Privacy Policy

1. Who We Are

TrustSwap Launchpad S.A. de C.V., incorporated in El Salvador ("TrustSwap Launchpad", "we", "us", "our"), operates the TrustSwap Launchpad platform (the "Launchpad") at trustswaplaunchpad.com.

We are the data controller for the personal information described below.

Contact: info@trustswap.org

This policy covers the Launchpad only. It does not cover third-party wallets, blockchains, project websites, or our identity verification provider, each of which operates under its own terms.

This policy explains how we handle personal information. If you are not comfortable with the practices described here, please do not use the Launchpad.

2. Information We Collect

Information you provide. Your email address, staking wallet address and the wallet provided collect the tokens. We store these together, because the connection between them is what allows us to calculate your allocation and notify you about it as well as input for the vesting schedule.

Information we derive. We calculate and store a SWAP Score against your wallet address, based on your staking activity. Your SWAP Score determines the size of your allocation, and we retain it for as long as we retain your participation data.

Information generated automatically. We do not deliberately collect browsing or behavioural data, and we do not run advertising or profiling tools. However, our third party hosting and email providers process technical data as an unavoidable part of delivering the service, including IP addresses, request timestamps, browser and device type, and email delivery status. This information is not shared with us. We use cookies only where strictly necessary to keep your session and wallet connection active.

Public blockchain data. We read publicly available on-chain data associated with your wallet in order to determine your SWAP Score and allocation. Transactions you make are recorded on public blockchains. Those records are permanent, publicly visible, and outside our control, we cannot alter or delete them, and neither can you.

The Launchpad is not available to anyone under 18, or to residents of restricted jurisdictions that are determined by the projects on our launchpad and can change per project based on the regulation within the jurisdiction they are incorporated.

3. How and Why We Use It

We use your email address, wallet address and SWAP Score to:

• calculate and record your allocation;
• notify you about allocations, participation, timings and platform announcements;
• respond to you if you contact us;
• maintain the security and integrity of the Launchpad; and
• comply with legal obligations that apply to us.

Where the General Data Protection Regulation applies, our legal bases are performance of our contract with you (operating your account, calculating and allocating participation, and sending the transactional notices that go with it), our legitimate interests in keeping the platform secure, preventing abuse and enforcing eligibility restrictions, and legal obligation where we are required to retain or disclose information.

4. Identity Verification (KYC)

Identity verification is carried out by Sekuritance, an independent third party provider. You deal with them directly. The identity documents and personal information you submit for verification are collected, held and processed by that provider under its own privacy policy, we do not receive, access, or store them.

We only receive confirmation that your wallet address has passed KYC, along with your name and email address. This information is used solely to address you personally in correspondence and to communicate with you regarding your allocation confirmation.

If you want to exercise rights over the information you submitted for verification, or ask how long it is kept, contact Sekuritance at https://sekuritance.com/about-us/contact/.

5. Who We Share Information With

We do not sell, rent, or trade your personal information, and we do not share your email address for anyone else's marketing.

We disclose information only:

• to service providers who host the Launchpad and deliver our email on our instructions, who are contractually restricted to using it for those purposes and nothing else;
• where required by applicable law, court order, or a competent authority, or to establish or defend legal claims; and
• to a successor entity if we are involved in a merger, acquisition or sale of assets.

6. International Transfers

We are established in El Salvador.

If you are in the European Economic Area or the United Kingdom, your information is transferred outside those areas. El Salvador is not covered by a European Commission adequacy decision, so where we make such transfers we rely on the European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Addendum where relevant.

7. How Long We Keep It

We keep your email address, wallet address until requested by you to remove. Blockchain records are permanent and outside our control.

8. Security

We maintain technical and organisational measures appropriate to the risk, including access controls, multi-factor authentication for administrative access, encryption in transit and at rest, and regular backups. No system is completely secure and we cannot guarantee absolute security.

If a breach affects your personal information we will notify the State Cybersecurity Agency of El Salvador and, where required, other authorities and affected users, within the timeframes set by applicable law, within 72 hours where that requirement applies.

You are responsible for the security of your own wallet, seed phrase and private keys. We will never ask you for a seed phrase or private key. Any message that does is not from us.

9. Your Rights

Email info@trustswap.org to make a request. We may first ask you to demonstrate control of the wallet or email address concerned.

We cannot delete information we are required by law to keep, and we cannot alter or delete blockchain records. Requests about your identity verification data must go to Sekuritance, since we do not hold it.

10. Changes to This Policy

We may update this policy to reflect changes to our practices, services or legal obligations. The current version is always available through the TrustSwap Launchpad dashboard at trustswaplaunchpad.com, with the date of last update shown at the top.

Where a change materially affects how we use your personal information they take effect when published. We encourage you to review this policy from time to time.

11. Contact

TrustSwap Launchpad S.A. de C.V., San Benito, El Salvador

Privacy contact: info@trustswap.org