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Privacy Policy Effective Date: 10/22 2025

A legal disclaimer, AquaCredit Platform Privacy Policy

This Privacy Policy describes how [Insert Legal Entity Name of GreenChain/AquaCredit] ("AquaCredit," "we," "us," or "our") collects, uses, processes, and shares personal data when you visit our website, use our audience-specific portals (Investor, Regulator, ESG/Corporate, Developer), and participate in our strategic token pre-sale (Token Generation Event or "TGE").

We are committed to protecting your privacy and ensuring the security of your personal information, especially given our focus on regulatory alignment (MiCA, KYC/AML).

1. Information We Collect

We collect information directly from you when you interact with our website and automatically when you browse our services. The type of information collected depends on your interaction with the platform.

A. Information You Provide Directly

This data is collected when you use contact forms, subscribe to our newsletter, or register for our strategic portals.

  • Contact Data: Name, email address, company name, job title, phone number, and any messages or inquiries you send us.

  • Newsletter Data: Email address and subscription preferences.

  • Portal Registration Data: Credentials (username, password/hash) to access gated content for Investors, Regulators, or Developers.

B. Strategic Pre-Sale and Compliance Data (KYC/AML)

This highly sensitive data is only collected if you proceed to securing a strategic token allocation (Pre-Sale/SAFT) as part of our rigorous Know-Your-Customer (KYC) and Anti-Money Laundering (AML) obligations.

  • Identity Data: Full legal name, date of birth, nationality, physical address, and copies of government-issued identification (e.g., passport, driver's license).

  • Financial Data: Wallet addresses (to receive ACT tokens), source of funds documentation, and corporate registration documents (for institutional investors).

  • Corporate Data: Legal entity name, place of incorporation, tax ID, and details about the beneficial owners.

C. Information Collected Automatically

When you visit our website, we automatically collect certain information:

  • Usage Data: Details about how you use our site, including pages viewed, links clicked, time spent on pages, and referring URLs.

  • Technical Data: Internet Protocol (IP) address, browser type and version, operating system, and device identifiers.

2. How We Use Your Information

We use the information we collect for the following purposes, based on a specific legal basis:

Purpose of ProcessingLegal Basis for Processing

KYC/AML Compliance & TGE ParticipationLegal Obligation: To verify identities, adhere to global anti-money laundering regulations, and screen for sanctions/PEPs.

Service FulfillmentContractual Necessity: To provide access to portal features, respond to your inquiries, and fulfill our obligations under a Simple Agreement for Future Tokens (SAFT).

Scaling & Project AlignmentLegitimate Interest: To connect strategic investors with relevant project pipelines (e.g., funding a specific water treatment facility) to help scale the AquaCredit ecosystem.

Security and Fraud Prevention Legitimate Interest & Legal Obligation: To protect our website, prevent malicious activity, and ensure the integrity of the token sale.

Marketing and CommunicationsConsent: To send newsletters and updates about AquaCredit, new projects, and the token roadmap (where explicit consent is provided).

3. How We Share Your Information

We do not sell your personal data. We only share your data with trusted third parties under specific and necessary circumstances:

  • Compliance and Audit Partners: We share required KYC/AML data with our external legal counsel, audit firms (e.g., PwC), and specialized KYC/AML verification services to ensure regulatory adherence and due diligence.

  • Strategic Partners: We may share anonymized or aggregated data with our confirmed partners (e.g., UniCredit) for strategic planning and project scaling. Personally identifiable data is only shared with partners if explicitly required for the execution of a project funded by your investment and with prior notification.

  • Legal Authorities: We will disclose personal data when required by law, such as in response to a subpoena, court order, or governmental request (especially relating to money laundering or terrorist financing).

  • Service Providers: We use third-party services for website hosting, analytics, and email delivery. These providers are obligated to protect your data and only process it according to our instructions.

4. Data Security and Retention

Security: We implement technical and organizational measures, including encryption and secure network protocols, to protect your personal data from unauthorized access, disclosure, or destruction. Given the blockchain nature of our platform, data security is paramount.

Retention: We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements (especially in relation to long-term KYC/AML record-keeping, which can be up to 7-10 years post-transaction).

5. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

  • The Right to Access: Request a copy of the personal data we hold about you.

  • The Right to Correction (Rectification): Request that we correct any inaccurate or incomplete data.

  • The Right to Erasure: Request the deletion of your personal data, subject to our legal obligations (e.g., we cannot delete data required for KYC/AML compliance).

  • The Right to Object: Object to the processing of your data based on legitimate interest.

  • The Right to Withdraw Consent: Where we rely on your consent, you have the right to withdraw it at any time.

To exercise any of these rights, please contact us using the details provided below.

6. Contact Information and Policy Changes

Contact for Privacy Matters:

If you have questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer:

  • Email: info@aquacredit.com

  • Address: AD Astra Research AG. Zug
    Pilatusstrasse 3
    6300 Zug
    Switzerland (AquaCredit)

Changes to this Policy:

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on the AquaCredit website with a revised "Effective Date." We encourage you to review this policy periodically.

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