This Privacy Policy (the Policy) describes how Copper collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our websites. We comply with the applicable data protection laws of Switzerland, Swiss Federal Act of 19 June 1992 on Data Protection (FADP) and any reference to the FADP shall always also include a reference to the Ordinance of the FADP (the OFADP), and the European Union, in particular the General Data Protection Regulation, GDPR.

We may revise this Policy at any time by amending this page. We therefore recommend that you check this page on a regular basis to take notice of any changes we make. This Privacy Policy was last updated on 20 February 2023.

General Information

In this Policy when we refer to Copper or “we”/”us”/”our” we mean Copper Markets (Switzerland) AG registered in the Commercial Register of the Canton of Zug under No. CHE-477.629.838. Our registered office is at Theilerstrasse 1a, 6300 Zug, Switzerland. You can find contact details in the Contact us section of our website.

Who we are

Copper is a FinTech scale-up and go-to provider of safeguarding and trading infrastructure for digital assets. We create and maintain the systems that enable vast sums of crypto-assets to move quickly and securely between exchanges and hedge funds, private banks and family offices. Your interest in our Crypto Asset Services is highly appreciated.

What is personal data / client registration

“Personal data” is anything which enables us to identify you in some way such as a name, email address, or an online identifier such as an IP address that we can link to you. You may be asked to provide personal data through our digital channels such as the website. In order to register as a new e.g. corporate client, we might probably collect following data: -Company name / Company address - First and Last name / copy of passport - E-Mail Address / Phone Number / Residential Address -Your wallet ID -Some additional information, e.g. what kind of service is desired, to ensure compliance with KYC/AML requirements (Art. 6 para. 1 Anti-Money Laundering Act, AMLA). We collect these data to fulfil our pre-contractual and contractual legal obligation with the meaning of Art. 13 para. 2 FADP and of Art. 6 para. 1 lit. b GDPR. The process of personal data is not limited to the personal data of our clients, it includes also suppliers, prospects, website users, employees, job applicants, vendors and third parties. Our aim is to limit its processing of these to a necessary minimum and in accordance with the applicable laws and regulations.

Origin of personal data that we collect

We collect personal data to the extent that is legally permitted and in particular from the following sources:

Personal data that is given to us by the data subject

1. We will process personal data that you give to us including when you email us or contact us through various channels as follows:
2. Signing up for services on our website: when you sign up for newsletters, webinars, participating in discussion boards or other social media functions, events or digital asset acquisition or storage services from us or when you contact us with queries or respond to our communications.
3. In connection with our provision of digital asset acquisition and storage services: namely for the account opening you will provide us with personal data when you or the company you represent becomes a client of Copper. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.

Use of Personal Information

We may use each of the categories of personal information described above for one or more of the following purposes:

• To fulfil or meet the reasons for which the information is provided, including hiring, retention and employment purposes.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• As described to you when collecting your personal information or as otherwise set forth in the CPRA.

We use or disclose sensitive personal data for the following purposes only: providing the products and services you request, as well as improving those offerings; operating and overseeing our business; protecting rights and interests; and for purposes that do not infer characteristics about consumers.

CPRA Notice to Applicants, Employees, Principals and Consumers

Last updated: 20 February 2023

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Copper Markets (Switzerland) AG and its subsidiaries (collectively, “Copper,” “we,” “us,” or “our”), including Copper Technologies (US) Inc., and applies solely to visitors, applicants, employees, persons who manage and administer Copper but are not employees such as board members (“principals”), and others who reside in the State of California (“consumers” or “you”). Any terms defined in the CCPA as amended by the California Privacy Rights Act (“CPRA”) have the same meaning when used in this notice. This information should be read together with rest of our Privacy Policy.

Information We Collect

We collect personal information to operate and manage our business. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Use of Personal Information

We use or disclose sensitive personal data for the following purposes only: providing the products and services you request, as well as improving those offerings; operating and overseeing our business; protecting rights and interests; and for purposes that do not infer characteristics about consumers.