Zama Auction Privacy Notice

PRIVACY NOTICE

Last updated 19.11.2025

Data protection and data security are important to Zama Switzerland  AG, registered in the Commercial Register of the Canton of Zug under company number CHE-186.971.062 (Zama; we). We process your personal data responsibly, in accordance with applicable Swiss and European Union laws and in accordance with this Privacy Notice.

We invite you to read this document carefully. If you have any questions about our Privacy Notice and, in general, about the collection and processing of your personal data by Zama please do not hesitate to contact us at: privacy@zama.org

  1. Content of this Privacy Notice 

In this Privacy Notice, we inform you about how we collect and process personal data when you visit our website at auction.zama.org (the “Website”), contact us or inquire about our services or products as a prospect. 

  1. Responsible for Data Processing 

Zama is responsible for the data processing described in this Privacy Notice. 

If you have any questions or if you wish to exercise your data protection rights, please contact us at privacy@zama.org or write to: Zama Switzerland  AG, Data Protection Officer, Grafenauweg 8, 6300 Zug, Switzerland. 

  1. Information We Collect

 When you use the Website, we may collect and link the following types of information to your user profile: 

  • Personal Information: Name, email address, physical address, and wallet address. 
  • Device Information: Device ID and operating system. 
  • Usage Data: On chain activity. 
  • User Identifiers: A unique user ID associated with your account. 

We also process personal data that we receive from third parties. This includes personal data that we receive from Sumsub, e.g. ID and Proof of Address information which are used for anti-money laundering, sanctions checks and other compliance and regulatory purposes. 

  1. How We Use Your Personal Information

 We collect this information for the following purposes: 

  • To notify you of the Auction process and to add you to Zama newsletter;
  • To enable you to register, bid, and participate in the auction; 
  • To verify your identity and deliver the tokens / airdrops / bonuses; 
  • To respond your inquiries and to communicate with you; 
  • To maintain and improve the Website functionality and security; 
  • To analyze usage trends and improve user experience; The web analytics services we use collect and store usage data using cookies. 
  1. Cookie Usage Note 

We use cookies, tags, and similar technologies on the Website to provide you with the best possible user experience and to help us improve the Website. Cookies are text files that are downloaded to your computer or mobile device when you visit the Website. 

Some of the cookies we use are necessary to provide certain features of the Website. In addition, we use cookies to analyze the use of the Website and to obtain information to optimize the Website. 

You can instruct your browser not to accept cookies or to prompt you each time before a cookie is set. You can also delete cookies on your device by using the appropriate function of your browser. In addition, you have the possibility to inform us of your preferences regarding the acceptance of cookies via the cookie preferences tool used on the Website.

  1. Use and Optimization of our Newsletter 

When you sign up for our newsletter, we collect the information you provide to us. This includes general personal data such as first name, last name and email address. We use analytics services to measure and analyze the use of our newsletter. These allow us to optimize our newsletter and provide you with content that interests you. 

You can let us know at any time that you would like to stop receiving our newsletter in the future. To do so, please use the unsubscribe link at the end of the newsletter.

  1. On which Basis we Process your Personal Data

We have a legitimate interest in processing your personal data in accordance with the aforementioned purposes. Some processing is also necessary so that we can fulfill our contractual obligations. Furthermore, we may process your personal data to comply with applicable laws and regulations or internal rules of Zama, such as with respect to the prevention of anti-money laundering and terrorist financing, know-your-customer, prevention of tax evasion, risk management and supervision, for combating abusive conduct, for purposes of investigations or proceedings and for the response to inquiries of public authorities. 

We may also base our processing of specific personal data on your consent, whereby you can revoke this consent at any time. 

On these legal bases, we process your personal data if and to the extent that the applicable data protection law requires a legal basis or justification for the lawfulness of the data processing in general or specific processing activities.

  1. With Whom We Can Share your Personal Data 

In order to achieve the purposes described in this Privacy Notice, it may be necessary for us to share your personal data with third parties. 

These are the following categories of recipients:

  • Other group companies; 
  • External Service Providers: We use trusted third-party services (e.g., custodian, analytics, payment processors) to help us operate and improve the Website; 
  • Authorities, agencies, and courts: We may disclose your information when required to do so by law or in response to valid legal processes. 
  1. Place of Processing 

We store and process your personal data primarily in Switzerland and the EU. However, we may also transfer your personal data to recipients in countries outside of Switzerland or the EU (worldwide). We transfer data to countries without adequate data protection on the basis of the revised European Commission’s standard contractual clauses including the Swiss specifications as required by the Swiss data protection supervisory authority, other transfer mechanisms, or legal exceptions (e.g. necessity for contract performance).

  1. How we Store and Protect your Personal Data 

We store your personal data only to the extent and for as long as necessary to fulfill the purposes described in this Privacy Notice or to comply with legal and regulatory obligations.

You are aware that data written on a blockchain (e.g. execution of trade orders) cannot be deleted by Zama. 

In the interest of the integrity and confidentiality of personal data, we take appropriate technical and organizational measures. In particular, we implement access controls, and procedures to regularly review, assess, and evaluate the effectiveness of the measures in accordance with our risk assessment, but no system is 100% secure.

11 Your rights in relation to your Personal Data 

You have the following rights in relation to personal data concerning you: 

  • The right to obtain information about what personal data we store about you and how we process it; 
  • The right to receive or transfer a copy of your personal data in a common format; 
  • The right to have your personal data corrected; 
  • The right to have your personal data deleted; and 
  • The right to object to the processing of your personal data. 

Please note that legal and regulatory requirements and exceptions apply to these rights. 

To the extent permitted by law, we may refuse your request to exercise these rights. You also have the right to file a complaint with the competent data protection supervisory authority. In Zama’s case the primary supervisory authority is the Federal Data Protection and Information Commissioner of Switzerland.

12 How we can change this Privacy Notice 

We may change this Privacy Notice at any time, in particular if we change our data processing practices or if new legal obligations become applicable. The version provided at auction.zama.org/privacy  applies in each case.

Privacy is necessary for an open society in the electronic age. Privacy is not secrecy. A private matter is something one doesn't want the whole world to know, but a secret matter is something one doesn't want anybody to know. Privacy is the power to selectively reveal oneself to the world.If two parties have some sort of dealings, then each has a memory of their interaction. Each party can speak about their own memory of this; how could anyone prevent it? One could pass laws against it, but the freedom of speech, even more than privacy, is fundamental to an open society; we seek not to restrict any speech at all. If many parties speak together in the same forum, each can speak to all the others and aggregate together knowledge about individuals and other parties. The power of electronic communications has enabled such group speech, and it will not go away merely because we might want it to.Since we desire privacy, we must ensure that each party to a transaction have knowledge only of that which is directly necessary for that transaction. Since any information can be spoken of, we must ensure that we reveal as little as possible. In most cases personal identity is not salient. When I purchase a magazine at a store and hand cash to the clerk, there is no need to know who I am. When I ask my electronic mail provider to send and receive messages, my provider need not know to whom I am speaking or what I am saying or what others are saying to me; my provider only need know how to get the message there and how much I owe them in fees. When my identity is revealed by the underlying mechanism of the transaction, I have no privacy. I cannot here selectively reveal myself; I must always reveal myself.Therefore, privacy in an open society requires anonymous transaction systems. Until now, cash has been the primary such system. An anonymous transaction system is not a secret transaction system. An anonymous system empowers individuals to reveal their identity when desired and only when desired; this is the essence of privacy.Privacy in an open society also requires cryptography. If I say something, I want it heard only by those for whom I intend it. If the content of my speech is available to the world, I have no privacy. To encrypt is to indicate the desire for privacy, and to encrypt with weak cryptography is to indicate not too much desire for privacy. Furthermore, to reveal one's identity with assurance when the default is anonymity requires the cryptographic signature.We cannot expect governments, corporations, or other large, faceless organizations to grant us privacy out of their beneficence. It is to their advantage to speak of us, and we should expect that they will speak. To try to prevent their speech is to fight against the realities of information. Information does not just want to be free, it longs to be free. Information expands to fill the available storage space. Information is Rumor's younger, stronger cousin; Information is fleeter of foot, has more eyes, knows more, and understands less than Rumor.We must defend our own privacy if we expect to have any. We must come together and create systems which allow anonymous transactions to take place. People have been defending their own privacy for centuries with whispers, darkness, envelopes, closed doors, secret handshakes, and couriers. The technologies of the past did not allow for strong privacy, but electronic technologies do.We the Cypherpunks are dedicated to building anonymous systems. We are defending our privacy with cryptography, with anonymous mail forwarding systems, with digital signatures, and with electronic money.Cypherpunks write code. We know that someone has to write software to defend privacy, and since we can't get privacy unless we all do, we're going to write it. We publish our code so that our fellow Cypherpunks may practice and play with it. Our code is free for all to use, worldwide. We don't much care if you don't approve of the software we write. We know that software can't be destroyed and that a widely dispersed system can't be shut down.Cypherpunks deplore regulations on cryptography, for encryption is fundamentally a private act. The act of encryption, in fact, removes information from the public realm. Even laws against cryptography reach only so far as a nation's border and the arm of its violence. Cryptography will ineluctably spread over the whole globe, and with it the anonymous transactions systems that it makes possible.For privacy to be widespread it must be part of a social contract. People must come and together deploy these systems for the common good. Privacy only extends so far as the cooperation of one's fellows in society. We the Cypherpunks seek your questions and your concerns and hope we may engage you so that we do not deceive ourselves. We will not, however, be moved out of our course because some may disagree with our goals.The Cypherpunks are actively engaged in making the networks safer for privacy. Let us proceed together apace.Onward.Eric Hughes9 March 1993
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