COOKIE STATEMENT

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1. SCOPE AND STATUTORY BASIS

1.1. Nature of this Statement

This Cookie Statement (the "Statement") provides a detailed overview of how Alterswap AG (hereinafter "Alterswap," "the Company," "we," or "us") utilises cookies, pixels, local storage, and similar tracking technologies on our website and digital platform. This Statement is an integral part of our broader Privacy Policy and is designed to ensure full transparency regarding the automated collection of data during your interaction with our platform.

1.2. Legal and Regulatory Compliance

As a Swiss-based financial intermediary, Alterswap's use of tracking technologies is governed by a dual-layered legal framework ensuring the highest standards of electronic privacy:

- The Swiss Federal Act on Data Protection (FADP) [SR 235.1]: Adhering to the principles of Privacy by Design and Privacy by Default, ensuring that data processing via cookies is proportionate and transparent.
- The EU ePrivacy Directive (Directive 2002/58/EC): Complying with international Cookie Law standards, particularly for users accessing our services from within the European Economic Area (EEA), which requires informed consent for non-essential tracking.
- Swiss Federal Act on Unfair Competition (UCA): Ensuring that our digital tracking practices are fair and do not mislead the user.

1.3. Commitment to Data Sovereignty

At Alterswap, we prioritise the security of your financial environment. Our use of cookies is primarily dictated by the necessity of maintaining a secure, AML-compliant, and high-performance platform. We do not utilise tracking technologies that compromise your anonymity for third-party advertising purposes without your explicit, granular consent.

1.4. Consent Philosophy

We operate on a Transparency-First basis:

- Strictly Necessary Cookies: These are deployed automatically as they are essential for the operation of the platform and your security.
- Optional Cookies: Performance, Functional, and Analytical cookies are disabled by default and will only be activated if you provide affirmative consent via our Cookie Consent Manager.

2. DEFINITION AND TECHNICAL TAXONOMY

2.1. Defining Cookies and Digital Identifiers

A "Cookie" is a small text file or data packet containing a unique string of alphanumeric characters that is transferred to your device's browser or hard drive when you visit the Alterswap platform. Cookies enable our servers to recognise your specific session, maintaining the integrity of your account as you navigate through different sections of the site.

2.2. Complementary Tracking Technologies

In addition to standard HTTP cookies, Alterswap may utilise advanced technical equivalents to ensure platform security and performance:

- Local Storage (HTML5): Technologies that allow our platform to store data locally within your browser. Unlike cookies, local storage has a higher capacity and is not automatically transmitted to our servers with every request, making it more efficient for storing user interface preferences.
- Web Beacons and Pixel Tags: Minute, transparent graphic images (also known as "clear GIFs") embedded in our platform or HTML-formatted emails. These are utilised to verify the successful delivery of critical security notices and to analyse the effectiveness of our communication channels.
- Device Fingerprinting: The collection of technical telemetry — such as browser version, operating system, and screen resolution — to create a unique identifier for your device. This is a security measure used to detect account takeover attempts and unauthorised access from unrecognised hardware.

2.3. Duration-Based Classification

- Session Cookies (Transient): These are temporary identifiers that expire and are automatically deleted once you close your browser or log out of the Alterswap secure area. They are essential for maintaining your authenticated state during a single session.
- Persistent Cookies (Extended): These remain on your device for a pre-defined period (ranging from a few days to several months) or until manually deleted. They allow the platform to remember you on subsequent visits — for example, to retain your preferred language or to recognise your device for faster multi-factor authentication (MFA).

2.4. Origin-Based Classification

- First-Party Cookies: These are deployed directly by Alterswap AG. They are primarily functional and are used to facilitate the core services, such as your multi-currency account dashboard, FX conversion interface, and IBAN management.
- Third-Party Cookies: These are deployed by our regulated service partners — such as banking providers, KYC/KYB vendors, or security auditors. These cookies allow third-party features to be provided on or through our platform, such as secure document uploads for identity verification.

3. CATEGORISATION BY FUNCTIONAL PURPOSE

In accordance with the principle of data minimisation and Privacy by Design, Alterswap AG categorises cookies based on their specific technical and operational roles within our platform.

3.1. Strictly Necessary (Essential) Cookies

These cookies are essential for the technical operation and security of the Alterswap platform. Without these technologies, the core financial services you have requested — including multi-currency account management, FX conversion, and international payment execution — cannot be provided.

- Purpose: Authenticating your identity, maintaining your secure session across different pages, preventing Cross-Site Request Forgery (CSRF) attacks, and ensuring the stability of the platform.
- Legal Basis: Processing is necessary for the performance of a contract (Art. 6(1)(b) GDPR / Art. 13(2)(a) FADP) and to fulfil statutory AML/CTF security obligations.
- Consent: Under Swiss and EU law, these cookies do not require prior user consent as they are strictly necessary for the service.

3.2. Security and Fraud Prevention Cookies

Given our status as a regulated financial intermediary, we deploy specialised tracking to protect the integrity of your account and the platform.

- Purpose: Detecting bot activity, identifying multiple failed login attempts from a single IP address, and recognising device fingerprints to alert you of unauthorised access from new hardware.
- Role: These act as a digital perimeter, ensuring that only the authorised account holder can initiate transactions or view sensitive financial data.

3.3. Functional (Preference) Cookies

These cookies allow the platform to remember choices you make in order to provide an enhanced, personalised experience.

- Purpose: Remembering your preferred language (e.g., German, French, or English), your preferred base currency (e.g., CHF or EUR), and your customised dashboard layout.
- Control: These are optional. While disabling them will not affect the platform's security, it will result in a degraded user experience where you must re-select your preferences upon every visit.

3.4. Performance and Analytical Cookies

We utilise privacy-centric analytical tools to understand how users interact with our platform in order to improve our services.

- Purpose: Aggregating anonymous data such as page load speeds, the most frequently used currency pairs, and identifying technical bottlenecks in the onboarding or conversion process.
- Data Protection: We utilise IP-masking and anonymisation protocols to ensure that these cookies do not identify you personally. We do not use marketing or retargeting cookies that track your behaviour across third-party websites.

Summary table:

4. THIRD-PARTY INTEGRATIONS AND DATA FLOWS

Alterswap AG operates as a technical orchestrator between your browser and several specialised, regulated service providers. To ensure the integrity of your IBAN accounts, FX conversions, international payments, and identity verification, certain third-party tracking technologies are required.

4.1. Identity Verification (KYC/KYB) Cookies

During the onboarding process, Alterswap integrates specialised identity verification modules. These third-party providers deploy cookies and local storage to:

- Liveness Detection: Facilitate the secure transmission of biometric data to prevent deepfake or spoofing attacks during identity verification.
- Document Integrity: Ensure that high-resolution images of your government-issued identification are uploaded securely and associated with your specific session.
- Session Continuity: Prevent the need to restart the verification process if your connection is momentarily interrupted.

4.2. Banking and Payment Provider Interface

To manage your dedicated IBAN accounts and execute FX conversions and international payments, our platform communicates with licensed banking partners and payment providers.

- Cross-Site Security: These cookies ensure that instructions sent from your Alterswap dashboard to the banking infrastructure are authentic and have not been tampered with by a man-in-the-middle attack.
- Transaction State: Tracking the real-time status of currency conversions, wire transfers, and SEPA, CHAPS, and Faster Payments settlements.
- Session Integrity: Maintaining the authenticated state of your session during multi-step payment or conversion flows to prevent unauthorised interruption.

4.3. Security and Infrastructure Monitoring

We utilise globally distributed Content Delivery Networks (CDNs) and cybersecurity services — such as Cloudflare or similar enterprise-grade providers.

- Bot Mitigation: These providers deploy cookies to distinguish between legitimate human users and automated malicious scripts, providing DDoS protection.
- Load Balancing: Directing your traffic to the nearest secure Swiss or EEA-based server to minimise latency during periods of high platform activity.

4.4. Data Flows and Sovereign Control

While these third parties deploy their own cookies, Alterswap AG ensures that:

- No Marketing Leakage: These partners are contractually prohibited from using data collected via our platform for their own marketing or profiling purposes.
- Jurisdictional Integrity: We prioritise partners who store and process cookie-related metadata within Switzerland or the European Economic Area (EEA).

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5. GOVERNANCE OF USER CHOICE (COOKIE MANAGEMENT)

Alterswap AG provides you with granular control over your digital footprint. While we operate under high-security standards, we ensure that you have the technical means to manage your privacy preferences in accordance with the Swiss FADP and the EU ePrivacy Directive.

5.1. The Alterswap Consent Manager

Upon your first visit to our platform, and at periodic intervals thereafter, you will be presented with our Cookie Consent Manager. This interface allows you to:

- Accept All: Enable all categories of cookies (Essential, Functional, and Analytical) for the most seamless experience.
- Reject Non-Essential: Opt out of Functional and Analytical cookies while maintaining the Essential and Security cookies required for the platform to operate.
- Granular Selection: Toggle individual categories based on your specific privacy preferences.

5.2. Browser-Level Controls

Most modern web browsers allow you to manage cookies through their internal settings. You can typically:

- Delete All Cookies: Clear your browser cache to remove all existing cookies from your device.
- Block Third-Party Cookies: Prevent service providers other than Alterswap from placing identifiers on your device.
- Incognito/Private Mode: Use a browsing mode that automatically deletes cookies and local storage when the session is closed.

For detailed instructions, please refer to the official documentation of your browser provider — including Google Chrome (support.google.com/chrome), Apple Safari (support.apple.com/safari), Mozilla Firefox (support.mozilla.org), or Microsoft Edge (support.microsoft.com/edge).

5.3. Consequences of Deactivation

As Alterswap AG is a regulated financial platform, the deactivation of certain cookie categories has operational implications:

- Deactivating Essential / Security Cookies: This is not permitted through our Consent Manager. If you use browser-level blocks to stop these cookies, the Alterswap platform will be unable to authenticate your session. For your protection, our system will prevent you from accessing account features, viewing your IBAN details, or initiating payments or conversions, as we cannot guarantee the security of the connection.
- Deactivating Functional Cookies: You will lose the ability to save your language preferences or dashboard customisations. You will be required to re-configure your interface settings upon every login.
- Deactivating Analytical Cookies: This has no impact on your user experience but prevents us from receiving the technical feedback necessary to optimise our platform performance.

5.4. Global Privacy Control (GPC) and "Do Not Track"

Alterswap AG is designed to recognise Global Privacy Control (GPC) signals. If your browser broadcasts a GPC signal, our platform will automatically treat this as a request to opt out of all non-essential tracking, effectively mirroring a Reject Non-Essential selection in our Consent Manager.

6. CROSS-BORDER DATA PROCESSING

6.1. Cross-Border Data Transfers

As a global financial platform, Alterswap AG may utilise third-party infrastructure and security services (as detailed in Section 4) that operate across international borders.

- Jurisdictional Safe Harbours: We prioritise service providers located within Switzerland and the European Economic Area (EEA), which are recognised for providing an adequate level of data protection.
- Third-Country Transfers: If a technical service — such as a DDoS shield or a global CDN — requires data processing in a third country (for example, the United States), we ensure that such transfers are governed by Standard Contractual Clauses (SCCs) and supplementary technical measures, including data encryption and IP-masking, to maintain compliance with the FADP.

7. FINAL PROVISIONS

7.1. Policy Evolution and Versioning

The digital landscape and financial regulations are subject to frequent change. Alterswap AG reserves the right to update this Cookie Statement to reflect changes in our technical stack, new service integrations, or shifts in Swiss and international privacy laws.

- Review Cycle: We conduct a technical audit of our cookie and tracking implementation at least annually.
- Notification: Any material changes to how we use tracking technologies will be signalled via an updated banner on our platform or a direct notification to your registered email address.

7.2. Integration with Other Legal Documents

This Statement must be read in conjunction with the:

- Alterswap General Privacy Policy — for broader data rights and processing purposes.
- Terms and Conditions — for the contractual basis of service.
- Risk Disclosure — for technical and operational risk information.
- AML/CTF Policy — for our compliance and monitoring obligations as a regulated financial intermediary.

7.3. Contact for Technical Privacy Inquiries

If you have specific questions regarding the cookies we use, or if you wish to request a detailed Cookie Audit Log of the trackers currently active on your account, please contact our Compliance Department:

- Entity: Alterswap AG
- Email: support@alterswap.ch
- Subject Line: "Cookie / Tracking Inquiry"
- Registered Address: Assetstrasse 37, CH 6438, Ibach, Switzerland

7.4. Effective Date

This Cookie Statement is effective as of March 2026.
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REGULATORY

AlterSwap AG
Company Registration: CHE-400.153.137
Registered Address: Assetstrasse 37, CH 6438, Ibach, Switzerland
Regulatory Status: AlterSwap AG is an officially affiliated member of the VQF (Self-Regulatory Organisation), a supervised body officially recognised by the Swiss Financial Market Supervisory Authority (FINMA) for the purpose of combating money laundering and terrorist financing (AMLA). AlterSwap AG does not hold a banking licence from FINMA and does not provide traditional deposit insurance.

For cookie and tracking inquiries, please contact: support@alterswap.ch

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