Privacy Policy

1. Introduction

Limytd AG, a Swiss corporation (Aktiengesellschaft) registered under UID CHE-135.702.391, with its registered office at Chamerstrasse 172, 6300 Zug, Switzerland ("Company", "we", "us", or "our"), is the data controller responsible for the processing of your personal data.

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our website at https://presale.speax.ai/ (the "Website") and participate in the SPEAX token presale (the "Presale"). This Privacy Policy is drafted in accordance with the Swiss Federal Act on Data Protection (FADP/nDSG), which came into force on September 1, 2023.

We are committed to protecting your privacy and ensuring that your personal data is processed lawfully, fairly, and transparently. Please read this Privacy Policy carefully to understand our practices regarding your personal data.

2. Personal Data We Collect

2.1 Data You Provide Directly

When you participate in the Presale or interact with our Website, you may provide us with the following personal data:

Category	Examples
Blockchain Data	Your wallet address on the Apertum Network, transaction hashes, and contribution amounts.
Communication Data	Any information you provide when you contact us, including your name, email address, and the content of your communications.

2.2 Data We Collect Automatically

When you visit our Website, we automatically collect certain technical data through cookies and similar technologies:

Category	Examples
Device Data	Your IP address, browser type and version, operating system, device type, and screen resolution.
Usage Data	Information about how you use our Website, including pages visited, time spent on pages, links clicked, and navigation paths.
Location Data	Approximate geographic location derived from your IP address.

2.3 Data from Third Parties

We may receive personal data about you from third parties, including blockchain analytics providers and identity verification services, to comply with our legal and regulatory obligations.

3. Purposes and Legal Bases for Processing

We process your personal data for the following purposes and on the following legal bases under the FADP:

Purpose	Legal Basis
Processing your participation in the Presale	Performance of a contract (Art. 31 para. 2 lit. a FADP)
Distributing SPEAX tokens to your wallet	Performance of a contract
Complying with legal and regulatory obligations	Legal obligation (Art. 31 para. 1 FADP), including anti-money laundering (AML) and sanctions compliance
Preventing fraud and ensuring security	Legitimate interest (Art. 31 para. 1 FADP)
Improving our Website and services	Legitimate interest
Communicating with you about the Presale and Speax.ai	Consent or legitimate interest
Analyzing Website traffic and usage patterns	Consent (for non-essential cookies) or legitimate interest

4. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies to enhance your browsing experience and to collect information about how you use our Website.

4.1 Types of Cookies

Cookie Type	Purpose	Duration
Essential Cookies	Necessary for the Website to function properly.	Session
Analytics Cookies	Help us understand how visitors interact with our Website.	Up to 2 years
Preference Cookies	Remember your preferences and settings.	Up to 1 year

4.2 Your Cookie Choices

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website.

5. Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your personal data with the following categories of recipients:

Recipient	Purpose
Service Providers	Third-party companies that provide services on our behalf, such as hosting, analytics, and customer support.
Blockchain Networks	Your wallet address and transaction data are recorded on the Apertum blockchain, which is publicly accessible.
Legal and Regulatory Authorities	When required by law or to comply with legal processes, including requests from Swiss or foreign authorities.
Professional Advisors	Lawyers, accountants, and auditors who provide professional services to the Company.
Affiliates	Companies within our corporate group for internal administrative purposes.

All third-party service providers are contractually obligated to protect your personal data and to process it only in accordance with our instructions.

6. International Data Transfers

Your personal data may be transferred to, and processed in, countries outside of Switzerland. When we transfer your personal data to countries that do not provide an adequate level of data protection as determined by the Swiss Federal Data Protection and Information Commissioner (FDPIC), we will implement appropriate safeguards, such as standard contractual clauses approved by the FDPIC or the European Commission.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. The retention periods for different categories of data are as follows:

Data Category	Retention Period
Blockchain Data	Permanently recorded on the blockchain
Transaction Records	10 years (as required by Swiss commercial law)
Communication Data	3 years after the last communication
Analytics Data	Up to 26 months

8. Your Rights

Under the FADP, you have the following rights with respect to your personal data:

8.1 Right of Access

You have the right to request confirmation as to whether we are processing your personal data and, if so, to obtain a copy of your personal data and information about how we process it.

8.2 Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

8.3 Right to Erasure

You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.

8.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

8.6 Right to Object

You have the right to object to the processing of your personal data based on our legitimate interests. We will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing.

8.7 Right to Withdraw Consent

Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the contact information provided below.

9. Data Security

We have implemented appropriate technical and organizational measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption, access controls, and regular security assessments. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your personal data.

10. Children's Privacy

Our Website and the Presale are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us, and we will take steps to delete such data.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated Privacy Policy on our Website with a new effective date. We encourage you to review this Privacy Policy periodically.

12. Contact Information and Complaints

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:

If you believe that we have violated your data protection rights, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC):