Telcoin

Privacy Policy

Last updated: [CONFIRM: publication date]

This policy covers two services run by Telcoin Association:

  • the website at www.telcoin.network (the “website”), including its forms and the pages that connect to a crypto wallet; and
  • the governance forum at forum.telcoin.org (the “forum”).

It explains what personal data we collect, why, who we share it with, how long we keep it and what rights you have. Some other Telcoin services are run by other organisations and have their own privacy policies. In particular, Telcoin, Inc. and Telcoin Digital Asset Bank are separate companies and this policy does not cover the Telcoin Wallet app or any service they provide.

1. Who we are

The controller responsible for your personal data is:

Telcoin Association c/o Fiduciaria Ortelli SA Via Greina 2 6900 Lugano Switzerland Swiss enterprise identification number (UID): CHE-169.445.588

Telcoin Association is an association under Articles 60 ff. of the Swiss Civil Code. It is the governance body for the Telcoin Platform. Telcoin Autonomous Ops, Ltd. (“TAO”), a company wholly owned by the Association, carries out day-to-day operation of these services on the Association’s behalf. TAO staff run the website and forum under a master services agreement between the Association and TAO, and act as our processor when they do.

Privacy questions and requests: compliance-council@telcoin.org

[CONFIRM, for legal: whether the Association offers these services to people in the EU or UK in a way that brings it within Article 3(2) GDPR or UK GDPR. If it does, name an EU and/or UK representative here under Article 27.]

2. What we collect and why

We collect only what each service needs. The table below lists every category we currently process.

Website

What we collect

When

Why

Legal basis (where GDPR applies)

Name, email address, organisation, role, mobile operator, GSMA membership status, sector, operating jurisdiction, description of your service, and your message

When you submit one of the website forms (contact us, request a conversation, partner conversation, Application Developer membership)

To reply to you and to assess partnership or membership enquiries

Steps at your request before entering a contract, and our legitimate interest in answering enquiries

A reCAPTCHA token and the device and browser information Google collects to produce it

When you submit a form or use the testnet faucet

To block automated abuse of the forms and faucet

Legitimate interest in keeping the services secure

Public wallet address, network and the transactions you ask your wallet to sign

When you connect a wallet to use the bridge, swap, pools, portfolio, eUSD vault, TEL upgrade or faucet pages

To show balances and positions and to prepare transactions for you to sign

Performance of the service you requested

Wallet address, token requested and time of your last request

When you request testnet tokens from the faucet

To enforce the faucet’s 24-hour limit per address

Legitimate interest in preventing abuse

IP address, browser type, requested page and time

Every visit, recorded by our hosting provider

To deliver the site, keep it secure and diagnose faults

Legitimate interest

The website does not use analytics, advertising or tracking cookies. [CONFIRM with the technical administrator that no analytics, tag manager or Vercel Web Analytics is enabled in the production deployment settings. None is present in the website code.]

Forum

What we collect

When

Why

Legal basis (where GDPR applies)

Username, email address, password (stored hashed) and any profile details you add

When you register

To create and secure your account

Performance of the forum terms

Your posts, replies, likes, poll votes, flags and private messages

When you participate

To run the forum and keep a record of governance discussion

Performance of the forum terms, and our legitimate interest in a public governance record

IP address of each post and of each request to the server

When you use the forum

Security, spam prevention and moderation

Legitimate interest

Read history, notification settings and session data

When you are signed in

To show what is new and to keep you signed in

Performance of the forum terms

Email notifications you have chosen to receive

Ongoing

To send the notifications you asked for

Performance of the forum terms; you can turn them off in your preferences

Text you ask an AI feature to work on (proofreading, title suggestions, explanations, translation, tables, images), and topics you ask to have summarised

When you use an AI feature

To provide the feature you asked for

Performance of the forum terms

Every new post, checked automatically for spam by an AI model

When you post

To catch spam. A post that looks like spam is sent to a moderator for review, and may be hidden until then.

Legitimate interest in keeping the forum free of spam

A numerical representation (“embedding”) of each public topic

When a topic is posted or edited

To show related topics and to power search

Legitimate interest in making the forum usable

You sign in to the forum with an email address and password. No third-party sign-in is enabled.

The AI features run on a language model hosted by Civilized Discourse Construction Kit, Inc., the company that hosts the forum. CDCK does not use forum content to train AI models or share it with anyone else for that purpose.

CDCK may also use automated tools to check public posts for abuse, security threats and potentially unlawful material. It passes anything it finds to our moderators and does not make the decision itself.

The forum also works some things out automatically from your activity. It sets your trust level, which decides what you can do on the forum (for example, whether you can upload images), from how much you read and post. And it may hide a post automatically when enough other users flag it. A moderator can reverse either: contact us if you think one is wrong.

We do not sell personal data and do not use it for advertising. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. When the spam check catches a post, it can hide the post and pause the account’s ability to post, but only until a moderator reviews it. A moderator makes the final decision every time, and can restore the post and the account straight away.

3. Public information

Some of what you provide is public by design, and you should take that into account before you provide it.

Forum posts are public. Anyone on the internet can read them, search engines index them, and others may copy them. Posts in governance categories form part of the record of how the Telcoin Platform is governed (see the forum terms, section 6).

Blockchain transactions are public and permanent. When you use the website to sign a transaction, the transaction and your wallet address are recorded on a public blockchain. We do not control that blockchain and cannot change or delete anything recorded on it. Rights to erasure or correction under section 7 cannot apply to on-chain data.

4. Who we share data with

We share personal data with service providers who run parts of these services for us, and only for that purpose. They act as our processors unless stated otherwise.

Provider

What it does

Location

Vercel Inc.

Hosts the website and processes server logs

United States, with edge servers worldwide [CONFIRM: function region]

Strapi Solutions SAS (Strapi Cloud)

Hosts the content system that stores form submissions

[CONFIRM: region chosen for the Strapi Cloud project]

Google LLC / Google Ireland Ltd

reCAPTCHA, on forms and the faucet. Google processes the data under its own privacy policy and terms, so it acts as an independent controller for that data.

United States and worldwide

Google LLC

Google Maps, on the locations map. Loading the map sends your IP address to Google.

United States and worldwide

Upstash, Inc.

Stores faucet cooldown records

[CONFIRM: database region]

Alchemy Insights, Inc.

Blockchain node access. The website forwards your wallet’s read requests (which contain your wallet address) to Alchemy through our server, so Alchemy does not receive your IP address.

United States

Reown (WalletConnect)

Relays messages between the website and your wallet if you choose to connect with WalletConnect

[CONFIRM]

Civilized Discourse Construction Kit, Inc. (Discourse)

Hosts the forum, its database and backups, sends forum emails and runs the forum’s AI features. CDCK staff in the United States, Australia and other countries can access forum data to keep the forum running and provide support.

United States, Canada or Ireland

Amazon Web Services (sub-processor of CDCK)

Stores forum backups and uploaded files, and delivers images and site files

United States, Canada or the EU

Equinix (sub-processor of CDCK)

Houses the servers in CDCK’s data centres

As for CDCK

KeyCDN (sub-processor of CDCK)

Serves generic avatars and common emoji, so receives your IP address when they load

Switzerland, with servers worldwide

Automattic, Inc. (Gravatar)

When you register, the forum looks up your email address on Gravatar using a one-way hash of it. If you have a Gravatar profile picture, the forum uses it as your avatar. You can replace it in your preferences.

United States

Apple and Google

Deliver push notifications, only if you use the DiscourseHub mobile app

United States

Discord Inc.

New topics in public forum categories are posted automatically to the Telcoin Association Discord server, with the author’s username and an excerpt. Replies, restricted categories and private messages are never posted. Discord holds these copies under its own terms.

United States

Telcoin Autonomous Ops, Ltd.

Runs the website and forum for the Association

United Kingdom

Wallet software you connect, such as MetaMask or Coinbase Wallet, is provided by its own developer under its own terms. We do not receive anything from it except what you approve in the wallet.

We may also disclose personal data where Swiss law or a court or authority with jurisdiction over us requires it, or where it is needed to establish, exercise or defend legal claims.

5. International transfers

Some of the providers above process data outside Switzerland. Where a provider is in a country the Swiss Federal Council does not recognise as providing adequate protection, we rely on the European Commission’s standard contractual clauses as recognised by the Federal Data Protection and Information Commissioner, or, for US providers certified under it, the Swiss-US Data Privacy Framework.

The United Kingdom and the member states of the European Economic Area are recognised as adequate under Swiss law.

For the forum, CDCK’s data processing addendum applies. It incorporates the European Commission’s 2021 standard contractual clauses (controller to processor), with the amendments needed for transfers from Switzerland, and it requires CDCK to tell us before it appoints a new sub-processor.

[CONFIRM: for each other provider in section 4, which mechanism applies. Vercel, Google and Alchemy should each be checked for Swiss-US DPF certification.]

6. How long we keep data

Data

Retention

Server logs kept by our forum host, containing IP addresses

Kept by CDCK for as long as it needs them to run and secure the forum, under the data processing addendum

Forum email logs, and incoming emails that were rejected

90 days

Forum accounts that were registered but never activated

Deleted after 14 days

IP addresses and email addresses blocked to stop abuse

Deleted after 365 days if no further attempt is made from them

Website hosting logs

[CONFIRM: Vercel log retention for our plan]

Faucet cooldown records

Until the 24-hour cooldown ends, then deleted automatically

Website form submissions

Deleted automatically 24 months after they are submitted [CONFIRM: the deletion job in form-retention.md is live before publication]

Forum account data

For as long as your account exists, then as described in section 7

Forum posts

For as long as the forum exists, unless removed under the forum terms or section 7

Forum backups

Kept by CDCK on a fixed schedule and deleted when that schedule expires. Data deleted from the forum stays in existing backups until they expire.

7. Your rights

You can ask us to:

  • tell you whether we hold personal data about you, and give you a copy;
  • correct data that is wrong;
  • delete your data;
  • stop or limit processing, or object to processing based on our legitimate interests;
  • give you data you provided in a machine-readable format.

Forum users can download an archive of their posts and account data from their account preferences (“Export your data”), and correct most details there directly. A user who has made no more than one post can delete their own account from their preferences. Anyone else should contact us, and we will deal with the request as described below.

Send any other request to compliance-council@telcoin.org. We will reply within 30 days. We may ask you to confirm your identity first.

There are two limits on deletion. Blockchain records cannot be changed (section 3). And when you delete a forum account, we delete your account and personal details, but where a post forms part of a governance proposal or the discussion of one, we may keep the post and attribute it to an anonymous user instead of deleting it, so that the governance record stays complete. You can ask us to remove specific posts, and we will weigh your request against the reasons for keeping the record.

If you are unhappy with how we have handled your data, you can complain to the Swiss Federal Data Protection and Information Commissioner (www.edoeb.admin.ch). If you are in the EU or UK, you can also complain to the data protection authority where you live or work.

8. Cookies and local storage

The website stores the following in your browser. None of it is sent to us.

Item

Purpose

Recent bridge transfers

Lets you see the status of transfers you started

Pending eUSD vault transactions

Lets the page pick up a transaction you submitted if you reload

Swap slippage setting

Remembers your chosen setting

Wallet connection state (set by the wallet libraries)

Reconnects your wallet on your next visit

Google reCAPTCHA cookies

Set by Google when a form or the faucet loads

Google Maps cookies

Set by Google when the locations map loads

The forum sets no cookies until you sign in. After that it sets two, both needed for it to work:

Cookie

Purpose

Expires

_t

Keeps you signed in

60 days

_forum_session

Holds your session and protects against cross-site request forgery

When you close your browser

Discourse also sets some short-lived essential cookies in particular situations: to return you to the page you were on after you sign in, to remember a theme, colour or text size you chose for one device, and to protect the forum against denial-of-service attacks.

The forum does not use analytics or advertising cookies.

You can clear or block cookies and local storage in your browser. If you block the forum’s cookies you will not be able to sign in.

[CONFIRM, for legal: whether a consent banner is needed for Google Maps for EU visitors. reCAPTCHA can be justified as necessary for security; Maps is harder to justify on that basis.]

9. Security

The website forms are protected by reCAPTCHA and submitted over HTTPS. Form submissions are stored in a content system that only authorised administrators can access. The website never handles your private keys: transactions are signed in your own wallet. Forum passwords are stored only as salted hashes, and forum moderators and administrators must use two-factor authentication.

No system is completely secure. If you think your forum account has been compromised, change your password and contact us.

10. Children

These services are not intended for anyone under [CONFIRM: 18, per the forum terms]. We do not knowingly collect personal data from them. If you believe a child has provided us with personal data, contact us and we will delete it.

11. Changes to this policy

We will post any change on this page and update the date at the top. If a change is significant, we will also announce it on the forum before it takes effect.

12. Licence

Parts of this policy are adapted from the privacy policy template published by Civilized Discourse Construction Kit, Inc. under the Creative Commons Attribution-ShareAlike 3.0 Unported licence (CC BY-SA 3.0). [CONFIRM: the version of the template the current forum policy derives from.]

Sources: discourse.org/privacy (CDCK notice, effective 23 September 2026), discourse.org/subprocessors (updated 29 October 2025), discourse.org/self-serve-terms and discourse.org/data-processing-addendum (read 16 October 2026); forum admin settings as reported 16 October 2026; forum/extracted/topics/privacy-policy–6.md (current forum template); leo-drive/Telcoin Privacy Policy.docx (TAO policy, for structure only); repos/telcoin-association-website/web/src/app/api/form-submission/route.ts, web/src/sections/*/validation.ts, cms/src/api/form-submission/content-types/form-submission/schema.json (form fields and storage); web/.env.example and web/src/lib/faucet/cache.ts (third-party services, faucet retention); web/src/server/rpcCache.ts (RPC proxy); web/src/features/EusdVault/web3/pendingRecords.ts, web/src/sections/TelBridge/hooks/useBridgeHistory.ts, web/src/features/Swap/hooks/useSwap.ts (local storage); tao-drive/Banks/Maerki Baumann/Questionnaire Corporate - TA.docx and tao-drive/Exchanges/Standard Exchange Docs/Telcoin Association Details.docx (UID, address).