This privacy policy sets out what personal data we, Gold Token SA (“GTSA”), collect, use, store and disclose when you sign up to our newsletter.

This privacy policy sets out what personal data we, Gold Token SA (“GTSA”), collect, use, store and disclose when you sign up to our newsletter.

1. Name and Address of the Controller

GTSA is the controller and responsible for your personal data within the meaning of the applicable data protection law, who determines the purposes and means of processing personal data. If you have any questions regarding data protection, please do not hesitate to contact us:

Gold Token SA Promenade de Saint-Antoine 10 c/o MKS (Switzerland) SA 1204 Genève

Our data protection coordinator can also be reached via the following contact details:

E-mail address: [email protected]

2. Scope and security of data processing

Data protection is of a particularly high priority for us. We only process personal data if this is necessary to provide a functional website as well as our contents and services. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from you.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

3. Provision of the Website and creation of log files

3. Provision of the Website and creation of log files

I. Description and scope of data processing

Every time you visit our Website, our system automatically collects following data and information from the computer system of the calling computer:

  • Information about the browser type and version used

  • The user’s operating system

  • The user’s IP address

  • The user’s country of access

  • Websites from which the user’s system reaches our Website

  • Page viewed on our Website

II. Purposes of data processing and legal basis

We process connection data on the basis of our legitimate interests: to deliver the Website to your device and keep it functioning, and to protect it against attacks and abuse. Our hosting provider, Framer, processes this data on our behalf; we do not have access to it.

We also use Framer’s built-in analytics to understand how the Website is used and to improve it. Framer hashes IP addresses and browser information with a key that changes and is deleted every day, in order to produce anonymous daily visitor statistics. It sets no cookies and creates no persistent identifiers. To the extent personal data is processed in generating those statistics, we rely on our legitimate interest in measuring and improving the Website. The statistics available to us are anonymous and aggregated; we do not build individual visitor profiles or use this data for marketing.

We have assessed these interests against your rights, taking into account the minimal data involved, its short retention and the fact that this processing is standard for any website, and concluded that they are not overridden. You may object or ask about this assessment at [email protected].

III. Period of storage

III. Period of storage

The personal data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the Website, the data will be deleted when the respective session has ended. If the personal data is stored, it will be deleted by or at the end of the day.

4. Newsletter

I. Description and scope of data processing

You can subscribe to a free newsletter on our Website.

When registering for the newsletter, the data from the input mask is transmitted to us. We only require your e-mail address when signing up to our newsletter and we do not require any additional personal data.

During the registration process, your consent is obtained for the processing of the data and reference is made to this privacy policy. You may withdraw your consent at any time.

II. Purpose of data processing and legal basis

II. Purpose of data processing and legal basis

The collection of the user’s e-mail address serves to send the newsletter. We process your personal data collected during registration for the newsletter based on your consent.

III. Period of storage

III. Period of storage

The data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s e-mail address will therefore be stored for as long as the subscription to the newsletter is active or until the user cancels their subscription to the newsletter.

IV. Possibility of objection and withdrawal

IV. Possibility of objection and withdrawal

The subscription to the newsletter can be cancelled by affected user at any time. For this purpose there is a corresponding link in every newsletter. This also enables the withdrawal of the consent to the storage of personal data collected during the registration process.

5. Contact form

I. Description and scope of data processing

There is a contact form on our Website which can be used for electronic contact. If a user takes advantage of this possibility, the following data entered in the contact form will be transmitted to us and will be stored:

  • Request type

  • First name and last name

  • Company (voluntary)

  • E-mail address

  • Message

At the time the message is sent, the following data is stored in addition:

  • The IP address of the user

  • Date and time of registration

Before sending the contact form we will refer to this privacy policy. In this context, the personal data will not be transmitted to third parties. The data is used exclusively for processing the conversation.

II. Purpose of data processing and legal basis

II. Purpose of data processing and legal basis

The processing of the personal data from the input mask serves us solely to process the establishment of contact. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems. This is also our legitimate interest in the processing of the data.

III. Period of storage

III. Period of storage

To offer a good user experience and to safeguard our ability to comply with our contractual obligations, we need to have access to all user communication. Consequently, the personal data from the contact form or the personal data that is sent by e-mail will only be collected and processed for as long as necessary for the purposes it was originally collected for, or you withdraw your consent.

IV. Possibility of objection and withdrawal

IV. Possibility of objection and withdrawal

If data in the contact form is not clearly marked as voluntary and the processing is not carried out on the basis of consent, we cannot provide our intended service if the consent for data processing is refused.

6. Who we share your data with

We may share your personal data where necessary with the parties set out below for the purposes as mentioned in this Privacy Policy.

  • Framer – To support us in developing our website and sending our newsletter to you if you have signed up for it.

We require third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions.

7. International transfers

We may transfer your personal data to providers that carry out certain functions on our behalf. This may involve transferring personal data outside Switzerland or the United Kingdom (UK) to countries which have laws that do not provide the same level of data protection as provided under Swiss law or the UK law.

Whenever we transfer your personal data to service providers based outside of Switzerland or the UK, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed by Switzerland and the UK to provide an adequate level of protection for personal data.

8. Rights of the data subject

You have the right to information, correction, limitation of data processing, deletion of personal data, objection, revocation of the declaration of consent under data protection law for the future and data transferability within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). In addition, you have the right to assert your claims in court or to file a complaint with the responsible data protection authority that you reside in. Switzerland’s competent data protection authority is the Federal Data Protection and Information Commissioner.

If you are a user residing in an EU member state, you have a right to raise a complaint to your local data protection supervisory authority.

If you are a resident in the United Kingdom you have a right to raise a complaint with us and you can do so by using the contact details at the top of this Privacy Policy. You also have a right to lodge a complaint with the Information Commissioner’s Office, the UK regulator for data protection issues (www.ico.org.uk).

9. Amendments to this Privacy Notice

We reserve the right to change this Privacy Notice at any time without notice. We will notify you of any changes by posting the updated Privacy Policy on our Website. If the Privacy Notice is part of an agreement with you, we will email you an updated Privacy Policy or otherwise provide you with appropriate information. Any changes we make will be effective from the date we post them on our Website.

This Privacy Policy was last updated on September 8, 2026.