Privacy Policy Notice

Smat ("Smat", also referred to as "us" or "we") cares about your privacy. We are committed to maintaining your trust by protecting your personal data in accordance with applicable law.This Privacy Policy Notice ("Notice") describes how Smat collects, uses, and discloses your personal data in connection with the use of our websites or other services or products that refers to or links to this Notice, as well as any offline services (collectively our "Services") we provide to you or via our partners and service providers.

Before you use our Services, please read this Notice in its entirety, which helps you make informed decisions about your relationship with us.

References to "you" in this Notice means anyone who uses our Services, websites, or applications.Smat may also collect non-personal data or may anonymize personal data in order to make it non-personal.

We may collect, store, use and transfer and disclose non-personal data for any purpose.Personal data we may collectSmat may collect and process data in relation to the data referred to below with respect to persons using our Services, Smat website. In addition to collecting personal data from its clients (also known as users), including potential clients, Smat may also process personal data about relevant persons using its Services, for instance third party agents or intermediaries acting on behalf of prospective or existing users or clients of user or related persons, their contractors, etc. We may collect these data from several sources, including directly from you, via our affiliates, delegates, partners, service providers, legal professional advisors, or third-party entities with whom we undertake verification upon you or publicly available sources for the purposes of providing our Services.Where relevant, we may collect and process personal data related to persons associated with you or with whom you have a legal relationship.

In such circumstances, it is your responsibility to ensure you have permission from that third party for us to collect their data and you remain responsible for ensuring that the third party understands how their data are being used.

In each case, Smat collects data only insofar as is necessary or appropriate to fulfill the purpose of the person’s interaction with it, in particular to provide its Services. A person can always refuse to supply personal data to Smat; such refusal may however prevent such person from engaging in certain related activities with Smat.

Personal data that we may collect and process includes:identification data, such as name(s), address(es), phone number(s), email address(es), business contact information, passport, identification card, tax identification;certain personal characteristics, such as your date of birth, or nationality;professional information, such as employment and job history, title(s)/function(s);wallet and related financial information, such as financial and credit history information, bank details (e.g. IBAN);transaction data (current and past transactions), number and value of token held, role in a transaction (seller/acquirer of shares), transaction details, wealth and tax details;user profile/login data, such as username(s) and password(s);technical data, such as Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access this website (see also "Our cookie policy" section below).

Are your data transferred outside of Switzerland?

Personal data may be transferred to countries outside Switzerland if this is required for the execution of of our contractual obligations, prescribed by law, necessary to safeguard an overriding public interest, or if you have given us your consent (see also "When we may disclose personal data" section below).to achieve our legitimate interests (such as for instance electronic communications between you and us, or our affiliates; the provision of information to you (e.g. product or product performance/rating related information), details in order for us to manage and improve our website, for us obtaining and recording details relating to your visit behavior on our website) but always by ensuring that (i) your rights and interests are taken into account, protected, and any privacy impact on you is as minimal as possible, (ii) we are able to demonstrate that your data are used in a proportionate manner in a such way that can be expected by you and you would not object of such use, and (iii) we may lawfully disclose personal data to third-parties where we can demonstrate that this disclosure is justified; where we need to perform a contract that we are about to enter into or have entered into with you (this includes where you have asked us to do something before entering into a contract, for example to provide a quote);to comply with our legal or regulatory obligations; based on reasons of substantial public interest; where your personal data are public information as a result of your activity or action; explicit consent when required in very limited circumstance.

Do we rely upon profiling or automated decision-making?

As a rule, we do not make decisions based solely on automated processing in order to perform our Services.

Should we do so, we shall comply with applicable legal and regulatory requirements.When we may disclose personal dataour affiliates, including relevant third-party such as custodian bank, interdealer broker, product issuer, rating providers; our partners and professional service providers, including for the purposes of conducting due diligence, including service providers appointed by the third-party referred to above; any law enforcement, court, regulator or other government authority in order for us to comply with a legal obligation laid down in relevant applicable regulation, such as Swiss law;a prospective buyer of our business, including where we intend to sell part of our business or merge with another third-party.

How and where we store your personal data?

We generally store your physically (where applicable) and electronically held personal data in our Swiss premises (where applicable) in secure locations and/or on secure servers in Switzerland. We may however host or transfer your personal data to our affiliates, partners, or service providers that are based outside of Switzerland or the European Economic Area. In such circumstances, we will ensure that your personal data are adequately protected in accordance with applicable data protection regulations.

We take all reasonable steps to protect your personal data; however, where you choose to transmit your personal data to us via the internet, we do not guarantee the security of the personal data transmitted and therefore any transmission is at your own risk. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website or any application or platform operated by Smat, you are responsible for keeping this password confidential and not sharing it with any unauthorized person.

Your rights as a data subjectWhere applicable, you may have certain rights under relevant data protection regulations including the right to ask Smat for a copy or update the personal data held about you as well as obtain supporting explanatory information, including in case of automated decision-making. In certain circumstances, you may ask Smat to make any necessary changes to your data to ensure such data are accurate and up to date, ask Smat to erase your personal data, or ask Smat to restrict the processing of the data, or to transfer data collected by Smat to other organizations, or directly to you, at your request.

You may aso have rights to object to some processing, and where we have asked for your consent to process your data, to withdraw your consent. Where Smat processes your data because it has a legitimate interest in doing so, you may also have the right to object to this. These rights may however be limited in some situations, such as for instance, where Smat can demonstrate that it has a legal requirement to process your data. Where applicable, you may have similar rights in your country under local legislation to access and correct/update your data. If you wish to exercise any of these rights, please contact us (see "How to contact Smat " section below).How long we retain your personal dataWe reserve the right to retain your personal data for as long as we reasonably believe it to be necessary in order to facilitate our legitimate interests, in order for us to comply with our legal or regulatory obligations, where based upon reasons of substantial public interest, or where your personal data remain public information by your own actions. Subject to applicable legal minimum retention periods, your personal data will not be retained for longer than necessary with regard to the purposes and compliance obligations contemplated in this Notice. For further information, you may contact us (see "How to contact us" section below).

Our cookie policy

Smat website uses cookies. Cookies are small text files that are permanently or temporarily stored on the computers of visitors when visiting our website. The purpose of the cookies is specifically to provide a statistical analysis of the use of our website in order to allow for improvements to be made. Smat website visitors and users can disable the use of cookies on our website, in whole or in part, in their browser’s cookie or privacy settings at any time. If cookies are disabled, however, website visitors and users may no longer be able to access all of our website’s functions.

Smat website uses Google Analytics services provided by Google Inc., a US company, and its subsidiaries (referred to together as "Google"). The purpose of these Google services is to provide a statistical analysis of the use of our website to allow us to improve the user browsing experience. The listed Google services use cookies, which enable us to record individual use of our website. All data relating to the Google services are transmitted to Google in the United States of America (USA) for analysis. If necessary, Google will transmit the data to third parties insofar as this is required by law or insofar as third parties process these data on behalf of Google. The IP addresses of our website visitors will also be sent to Google as part of the Google Analytics service. Website users can disable the use of cookies for the listed Google services on our website, in whole or in part, in their browser’s cookie or privacy settings at any time.

Alternatively, users can prevent their use of our website being analyzed via the "Google Analytics" service by downloading and installing the corresponding Google browser plugin available at This plugin installs an "opt-out cookie".

More information on data protection in connection with Google services can be found in the Google Privacy Policy at[1].

Changes to this Notice Smat may make changes to this Notice at any time and may do so without expressly notifying you of these changes. However, should the legal basis or purpose for processing your personal data changes then Smat will expressly notify you.

How to contact usQuestions or individual data requests relating to this Notice should be addressed to: Smat SA, Rue de l'Avenir 23, Delemont (2800)