Effective: 2 April 2024 · Last Updated: April 2026 · Version 2.0
// Section 01 — Data Controller //
01
Who We Are & Scope of This Policy
This Privacy Policy is issued by Saeculum XXI Ethicoin ("Ethicoin", "we", "us", "our"), the operator of the Ethicoin platform at ethicoin.org and its subdomains. Ethicoin acts as the data controller for personal data collected through the Platform.
This Policy covers all personal data collected when you use the Ethicoin website, contact us, apply for the Ambassador Programme, subscribe to updates, or interact with the ETHIC+ token ecosystem — including activities related to gold index value redemption via the token burn mechanism on AIA Exchange.
Important — AIA Exchange is SeparateKYC identity verification and gold index redemption are processed through AIA Exchange (aianalysisexchange.com), which is an independent entity with its own privacy policy. Ethicoin does not collect, store, or process your KYC data — that data is handled exclusively by AIA Exchange. You should review AIA Exchange's privacy policy separately before submitting identity documents.
By using the Platform you confirm you have read and understood this Policy. If you do not agree, please cease use of the Platform. Questions: office@ethicoin.org
// Section 02 — Data We Collect //
02
What Data We Collect
Data you provide directly:
Contact enquiries — name, email address, subject, message content when you contact us via office@ethicoin.org or the contact form
Ambassador applications — name or handle, email, country, social media URLs, audience size, and application responses
Newsletter/community sign-ups — email address and communication preferences
Press enquiries — name, publication, and nature of request
Data collected automatically:
Technical data — IP address, browser type and version, device type, operating system, referring URL
Usage data — pages visited, time on site, interactions, click patterns
Cookies — session management, analytics, and functional preference cookies (see Section 07)
Data We Do Not CollectEthicoin does not collect private keys, seed phrases, or wallet passwords. We do not collect KYC identity documents — those are submitted to and held by AIA Exchange only. We do not collect payment card data.
// Section 03 — Blockchain & On-Chain Data //
03
On-Chain Data & Blockchain Transparency
ETHIC+ operates on BNB Smart Chain — a public, decentralised, permissionless blockchain. All on-chain transactions are permanently public and cannot be deleted, modified, or erased by Ethicoin or any party.
What Is Permanently Public on the Blockchain
When you transact with ETHIC+ tokens, the following is publicly recorded on BNB Smart Chain and visible to anyone via BSCScan:
▸ Your wallet address
▸ Transaction amount, date, and time
▸ Token transfer direction (sender and recipient)
▸ The 1% charity fee allocation on each transaction
▸ Token burn transactions (gold index redemption events)
Your wallet address is pseudonymous — it does not inherently reveal your real-world identity. However, it may be linked to your identity if you have previously associated it with KYC-verified accounts or exchanges.
Right to Erasure Does Not Apply to Blockchain DataUnder GDPR and similar regulations, the right to erasure (right to be forgotten) does not extend to data recorded on a public, decentralised blockchain. Once a transaction is confirmed on BNB Smart Chain, it is permanent and irreversible. This is the fundamental nature of blockchain technology and is not unique to Ethicoin.
ETHIC+ tokens may be redeemed for their gold index equivalent value through AIA Exchange via the token burn mechanism. This process involves the collection and processing of data at multiple steps. Here is what data is involved at each stage:
01
KYC Verification — AIA Exchange
Full identity verification is required on AIA Exchange before any redemption is eligible. This involves collection of government-issued ID, proof of address, and potentially biometric data. This data is collected and processed exclusively by AIA Exchange — Ethicoin has no access to it. Review AIA Exchange's privacy policy at aianalysisexchange.com.
Data Controller: AIA Exchange
02
Minimum Token Threshold Verification
AIA Exchange verifies that you hold a qualifying minimum amount of ETHIC+ tokens. This verification is performed on-chain by reading your wallet balance from BNB Smart Chain. Your wallet address and balance are public blockchain data.
Data: Wallet address (public blockchain)
03
Token Burn — Permanent On-Chain Event
Your ETHIC+ tokens are permanently and irreversibly burned on BNB Smart Chain. The burn transaction is recorded permanently on the public ledger — wallet address, token amount, timestamp, and burn confirmation. This cannot be reversed, deleted, or erased. It is publicly visible to anyone on BSCScan forever.
Data: Permanent public blockchain recordIrreversible
04
Gold Index Value Settlement — AIA Exchange
Upon confirmed burn, AIA Exchange processes the gold index value settlement. Settlement processing involves financial data handled by AIA Exchange in accordance with their terms, applicable AML/KYC regulations, and applicable financial law. Ethicoin does not process or receive financial settlement data.
Data Controller: AIA Exchange
// Section 05 — How We Use Your Data //
05
Purpose & Legal Basis for Processing
Responding to enquiries — to reply to your messages, press requests, or support questions. Legal basis: contract / legitimate interest
Ambassador programme — to evaluate, process, and manage ambassador applications. Legal basis: contract / legitimate interest
Security and fraud prevention — to identify and prevent unauthorised access, spam, or abuse. Legal basis: legitimate interest
Legal compliance — to comply with applicable law, court orders, or regulatory obligations. Legal basis: legal obligation
Analytics and improvement — to understand how users interact with the Platform and improve it. Legal basis: legitimate interest / consent
Communications — to send updates, announcements, and news if you have subscribed. Legal basis: consent
Press and media — to respond to journalist enquiries and support media coverage. Legal basis: legitimate interest
Dispute resolution — to resolve complaints, claims, or legal proceedings. Legal basis: legal obligation / legitimate interest
No Sale of DataEthicoin does not sell, rent, or commercially trade your personal data to third parties. Period.
// Section 06 — Data Sharing //
06
Who We Share Data With
We share data only where strictly necessary and always with appropriate safeguards in place.
Service providers — hosting, email delivery, and analytics providers who process data on our behalf under data processing agreements
Legal authorities — where required by applicable law, court order, or regulatory authority in the UAE or any other applicable jurisdiction
AIA Exchange — where you initiate gold index redemption through the burn mechanism, your wallet address and burn transaction data are publicly visible on BNB Smart Chain and accessible to AIA Exchange for settlement processing
Professional advisors — lawyers, accountants, and auditors, subject to professional confidentiality obligations
Business transfers — in the event of a merger, acquisition, or sale of assets, personal data may be transferred with appropriate notice
International TransfersEthicoin is operated from the UAE. If you access the Platform from the EEA, UK, or other jurisdictions with data export restrictions, your data may be transferred internationally. We apply appropriate safeguards — including standard contractual clauses where required — to protect your data during such transfers.
// Section 07 — Cookies & Tracking //
07
Cookies & Tracking Technologies
The Ethicoin website uses cookies and similar technologies to enable core functionality and improve the user experience.
Essential cookies — required for basic site function. Cannot be disabled
Analytics cookies — help us understand usage patterns (e.g. Google Analytics). Anonymised where possible
Functional cookies — remember your preferences between visits
Your Cookie ChoicesMost browsers allow you to control cookies through their settings. You can block or delete cookies at any time. Blocking essential cookies may affect site functionality. Analytics and functional cookies require your consent where applicable law demands it.
Third-Party TrackersWhere third-party services are embedded (such as YouTube videos), those providers may set their own cookies subject to their own privacy policies. Ethicoin does not control third-party cookies.
// Section 08 — Data Retention //
08
How Long We Keep Your Data
Contact enquiries — retained for 3 years from the date of last correspondence
Ambassador applications — retained for 2 years from submission; longer if an active ambassador relationship exists
Legal and compliance records — retained for as long as required by applicable law (typically 7 years in the UAE)
Analytics data — retained in anonymised or aggregated form in accordance with the relevant analytics provider's policies
Blockchain / on-chain data — permanent and irreversible by nature. Not subject to deletion
When data is no longer required we securely delete or anonymise it. We do not retain personal data indefinitely.
// Section 09 — Your Rights //
09
Your Data Rights
Depending on your jurisdiction, you may have some or all of the following rights regarding your personal data held by Ethicoin:
📋
Right to Access
Request a copy of the personal data we hold about you
✏️
Right to Rectify
Request correction of inaccurate or incomplete personal data
🗑️
Right to Erasure
Request deletion of your data where no legal basis for retention exists. Does not apply to blockchain data
⛔
Right to Object
Object to processing based on legitimate interests, including direct marketing
📦
Right to Portability
Receive your data in a structured, machine-readable format where applicable
⏸️
Right to Restrict
Request restriction of processing in certain circumstances
EEA & UK Users — GDPR RightsIf you are located in the European Economic Area or the United Kingdom, you have full GDPR / UK GDPR rights as described above. You also have the right to lodge a complaint with your local data protection supervisory authority. To exercise any right, contact us at office@ethicoin.org. We will respond within 30 days.
Data Subject Access Requests (DSARs)To submit a DSAR, email office@ethicoin.org with the subject line "DSAR Request", your full name, and the nature of your request. We may ask you to verify your identity before processing your request.
// Section 10 — Security //
10
Data Security
We implement reasonable and appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction — including encryption in transit, access controls, and regular security reviews.
Encryption — all data in transit over HTTPS/TLS
Access controls — data accessible only to authorised personnel
Minimal data collection — we collect only what is necessary
No System is Perfectly SecureDespite our measures, no internet transmission or electronic storage system is 100% secure. Ethicoin cannot guarantee the absolute security of your data and accepts no liability for breaches outside our reasonable control. You are responsible for maintaining the security of your own devices and wallet credentials.
// Section 11 — Children · Updates · Contact //
11
Children, Policy Updates & Contact
Children's PrivacyThe Ethicoin Platform is intended for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected data from a minor, we will delete it promptly. If you believe a minor has submitted data to us, contact office@ethicoin.org immediately.
Policy UpdatesWe may update this Privacy Policy periodically. Updates will be published on this page with a revised "Last Updated" date. Your continued use of the Platform following an update constitutes acceptance of the revised Policy. For material changes we will make reasonable efforts to provide notice.
For Data Subject Access Requests, erasure requests, or privacy complaints, email with subject line: "Privacy Request"
Governing LawThis Privacy Policy is governed by the laws of the United Arab Emirates, specifically the laws of the Emirate of Dubai. Any disputes shall be subject to the exclusive jurisdiction of the courts of Dubai, UAE.
Investment Risk Notice: Ethicoin (ETHIC+) is a high-risk speculative digital asset. The gold index reference entitles holders to redeem via token burn on AIA Exchange with full KYC and minimum token threshold — it is not a capital protection instrument or minimum price guarantee. Only invest what you can afford to lose. Nothing here constitutes financial advice. Full risk disclaimer →