Legal Docs
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).