Privacy policy

Document version: v1Date: 25/9/2022

1. Introduction

In accordance with and to the extent of applicable data privacy laws, every person is entitled to the protection of his or her privacy against the misuse of personal data. We make every reasonable effort to protect any personal data against unauthorized access, data loss, data misuse, forgery, and similar. Nonetheless, we would like to point out that data transmission and storage can have security gaps. Complete protection of data is impossible. 

By using the website (, and/or the Axo Protocol (together the “Services”), you agree to the processing and use of personal data in accordance with this privacy policy (the “Privacy Policy”). If you do not agree with the terms of this Privacy Policy, you should immediately discontinue the use of the Services.

2. Changes to Privacy Policy

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon our posting of the revised Privacy Policy. For the avoidance of doubt, your continued use of the Services indicates your consent to the revised Privacy Policy then posted.

3. Processing of personal data

Personal data is all information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, irrespective of the means and procedures applied, in particular the retention, disclosure, acquisition, deletion, storage, modification, destruction, and use of personal data.

We process personal data in accordance with Swiss data protection law and – insofar and to the extent that the EU DSGVO is applicable – in accordance with the following legal principles relating to Art. 6 Para. 1 DSGVO:

  • lit. a) Processing of personal data with consent for the person concerned.

  • lit. b) Processing of personal data for the purpose of fulfilling a contract with the data subject and for the implementation of relating pre-contractual measures.

  • lit. c) Processing of personal data for the fulfillment of a legal obligation to which we are subject under any applicable law of the EU or any country in which the DSGVO is applicable in whole or in part.

  • lit. d) Processing of personal data to protect the vital interests of the data subject or of another natural person.

  • lit. f) Processing of personal data for the purpose of safeguarding the legitimate interests of us or of third parties, except where such interests are overridden by fundamental freedoms and rights or by the interests of the data subject. Legitimate interests include in particular our commercial interest in being able to provide our website, information security, the enforcement of our own legal claims and compliance with Swiss law.

4. Information Collection
A. Information You Provide

We may collect the following information about you when you use the Services:

  • Content, within any messages you send to us (such as feedback and questions to information support).

  • You may choose to voluntarily provide other information to us that we have not solicited from you, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically

Although at this time we do not automatically collect information from you when you access the Services, it is possible that we may in the future. We would utilize this information to operate and ensure the security, reliability, and robust performance of our Services.

We may also use tracking technologies to automatically collect information including the following

  • Log Files, which are files that record events that occur in connection with your use of the Services.

  • Log files are created when you view content or otherwise interact with the Services.

  • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We will only use strictly necessary cookies in connection with the website and Services. For the avoidance of doubt, the cookies that we include are essential for you to browse the Site and use its features, including accessing secure areas of the Site. You find more information about the use of cookies below.

5. Use of Information

We may collect and use personal data for business purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

Operating and managing the Services; performing services requested by you, such as responding to your comments, questions, and requests, and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; detecting, preventing, and addressing fraud, breach of Terms and Conditions, and threats, or harm; and compliance with legal and regulatory requirements.

Protecting the security and integrity of the Services; improving the Services and other websites, apps, products and services; conducting promotions, such as hack-a-thons, including verifying your eligibility and delivering prizes in connection with your entries; and fulfilling any other business purpose, with notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. 

6. Sharing and Disclosure of Information

We may employ third party companies ("Service Providers") to facilitate the operation of our Services, assist us in analysing how our website is used or related services, such as payment, delivery or IT infrastructure services. These Service Providers have access to your personal data only and insofar as necessary to perform these tasks on our behalf and are required to safeguard it in accordance with our contractual obligations and applicable data protection legislation.

We and our Service Providers may process your Personal Data outside of your home country. We take adequate measures such as contractual and technical measures to safeguard your data abroad. 

7. Cookies

This website uses cookies. A cookie is a small data file that is placed on your browser or your hardware to allow a website to recognize you when you return to it. This can either be for the duration of your visit (using a 'session cookie') or for repeat visits (a 'persistent cookie'). Cookies can be created through a variety of web-related protocols and technologies, such as HTTP (sometimes referred to as 'browser cookies'), HTML5, or Adobe Flash. If you don’t wish this to happen, you can adapt the settings of your internet browser to block or delete cookies. Please note that deleting or blocking cookies might prevent you from using all functions and features of this website. To find out more on how to manage and delete cookies, visit

8. Links to third-Party Apps or websites

This website may contain links to websites or apps that are not operated by us. If you click a third party link, you will be directed to that third party’s site or app. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

9. Analytics

On our website, we use Google Analytics, a web analysis service provided by Google Inc ("Google"). Cookies are stored on the user's computer, which enables an analysis of the use of the website by the user.

The information generated by the cookie about the visit to this website is usually transferred to a Google server in the USA and stored there. We use the service on our website with IP anonymisation activated. This means that after revision on our website, your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and thus anonymised. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on our behalf for the purpose of evaluating your visit to the website, compiling reports on website activity and providing other services relating to website activity and internet usage to us as the website operator.

The IP address transmitted by the user's browser as part of Google Analytics will not be merged with other Google data.

In addition, the forwarding of the data generated by the cookie and related to the use of the website (incl. the user's IP address) to Google as well as the processing of this data by Google can be prevented by downloading and installing the browser plugin available under the following link:

10. Data Security

We take reasonable technical and organizational security measures that we deem appropriate in order to protect your stored data against manipulation, loss, or unauthorized third-party access. Our security measures are continually adapted to technological developments.

We also take internal data privacy very seriously. Our employees and the service providers that we retain are required to maintain secrecy and to comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate.

The security of your personal data is important to us but remember that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. We recommend that you use antivirus software, a firewall, and other similar software to protect your system. Nevertheless, in the event of a data security incident occurring, we follow our internal procedure to respond to the incident and notify you as quickly as possible. 

11. Children

The Services are intended for general audiences and are not directed at children. To use the Services, you must legally be able to enter into the Agreement. We do not knowingly collect personal information from children. 

12. Data Protection Rights

You have the below data protection rights on the basis of the Swiss Federal Act on Data Protection and the EU DSGVO insofar as applicable. Please note that we may ask you to verify your identity before responding to such requests.

  • Right of access: You have a right to request a copy of your personal data, which we will provide to you in an electronic form.

  • Right to amendment: You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.

  • Right to withdraw consent: If you have provided your consent to the processing of your personal data, you have the right to withdraw your consent. This includes cases where you wish to opt out from marketing communications. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal basis for processing. To stop receiving emails from us, please click on the 'unsubscribe' link in the email you received.

  • Right to erasure: You have the right to request that we delete your personal data when it is no longer necessary for the purposes for which it was collected, or when it was unlawfully processed. Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any NFTs held by your wallet address.

  • Right to restriction of processing: You have the right to request the restriction of our processing of your personal data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial purpose, but where we are not able to delete it due to a legal obligation or because you do not want us to delete it.

  • Right to portability: You have the right to request that we transmit your personal data to another data controller in a common format such as Excel, where this is data which you have provided to us and where we are processing it on the legal basis of your consent or in order to perform our contractual obligations.

  • Right to object to processing: Where the legal basis for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have a compelling legal basis for the processing which overrides your interests, or if we need to continue to process the personal data for the exercise or defence of a legal claim.

  • Right to lodge a complaint with a supervisory authority: You have the right of appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction. 

To exercise any of these rights, please contact us via our email or postal address listed in the “Contact Us” section above and specify which right you are seeking to exercise. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

13. Contact Us

If you have any questions or comments about this Privacy Policy, please contact us via e-mail at
privacy [at] axo [dot] trade