanctioned persons and organisations are compared daily with the KYC-Records from the relevant websites, such as World Check. 
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  • Politically exposed persons (PEP): PEPs are checked via relevant websites such as World Check.

Minimum KYC Data

The below is the minimum data that the Company collects:

Individuals

  • – First Name & Last Name
  • – Date of Birth 
  • – Residential Address 
  • – Citizenship 
  • – ID (Passport & other national ID)
  • – Any Additional information, not limited to origin and tracing of funds

Corporates

  • – Certificate of Incorporation
  • – Articles of Association
  • – Certificate of Good Standing or Incumbency
  • – Identity documents & Proof of Address for all signatories & beneficial owners equal to or more than 25%
  • – Any additional information, not limited to origin and tracing of funds


How is Data Processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and hence in compliance with applicable law. We permit only authorised Altcoinomy employees to have access to your information. Such employees are appropriately designated and trained to process data only according to the instructions we provide them.

Storage of Personal Data

The Company will retain personal data, taking into account the respective source of the data, the relevance thereof with respect to the purposes of the processing, our legitimate business needs to capture and retain such information as well as obligations provided by laws, current national and international regulations which our clients are subject to.

Data Subject’s Rights

The data subject has the right to information, correction, limitation of data processing, deletion of personal data (Reserve Exceptions pursuant to Art. 17 para. 3 DSGVO), objection under data protection law for the future and data transferability within the framework of the respectively applicable data protection law and to the extent provided for therein. The data subject may file a corresponding request through our website or using the above contact details.

In addition, the data subject has the right to assert its claims in court or to file a complaint with the responsible data protection authority. Switzerland’s competent data protection authority is the Federal Data Protection and Information Commissioner.

The Company reserves the right to request from the data subject appropriate proof of identity (such as copy of data subject’s ID or passport) prior to granting the rights set out above.

Amendments to this Privacy Statement

We reserve the right to change this Data privacy Policy at any time without notice. We will notify you of any changes by posting the updated Data privacy Policy on our website. Any changes we make will be effective from the date we post them on our website.

 

Altcoinomy SA, August 2021