Last Updated: 13 November 2025
This Privacy Notice describes how we collect and use information about you when you register for and/or participate in the offering of the AZTEC Token (the “Token”) by the Aztec Foundation (the “Services”).
The Aztec Foundation (“Aztec Foundation”, “our, “us” or “we”) is a Swiss Stiftung incorporated and registered in Zug, Switzerland, with a registered office at Gartenstrasse 6, 6300 Zug, Switzerland, and we are the data controller for the processing of your information.
Please read this Privacy Notice carefully. By using any of the Services, you acknowledge having read and understood this Privacy Notice, and agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.
1. CHANGES TO THIS PRIVACY NOTICE
We may modify this Privacy Notice from time to time without prior notice, in which case we will update the “Last Updated” date at the top of this Privacy Notice. We will indicate on our Website when our Privacy Notice has been updated, including by updating the date of this Privacy Notice. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services or on our website(s) used for the provision of the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not access or continue to use the Services.
2. COLLECTION OF YOUR INFORMATION
When you use or access the Services, we collect certain categories of information about you from a variety of sources.
Information You Provide to Us
In order to provide the Services, we require certain information about yourself. You may elect not to provide this information, but doing so may prevent you from participating in the offering of the Tokens. You may provide some or all of the following information to us when you complete our sanctions and KYC/KYB checks and/or apply to purchase the Tokens:
Information for sanctions and KYC/KYB checks, such as full legal name, country of residence, current proof of residence, Ethereum wallet address, email address and other contact information, and where a legal entity is purchasing the Tokens, information about their ultimate beneficial owners or shareholders (including their full legal name, title/position, date of birth, nationality, current proof of address, copy of ID documents, and whether they are a political exposed person). The information described above will be collected and processed on our behalf by third-party service providers engaged to perform sanctions screening and KYC/KYB verification. These providers act as independent or authorized processors, as applicable, in accordance with applicable data protection laws.
Information that you share with us via ZKPassport, such as your name, passport or ID information, and confirmation that you are not subject to any sanctions.
Email address, if you choose to opt-in to future communications from us.
Ethereum wallet address that will receive the Tokens.
Any other information you choose to include in communications with us, for example, when sending a message to us via email.
Information We Collect Automatically
We also automatically collect certain information about your IP address and use of VPNs when we provide you with the Services. We use this information to determine the country in which you are located, to allow us to comply with sanctions requirements.
Information Collected From Other Sources
We may obtain information about you from outside sources, including information that we collect directly from third parties. Such information includes:
Results of KYC / KYB checks and sanctions information we receive from sanctions databases, government agencies, identity verification services, KYC / KYB providers (including ZKPassport and Predicate), and other third parties. Any information we obtain from third parties in connection with the provision of Services will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.
3. use of your information
We process your information in order to perform our contract with you, to:
Provide you the Services;
Allow you to participate in the sale of the Tokens; and
Communicate with you in connection with the token sale and related updates.
Additionally, we process information in our legitimate interests to:
Ensure the network and information security, including to protect our and your information from loss, damage, alteration, theft or unauthorized access;
Prevent fraud and illegal activity; and
Enforce our contractual arrangements and our policies, and to protect or defend the Services, our rights, the rights of our users, or others.
We also process your information to comply with applicable laws such as tax, accounting, sanctions, and anti-money laundering regulations.
4. DISCLOSURE OF YOUR INFORMATION
We disclose your information with thirds parties in certain circumstances, subject to this Privacy Notice, including:
With business partners and service providers. Such third parties include (i) data analytics vendors that assist us in the improvement and optimisation of the Services; (ii) security vendors; and (iii) website hosting vendors. These service providers assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you. We share this information to provide our Services to you and help maintain our business relationship, on the basis of our legitimate interests.
For legal and security reasons and to protect our Services and business, in our legitimate interests or as required by law. We will share your information with KYC/KYB providers, service providers that conduct blockchain analytics and wallet screening, regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
With our professional advisors, such as legal, tax, and accounting advisors
5. WHERE WE STORE YOUR INFORMATION
The information that we collect from you will be primarily stored and processed in Switzerland and the EEA. However, your personal information can be accessed from, transferred to, and/or stored and used in other countries (potentially outside the country in which you are located), by us and/or by our third party service providers or partners. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.
Any transfers of data outside Switzerland or the EEA (such as to the United States will be governed by appropriate safeguards, such as the European Commission’s standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer) and/or module two (controller to processor transfer), as relevant), as approved by the relevant supervisory authority, unless the data transfer is to a country that has been determined by the Swiss Federal Council or European Commission , as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their information (as set out here for transfers subject to Swiss law, and here in respect of transfers from the EEA ). Please contact us at the details set out in Section 10 should you wish to examine a copy of the EU standard contractual clauses . We may also exceptionally rely on statutory derogations for these transfers, as the case may be, such as your express consent, contract necessity, the recognition, safeguarding or exercise of rights, an overriding public interest, personal data made public without objection and/or the need to protect individuals.
6. DATA SECURITY
Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit.
7. RETENTION OF YOUR INFORMATION
We retain your information only as long as necessary to fulfil the processing purposes outlined in this Privacy Policy. Once no longer needed, the data is deleted or anonymized where possible. In principle, we will apply the following retention durations:
Information relating to sanctions and KYC/KYB checks: 10 years after the completion of the sale of the Tokens;
Email address: until you have opted-out or withdrawn your consent to receiving communications from us;
Ethereum wallet address: 12 months after the completion of the sale of the Tokens; and
Information in communications with us: 12 months after the date of the communication.
We will also retain and use your information for longer periods of time to the extent necessary based on our consideration of various criteria, including whether we need the information to provide the Services, comply with our legal obligations, resolve disputes, enforce our contractual agreements and our policies, prevent harm, promote safety, security and integrity, and to protect or defend the Services, our rights (including for preserving evidence), the rights of our users, or others. Upon completion of the sale of the Tokens, we may store your information in an anonymized format; we may use this information indefinitely without further notice to you.
8. CHILDREN’s PRIVACY
Our Services are not intended for children, and we do not seek or knowingly collect information relating to children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.
9. EUROPEAN USER PRIVACY RIGHTS
If you are using the Services in Switzerland or the EEA you may have the following rights in relation to your information, within the limits of applicable privacy laws:
Access: the right to access the information we hold about you, how we use it, and who we share it with.
Portability: the right to receive a copy of certain information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
Correction: the right to correct your information we hold that is inaccurate.
Erasure: the right to delete the information we hold about you.
Restriction of processing to storage only: the right to require us to stop processing the information we hold about you, other than for storage purposes, in certain circumstances.
Objection: the right to object to our processing of your information.
Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, if fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, if there are overriding public interests or if we are required by law to retain your information.
To exercise any of these rights, you can contact us at the details provided in Section 10. We will respond to requests to exercise these rights without undue delay and in principle within one month (though this may be extended by a further two months in certain circumstances, or as otherwise permitted by applicable law). You will need to verify your identity (e.g. by providing ID) when exercising these rights.
If you think we have infringed data protection laws, you have the right to lodge a complaint with us, and we will investigate your complaint and respond to you in a timely manner. You also have the right to lodge a complaint with the data protection supervisory authority in the EEA country in which you are based or where you think we have infringed data protection laws, or the Swiss Federal Data Protection and Information Commissioner, as applicable to you.
10. HOW TO CONTACT US
We welcome your questions and feedback about our privacy practices and this Privacy Notice. You can email us at [email protected] or contact us at:
Aztec Foundation
Gartenstrasse 6
6300 Zug
Switzerland
11. Language
Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Notice, the English language version will prevail.