Levolution
Legal

Privacy Policy

Last updated: September 2026

1. Data Controller

This Privacy Policy describes how Levolution AG ("Levolution", "we", "us", or "our") collects, uses, stores, and shares your personal data when you access the Levolution Token Portal or related services.

Levolution AG
c/o M. & A. GLOOR Family Office GmbH, Chamerstrasse 14, 6300 Zug, Switzerland
support@levolution.net

We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).

2. Data We Collect

We collect personal data that you provide directly to us, data generated through your use of the portal, and data we receive from service providers. This includes:

Account & identity data

  • full name and date of birth;
  • email address;
  • residential address and country of residence;
  • nationality and country of citizenship.

Verification data (where required)

  • government-issued identity documents (passport, national ID, driver's license);
  • proof of address documents (utility bills, bank statements);
  • source of funds documentation where required by law.

Wallet & transaction data

  • wallet addresses submitted by you;
  • transaction hashes and on-chain transaction history;
  • allocation amounts, token quantities, and payment references.

Technical & usage data

  • IP address, browser type, and operating system;
  • pages visited, time spent on pages, and click patterns;
  • device identifiers and referring URLs.

3. How We Use Your Data

We use your personal data for the following purposes:

  • Account management: to create, maintain, and authenticate your account on the portal;
  • Allocation management: to record and manage your LEVLX allocations, staking balances, and token deliveries;
  • Identity verification: to conduct KYC/AML checks where required by applicable law and our internal policies;
  • Legal compliance: to comply with applicable laws, regulations, court orders, and government requests;
  • Fraud prevention: to detect, investigate, and prevent fraudulent activity or abuse of the portal;
  • Communications: to send you transactional emails, security alerts, and portal updates;
  • Marketing (with consent): to send you newsletters or announcements where you have given explicit consent;
  • Platform improvement: to analyze usage patterns and improve the security and functionality of the portal.

4. Legal Basis for Processing

Where the GDPR or similar data protection laws apply, we process your personal data on the following legal bases:

  • Contract performance: processing necessary to provide the portal and manage your allocations;
  • Legal obligation: processing required to comply with AML, KYC, and other legal obligations;
  • Legitimate interests: processing for fraud prevention, platform security, and business analytics;
  • Consent: processing for marketing communications and optional analytics where we have obtained your prior consent.

5. Data Sharing

We may share your personal data with the following categories of recipients:

  • Identity verification providers: where verification is required, specialised third-party providers may process your identity documents on our behalf under data processing agreements;
  • Payment processors: payment service providers may receive your wallet address and transaction data to facilitate payments;
  • Cloud & infrastructure providers: the portal is hosted on cloud infrastructure; service providers may process data as processors under our instructions;
  • Legal and regulatory authorities: we may disclose data to law enforcement, regulatory bodies, or courts when required by law or to protect our legal rights;
  • Professional advisors: lawyers, accountants, and auditors under professional secrecy obligations.

We do not sell your personal data to third parties for their own marketing purposes.

6. International Data Transfers

Levolution AG is based in Switzerland; the portal is hosted on servers within the European Union. Where personal data is transferred to countries outside Switzerland or the European Economic Area that do not provide an adequate level of data protection, such transfers are carried out under appropriate safeguards, including Standard Contractual Clauses (SCCs) or equivalent mechanisms.

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following minimum retention periods:

  • Account data: for the duration of your account, plus 7 years after account closure;
  • KYC/AML records: minimum 5 years after the end of the business relationship, as required by anti-money laundering regulations;
  • Transaction records: minimum 7 years for tax and financial record-keeping purposes;
  • Marketing consent records: until you withdraw consent, plus 3 years thereafter;
  • Technical logs: up to 12 months.

Upon expiry of retention periods, we will securely delete or anonymize your personal data.

8. Your Rights

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

  • Access: the right to request a copy of the personal data we hold about you;
  • Rectification: the right to have inaccurate or incomplete data corrected;
  • Erasure: the right to request deletion of your data, subject to legal retention obligations;
  • Restriction: the right to restrict processing of your data in certain circumstances;
  • Portability: the right to receive your data in a structured, machine-readable format;
  • Objection: the right to object to processing based on legitimate interests;
  • Withdraw consent: the right to withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at support@levolution.net. We will respond to verified requests within 30 days.

9. Cookies

The portal uses cookies and similar technologies to maintain sessions, analyze usage, and enhance security. You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the portal.

10. Contact & Complaints

For privacy-related inquiries or to exercise your data protection rights, contact:

Data Privacy — Levolution AG
support@levolution.net

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local data protection supervisory authority.