Privacy Policy

TNG Identity Application - 18 June 2025


PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE TERANODE WEBSITE, THE TERANODE PRODUCT SUITE PLATFORM, AND ANY OTHER PRODUCTS OR SERVICES OFFERED BY TERANODE OR ITS GROUP.

LAST UPDATED: 13 MAY 2025


Introduction

This privacy policy ("Privacy Policy") applies to Teranode Switzerland AG with respect to information and data we collect, use and process in connection with your interest in and the use of our website https://teranode.group, the Teranode Product Suite Platform https://nchainplatform.com and any products or services available thereon from time to time (“Online Offerings”).

Teranode Switzerland AG is a private limited company, register in Switzerland under company number CHE-276.016.833 and is part of the Teranode group of companies. Teranode group of companies (“Group”) is made up of different legal entities, details of which can be found here: https://teranode.group/about-us/. This Privacy Policy is issued on behalf of the Group so when we mention “Teranode”, "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Group responsible for processing your data. To contact us, please email [email protected]. By using our Online Offerings, you confirm that you accept this Privacy Policy. If you do not agree to the Privacy Policy, you must not use our Online Offerings.


1. The types of personal data we process about you

In this Privacy Policy, "personal data" or "personal information" is data or information about or that relates to you as an identifiable individual. "Use" or "process" means any operation performed on information about you, including but not limited to collect, disclose, record, organise, structure, store, alter, use, transfer, destroy or otherwise make available.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier.

  • Contact Data includes address, e-mail address and phone number.

  • Financial Data includes bank account, digital wallet and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have used or purchased from us and details relating to your use of them.

  • Technical Data includes the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

  • Usage Data includes information about how you interact with and use our website, products and services, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Purchase and Enquiry History: Details of goods and services you have previously purchased, including what you bought, when you bought it, and how much you spent, as well as information about goods and services you have inquired about, even if you didn't purchase them. This might include products you've looked at or asked questions about.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Online Offerings to help improve the Online Offerings and our services.


2. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your personal data by visiting or using our Online Offerings, or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you

    • apply for or use our products or services;

    • create an account on our Online Offerings;

    • request marketing to be sent to you;

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our Online Offerings, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For more information about the cookies we use and how to change your cookie preferences, please see https://nchainplatform.com/cookie-notice.

  • Third parties or other sources. This is information we receive about you if you use any of the other websites we or our partners operate or the other services we provide or they provide. In order to provide you with our services we intend to share your data internally and combine it with data collected on our Online Offerings. We will receive such data only in order to provide our services and ascertain if our services will benefit you as set out in this Privacy Policy. We may also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers).

  • Technical Data. Technical data relating to your use of our Online Offerings is collected from analytics providers, such as Google Analytics and Sprig, which may be based outside the European Economic Area.


3. How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

Tailored Offers:

Using details of past purchases or inquiries to suggest other products or services that align with your interests.

Personalized Experience:

Customizing your experience on our Online Offerings based on your preferences and past interactions, aiming to enhance your satisfaction and engagement.

(a) Identity

(b) Contact

(c) Profile

(d) Purchase and Enquiry History

(e) Usage

(f) Transaction

Necessary for our legitimate interests

In this case, the legitimate business purpose is providing more tailored offers and personalizing your experience on our Online Offerings. By analysing your past purchases or inquiries, the business aims to enhance your experience and engagement by offering relevant suggestions.

To process and deliver your orders, including management of payments and collection of monies owed to us

(a) Identity

(b) Contact

(c) Purchase and Enquiry History

(d) Usage

(e) Transaction

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to recover debts due to us and ensure we are delivering you the correct products and services on the agreed terms)

To manage our relationship with you which will include:

(a) Notifying you about relevant changes

(b) Dealing with your requests, complaints and queries

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Usage

(f) Transaction

(g) Purchase and Enquiry History

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and manage our relationship with you

To administer our Online Offerings and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes as may be required to ensure our Online Offerings and internal systems are functioning properly.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

Necessary for our legitimate interests

Legitimate interests include ensuring the proper functioning of our Online Offerings, improving user experience, and ensuring the security of the website and its systems.

To scrutinize information on your recent visits to our Online Offerings to assess and evaluate the usage and performance of our Online Offerings and internal systems to evaluate, optimize, improve and enhance our users’ experience.

(a) Technical

(b) Usage

Necessary for our legitimate interests

In this case, the legitimate interest is to assess and evaluate the usage and performance of the website to improve and enhance the user experience. This includes optimizing website performance, identifying and fixing technical issues, and tailoring the website to better meet user needs.

To keep our Online Offerings and internal systems safe and secure and to respond to incidents.

(a) Usage

(b) Technical

Necessary for our legitimate interests

Ensuring the security of our Online Offerings and internal systems is a legitimate interest, as it protects the organization and its users from potential harm, such as unauthorized access, data breaches, or cyberattacks. This processing includes implementing security measures, monitoring for security threats, and responding to security incidents.

To measure, analyse and comprehend the effectiveness of any advertising we may serve to you and others, to track the effectiveness of our marketing and online advertising.

(a) Technical

(b) Usage

(c) Profile

Necessary for our legitimate interests

In this case, measuring and analysing the effectiveness of advertising and tracking marketing efforts is a legitimate interest, as it helps improve the efficiency of advertising campaigns and optimize marketing strategies.

To provide information on events, publications, products, or services that may interest you.

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(e) Usage

(f) Purchase and Enquiry History

Consent

When you sign up to attend an event, access publications, or receive marketing materials, you are providing consent for us to collect and use your personal data for these specified purposes. We may use the information we collect to provide you with information on events, publications, products or services that we feel may interest you.

We may combine information you give to us with any information we collect about you and/or information we receive from other sources and use it in the ways set out above (depending on the types of information we receive) where this is necessary for our legitimate business purposes in providing you with a better and more tailored experience.

Direct marketing

When you sign up for our newsletter on our website, you will have the option to indicate your preferences for receiving direct marketing communications from us. By signing up, you consent to receive our newsletter and related marketing communications via email or other means of communication indicated in the consent.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view about which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Opting out of marketing

If you have already agreed to receive marketing communications from us but have now changed your mind, you can easily unsubscribe at any time by following the instructions (such as to click an “Unsubscribe” link in emails) included in these marketing communications.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.


4. Disclosures of your personal data

4.1. We may share your personal information with:

  • Any member of our Group, which means our affiliates and subsidiaries, our ultimate holding company and its subsidiaries and affiliates.

  • Selected third parties including business partners, licensees, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

  • Selected third parties who may use this information to send you details of products and services that may interest you (provided you have consented to this).

  • Analytics that assist us in the improvement and optimisation of our Online Offerings.

4.2. We may also disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your relevant personal data to the prospective seller or buyer of such business or assets.

  • If we, or substantially all of our assets are acquired by a third party, in which case personal data held by us about its customers may be one of the transferred assets.

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms or to protect the rights, property, or safety of our company, our customers, licensees, business partners, affiliates, subsidiaries, or others.


5. Transfer of personal data

The personal data that we collect may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be processed by staff outside the EEA who work for us or for one of our suppliers engaged in the processing of your personal details. We will take all reasonable and necessary steps to ensure your personal data is treated securely and in accordance with this Privacy Policy and applicable data protection laws, and will not transfer personal data outside the EEA unless an appropriate safeguard is implemented, such as entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the data. Please note that unfortunately the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee its security once transmitted to our Online Offerings; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


6. Data security

We shall use reasonable commercial efforts to maintain the appropriate security and technical measures to prevent the loss, use or unauthorized access to your personal data. You acknowledge and agree that no transmission of information via the internet is completely secure, and that no method of storage is completely secure and that the state of the technology prevents us from 100% guaranteeing your personal data’s security once transmitted to, or disclosed as part of your use of, our Online Offerings; any transmission is at your own risk.


7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period even after they cease being customers.

In some circumstances you can ask us to delete your data: see section 8 below for further information.


You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "subject access request"). This enables you to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal data, we may charge a reasonable administration fee.

  • Rectification. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Note that you can always make certain adjustments to certain personal information directly through your online account.

  • Deletion. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Objection. Object to processing of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see “Opting out of marketing” in section 3 for details of how to object to receiving direct marketing communications).

  • Portability. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due the need to establish, exercise or defend legal claims or any other legal or other obligation, or because you do not wish for us to delete it, or you have exercised the right to object and verification of the overriding grounds is pending.

  • Withdrawing Consent. Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 3 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can make any of these requests in relation to your personal data by sending the request by mail to [email protected].

Our Site may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to these websites, they have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


9. Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:


10. Complaints

You have the right to make a complaint at any time to the relevant local data protection authority if you believe that we have not complied with applicable data protection laws. In the UK that is the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are based or the issue you would like to complain about incidents that occurred in the European Economic Area (EEA), a list of local data protection authorities in the EEA countries can be found at www.edpb.europa.eu. In Switzerland that is the Federal Data Protection and Information Commissioner. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.


11. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Any changes we make to our Privacy Policy in the future will be posted on this page with immediate effect. Your continued use of our Online Offerings will constitute your acceptance of any changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

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