Privacy Policy — NumisVR

Last Update: April 10, 2026


*01. Identity of the Data Controller*

Company: Numisvr-ico Limited
Business Number: 2183122
Legal Address: Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands
Contact: contact@numisvr.com

NumisVR also operates through an operational entity based in Switzerland, Geneva, responsible for the physical management of numismatic pieces stored in the Geneva Free Port.

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*02. Collected Data*

As part of our services, we collect the following categories of data:

- Identification data: name, first name, email address, when creating an account or contacting us via the site form.
- KYC data: identification document, proof of residence, in accordance with MiCA and AML legal obligations.
- Transaction data: blockchain wallet addresses, transaction histories of NUVR and NFTs.
- Technical data: IP address, browser type, operating system, visited pages.
- Communication data: messages sent via the contact form.

We never collect sensitive data as defined in Article 9 of the GDPR.

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*03. Purposes and Legal Bases*

- Contract execution (Article 6.1.b GDPR): account management, processing of NUVR token purchases, access to the platform.
- Legal obligation (Article 6.1.c GDPR): KYC/AML verification in accordance with MiCA and VASP regulations.
- Legitimate interest (Article 6.1.f GDPR): platform security, fraud prevention, anonymous statistical analysis.
- Consent (Article 6.1.a GDPR): sending marketing communications (revocable at any time).

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*04. Data Retention Period*

- Account data: duration of the contractual relationship + 3 years after closure.
- KYC data: 5 years after the end of the business relationship (AML obligations).
- Blockchain transaction data: 5 years in our systems.
- Navigation data: 13 months maximum.
- Contact data: 3 years from the last contact.

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*05. Data Sharing and Transfer*

We never sell your personal data to third parties. Your data may be shared with:

- Technical providers: Infomaniak (Switzerland), security services.
- KYC/AML partners: approved identity verification providers.
- Legal authorities: only upon judicial request.
- Auditors: CertiK for smart contract audits (anonymized technical data only).

In the event of a transfer outside the EU, we apply the European Commission's standard contractual clauses.

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*06. Cookies and Tracking Technologies*

- Essential cookies: necessary for the site's operation. No consent required.
- Analytical cookies: anonymous audience measurement. Activated only after consent.
- Preference cookies: memorization of your language and display preferences.

You can manage your preferences via the consent banner or your browser settings.

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*07. Your GDPR Rights*

In accordance with the GDPR, you have the following rights:

- Right of access (Article 15): obtain a copy of your data.
- Right to rectification (Article 16): correct inaccurate data.
- Right to erasure (Article 17): request the deletion of your data.
- Right to restriction (Article 18): limit processing in certain cases.
- Right to portability (Article 20): receive your data in a readable format.
- Right to object (Article 21): object to processing based on legitimate interest.
- Right to withdraw consent: at any time, without retroactive effect.

To exercise your rights: contact@numisvr.com. Response within 30 days.

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*08. Data Security*

NumisVR implements the following measures:

- HTTPS (TLS) encryption of all communications.
- HTTP security headers (HSTS, CSP, X-Frame-Options).
- Smart contract audit by CertiK.
- Restricted access to data for authorized personnel.
- Hosting with Infomaniak (Switzerland), certified ISO 27001.

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*09. Specific MiCA / Web3 Provisions*

- Blockchain immutability: transactions on Solana are permanent. The right to erasure applies only to off-chain data.
- MiCA withdrawal clause: any individual buyer has 14 calendar days to withdraw.
- Pseudonymization: your wallet addresses are not directly linked to your civil identity.
- VASP license: our Estonian entity will obtain a VASP license in accordance with European directives.

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*10. Policy Changes*

NumisVR reserves the right to modify this policy to comply with legislative developments. In the event of a substantial modification, you will be informed by email with a 30-day notice.

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*11. Contact and Complaints*

Email: contact@numisvr.com
Address: Numisvr-ico Limited, Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands

In the event of an unresolved dispute, you can contact the competent supervisory authority (CNIL in France, EDOEB in Switzerland).