TERMS AND CONDITIONS

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1. INTRODUCTION

1.1. Purpose of These Terms

Welcome to Alterswap. These Terms and Conditions ("Terms") govern your use of our platform at https://alterswap.ch/, our services, and any associated applications (collectively, the "Platform"). By accessing or using the Platform, you agree to these Terms in full. If you do not agree, you must stop using the Platform immediately.

These Terms outline the rights and responsibilities between you ("User," "Client," or "you") and Alterswap AG ("Alterswap," "we," "us," or "our"), a company registered in Switzerland under company number CHE-400.153.137, with its registered office at Assetstrasse 37, CH 6438, Ibach, Switzerland.

Alterswap operates as a financial intermediary and is affiliated with the Financial Services Standards Association (VQF), a Swiss self-regulatory organisation (SRO) overseeing compliance with anti-money laundering laws. Our services are provided in full compliance with Swiss financial regulations.

1.2. Agreement to These Terms

By using the Alterswap Platform, you confirm that you have read, understood, and agree to be legally bound by these Terms, as well as any additional policies or notices referenced herein. These Terms apply to all Users, whether you register for an account, access services, or browse the Platform.

If you do not agree with any part of these Terms, you must immediately stop using our services. Your continued use of the Platform after any updates to these Terms signifies your acceptance of any changes.

1.3. Who Can Use Our Services

To use our services, you must meet the following conditions:

- You are at least 18 years old or the legal age of majority required in your jurisdiction.
- You do not reside in a country where access to our services is restricted or prohibited.
- You provide accurate and complete information when registering for an account.
- You agree to comply with all applicable laws, including anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
- You do not use our Platform for any illegal, fraudulent, or unauthorised activity.

If we determine that you do not meet these conditions, we reserve the right to suspend or terminate your access without prior notice.

1.4. Changes to These Terms

We may update or modify these Terms from time to time to reflect legal, regulatory, or business changes. If we make significant changes, we will notify you via email or through a notice on our Platform. The latest version of these Terms will always be available on our website, and the date of the last update will be indicated at the top of this document.

It is your responsibility to review these Terms periodically. If you continue to use our services after any updates, you accept the revised Terms. If you do not agree with any changes, you must stop using our Platform and close your account.

For any questions regarding these Terms, please contact us at support@alterswap.ch.

2. COMPANY INFORMATION AND REGULATORY STATUS

2.1. Who We Are

Alterswap AG ("Alterswap," "we," "us," or "our") is a Swiss-registered financial intermediary providing foreign exchange conversion, multi-currency account management, and cross-border payment services to private clients and businesses. Our company is incorporated under the laws of Switzerland, with company registration number CHE-400.153.137, and our registered office is located at Assetstrasse 37, CH 6438, Ibach, Switzerland.

Our mission is to provide secure, compliant, and efficient currency and payment solutions for individuals and businesses operating across borders. We operate as a financial intermediary, not a bank, which means we facilitate transactions but do not hold or manage deposits in the same way that traditional banks do.

2.2. Regulatory Affiliation and Compliance with Swiss Financial Regulations

Regulatory Status and Affiliation with VQF

Alterswap is a Swiss-registered financial intermediary, operating in full compliance with Swiss financial regulations. The company is a member of the Financial Services Standards Association (VQF), a self-regulatory organisation (SRO) officially recognised by the Swiss Financial Market Supervisory Authority (FINMA).

As a VQF-affiliated financial intermediary, Alterswap adheres to Swiss financial market laws and regulatory compliance obligations, ensuring that its operations meet the required standards of security, transparency, and client protection.

Compliance with Swiss Financial Laws

Alterswap operates under the following Swiss regulatory frameworks:

- Swiss Anti-Money Laundering Act (AMLA) — Establishes Alterswap's obligations in detecting, preventing, and reporting money laundering and terrorist financing.
- Swiss Financial Services Act (FinSA) — Regulates financial service providers, requiring risk disclosure, client protection, and fair treatment of Clients.
- Swiss Data Protection Act (FADP) and General Data Protection Regulation (GDPR) — Ensures Alterswap maintains data privacy standards, secure information storage, and client confidentiality.

Know Your Customer (KYC) and Know Your Business (KYB) Requirements

In compliance with AML and KYC/KYB regulations, Alterswap requires Clients to:

- Verify their identity (KYC) before accessing services.
- Submit business verification documents (KYB) for corporate accounts.
- Undergo transaction monitoring to prevent fraudulent activities.
- Provide additional documentation if required for compliance checks.

Failure to meet regulatory compliance requirements may result in account suspension, restricted services, or account termination as outlined in Section 15.

Regulatory Reporting and Legal Obligations

Alterswap is legally required to:

- Report suspicious transactions to relevant Swiss financial authorities.
- Maintain records of Client transactions and compliance reviews as required under AMLA.
- Implement sanctions screening and risk assessments for high-risk jurisdictions.

2.3. Our Relationship with Third-Party Service Providers

To deliver our financial services efficiently and securely, Alterswap collaborates with licensed third-party service providers. These include:

- Regulated banking and financial institutions — for IBAN account issuance and payment processing.
- Liquidity providers — for currency exchange services.
- Compliance and security firms — for customer identity verification, fraud prevention, and AML screening.

When you use certain services on our Platform, your information may be securely shared with these third-party providers to comply with regulatory requirements and facilitate transactions. These partners are carefully selected, fully licensed, and operate under strict Swiss and EU financial regulations.

While we ensure that our partners meet high compliance and security standards, Alterswap is not responsible for the actions, decisions, or policies of any third-party provider. Any agreements, fees, or terms related to third-party services will be clearly disclosed before you proceed with a transaction.

3. DEFINITIONS AND INTERPRETATION

3.1. Key Definitions

For the purposes of these Terms and Conditions, the following definitions apply:

- Account — The account you create with Alterswap, which grants you access to our Platform and services, including multi-currency accounts, FX conversion, and international payment services.

- Client (also referred to as "User" or "you") — Any individual or business entity that registers for an account, accesses our Platform, or uses our services.

- Platform — The website, applications, and digital systems operated by Alterswap that provide financial services, transaction management, and related functionalities.

- Services — The financial intermediary services offered by Alterswap, including foreign exchange conversion, multi-currency account facilitation, cross-border payment processing, IBAN account services, and related financial solutions.

- Transaction — Any financial operation performed through the Platform, including deposits, withdrawals, currency conversions, international payments, and transfers between accounts.

- Business Day — A day (excluding Saturdays, Sundays, and Swiss public holidays) when Alterswap and relevant financial institutions are open for business.

- Currency — Any government-issued legal tender supported by Alterswap, including but not limited to Swiss Francs (CHF), Euros (EUR), US Dollars (USD), Pounds Sterling (GBP), and other currencies made available on the Platform.

- AML/KYC/KYB Compliance — The legal processes we implement to verify the identity of Clients (Know Your Customer — KYC), businesses (Know Your Business — KYB), and ensure compliance with Anti-Money Laundering (AML) laws to prevent financial crime.

- Regulatory Authorities — The Swiss Financial Market Supervisory Authority (FINMA), Financial Services Standards Association (VQF), and any other legal body that governs financial intermediaries and compliance in Switzerland.

- Third-Party Provider — Any external licensed entity that provides banking, payment processing, compliance, or liquidity services on behalf of Alterswap.

- Restricted Jurisdictions — Countries or regions where our services are not available due to regulatory restrictions, sanctions, or compliance limitations. A full list of restricted jurisdictions is provided on our Platform.

- Force Majeure — Any unforeseen event beyond our control that may affect our ability to provide services, including but not limited to natural disasters, regulatory changes, cyberattacks, or economic disruptions.

3.2. Interpretation Guidelines

To ensure legal clarity, the following rules apply when interpreting these Terms:

- Singular and Plural — Words in singular form also include the plural, and vice versa, unless the context requires otherwise.
- Headings for Convenience Only — Section headings are provided for ease of reference and do not affect the interpretation of any provisions.
- No Waiver of Rights — If Alterswap does not immediately enforce a right or provision in these Terms, it does not mean we have waived that right.
- Reference to Laws and Regulations — Any reference to legal provisions, statutes, or regulations includes any amendments, replacements, or updates to those laws.
- Precedence of Specific Terms — If there is a conflict between general terms and specific terms applicable to a particular service, the specific terms shall prevail.
- Language — These Terms are provided in English. If translated versions are available, the English version shall take precedence in case of discrepancies.

By continuing to use our Platform, you confirm that you understand and accept these definitions and interpretation rules as part of our agreement.

4. SCOPE OF SERVICES

4.1. Overview of Financial and Payment Services

Alterswap provides regulated financial intermediary services, offering secure and efficient currency and payment solutions to individuals and businesses. Our services include multi-currency account management, IBAN account facilitation, foreign exchange conversion, and cross-border payment processing.

We enable Clients to manage multi-currency balances, conduct international transactions, and access payment services in compliance with Swiss financial regulations and anti-money laundering (AML) laws. Alterswap operates under the supervision of the Financial Services Standards Association (VQF), ensuring adherence to Swiss regulatory requirements.

4.2. Nature of Alterswap AG as a Financial Intermediary

Alterswap operates as a financial intermediary, meaning we facilitate transactions but do not operate as a bank or provide direct deposit-taking services. Instead, we partner with licensed third-party financial institutions that provide banking infrastructure and payment processing services.

As an intermediary, we are required to comply with Swiss AML laws, conduct identity verification (KYC/KYB), and monitor transactions for fraud and suspicious activity. By using our services, you acknowledge that Alterswap acts as a facilitator between you and licensed financial providers, ensuring compliant transactions.

4.3. IBAN Account Facilitation and Currency Transactions

Alterswap offers Clients the ability to apply for and manage IBAN accounts issued through our licensed banking partners. These accounts allow Clients to send, receive, and hold funds in multiple currencies, supporting both SEPA and SWIFT international transfers.

Key features of our IBAN account services include:

- Personal and Business IBANs — Available for individual and corporate Clients.
- Multi-Currency Support — Hold and transact in CHF, EUR, USD, GBP, and other supported currencies.
- SEPA Transfers — Low-cost and fast transactions within the European Economic Area (EEA).
- SEPA Instant — Real-time EUR transfers within the EEA where supported.
- SWIFT Transfers — International payments outside the SEPA region.
- CHAPS and Faster Payments — GBP domestic and same-day payment options.
- FX Conversion Services — Competitive currency conversion rates for cross-border transactions.

Funds held in IBAN accounts are managed by licensed third-party financial institutions, ensuring regulatory compliance and security. Alterswap does not directly hold Client funds but acts as an intermediary between Clients and regulated banking partners.

4.4. Important Considerations

- Alterswap does not provide banking services or store Client funds directly. All IBAN accounts and payment services are facilitated through licensed third-party institutions.
- Transactions may be subject to processing times, limits, and regulatory requirements, which may vary depending on the Client's jurisdiction and the payment rail used.
- Alterswap reserves the right to modify, add, or discontinue services based on regulatory changes or business needs.
- Alterswap does not provide investment advice, securities custody, or lending services.

5. CLIENT ONBOARDING AND VERIFICATION

5.1. Eligibility Criteria for Opening an Account

To access and use the services of Alterswap, you must meet the following eligibility criteria:

- You must be at least 18 years old or the legal age of majority in your jurisdiction.
- You must be a resident of a supported jurisdiction where Alterswap lawfully offers its services.
- You must have a valid government-issued identification document for identity verification.
- You must provide accurate, complete, and up-to-date personal or business information as required during the onboarding process.
- You must not be subject to any sanctions, restrictions, or prohibitions under Swiss, EU, or international regulations.
- You must not use Alterswap services for any illegal, fraudulent, or unauthorised activity, including but not limited to money laundering, terrorist financing, or financial crimes.

Alterswap reserves the right to refuse service to any applicant who does not meet these eligibility criteria or if we determine that providing services to the applicant would pose a regulatory or compliance risk.

5.2. Know Your Customer (KYC) and Know Your Business (KYB) Requirements

As a Swiss-regulated financial intermediary, Alterswap follows strict Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures. These procedures are required by Swiss financial laws and regulations to ensure the security and legitimacy of transactions.

Individual Clients (KYC Requirements)

To open an account, individual Clients must provide:

- Full legal name (as stated on an official government-issued ID).
- Date of birth and nationality.
- Residential address and proof of residence (e.g., utility bill, bank statement dated within the last three months).
- Valid government-issued identification (passport, national ID card, or driver's licence).
- Biometric or selfie verification as required by our compliance team.
- Source of funds declaration, if required.

Business Clients (KYB Requirements)

For corporate or business accounts, additional documentation is required, including but not limited to:

- Company registration documents (Certificate of Incorporation or equivalent).
- Business address and proof of operational presence.
- Ownership structure details, including information on Ultimate Beneficial Owners (UBOs) holding 25% or more of the entity.
- Proof of directors and authorised signatories, including valid government-issued IDs.
- Tax identification number and regulatory licences (if applicable).
- Description of business activities and expected transaction volumes.

Alterswap reserves the right to request additional documentation based on risk assessments, regulatory changes, or enhanced due diligence (EDD) procedures.

5.3. Verification Procedures and Approval Process

The onboarding process follows a structured verification procedure to ensure compliance with Swiss financial regulations.

1. Registration: Clients begin by submitting their personal or business details through the Alterswap Platform.
2. Identity Verification (KYC/KYB): Clients must upload the required documents for identity and business verification. This includes biometric authentication for individual accounts and corporate documentation review for business accounts.
3. Compliance Review: Alterswap's compliance team conducts an AML risk assessment, including screening against global sanctions lists, politically exposed persons (PEP) lists, and financial crime databases.
4. Approval or Additional Review: If the Client meets all requirements, the account is approved and activated. If additional information is needed, Alterswap may request further documentation or conduct an Enhanced Due Diligence (EDD) review.
5. Account Activation: Once verified, Clients can access the full range of Alterswap services.

Alterswap aims to process verifications promptly; however, timelines may vary depending on document accuracy, risk level, and regulatory review requirements.

5.4. Prohibited Jurisdictions and Restricted Entities

Alterswap does not provide services to individuals, businesses, or entities located in jurisdictions that are:

- Subject to international sanctions, including those imposed by Switzerland, the European Union (EU), the United Nations (UN), the United States (OFAC), and other regulatory bodies.
- Classified as high-risk for money laundering or financial crimes by global financial authorities.
- Known for inadequate AML/CTF regulations or weak enforcement of financial compliance standards.

Additionally, Alterswap does not provide services to entities involved in:

- Unlicensed financial services, such as unauthorised money transmitters or unregulated financial intermediaries.
- Gambling and betting platforms that are unregulated or restricted.
- Darknet marketplaces, illegal substances, or arms trading.
- Fraudulent, deceptive, or high-risk business models.

A full list of prohibited jurisdictions and restricted activities is available on our Platform and may be updated periodically in compliance with regulatory requirements.

5.5. Right to Reject or Terminate Accounts

Alterswap reserves the right to:

- Reject applications that do not meet KYC/KYB requirements or present a compliance risk.
- Suspend or close accounts if false or misleading information is provided.
- Conduct ongoing reviews of Clients and request updated documents to maintain compliance.
- Freeze transactions or report suspicious activity to financial regulators if required by law.

6. CLIENT ACCOUNT TERMS

6.1. Account Ownership and Permitted Usage

When registering an account with Alterswap, Clients are granted a personal, non-transferable right to access and use the Platform in accordance with these Terms.

- Individual accounts must be used solely by the registered account holder.
- Business accounts may be accessed only by authorised representatives designated during the onboarding process.
- Clients must use their accounts only for lawful financial activities.

6.2. Responsibilities of Account Holders

By creating an account, Clients agree to:

- Provide accurate, truthful, and up-to-date information during registration and verification.
- Maintain compliance with AML and KYC/KYB regulations.
- Monitor account activity and report any unauthorised transactions to Alterswap promptly.
- Refrain from using Alterswap services for illegal, fraudulent, or prohibited purposes.

Failure to adhere to these responsibilities may result in account restrictions, additional compliance reviews, or account termination.

6.3. Managing Account Credentials and Security

Clients are responsible for securing their account credentials, passwords, and authentication details.

- Alterswap recommends enabling multi-factor authentication (MFA) for enhanced security.
- The Client must not share credentials with any third party, including Alterswap employees.
- If unauthorised access is suspected, Clients must immediately notify Alterswap at support@alterswap.ch.

Alterswap is not liable for losses arising from compromised account credentials unless directly caused by a security failure on the Platform.

6.4. Client-Initiated Account Closure

Clients may request to close their account at any time by contacting support@alterswap.ch.

Before closing an account:

- All pending transactions must be completed or cancelled.
- Any remaining funds must be withdrawn or transferred to an external account.
- Any outstanding fees or charges must be settled.

Once an account is closed, access to Alterswap services will be permanently revoked.

For involuntary account suspensions or terminations, refer to Section 15.

7. DEPOSITS, TRANSFERS AND WITHDRAWALS

7.1. Funding Methods and Accepted Payment Channels

Alterswap provides multiple funding and withdrawal options, including:

- Bank Transfers (SEPA, SEPA Instant, SWIFT, CHAPS, and Faster Payments): Supported via IBAN accounts for deposits and withdrawals in multiple currencies.
- Internal Transfers: Instant transfers between verified Alterswap Clients on the Platform.

7.2. Processing Timelines and Transaction Limitations

- SEPA Transfers: Processed within 1–2 business days.
- SEPA Instant: Real-time processing where supported by the receiving institution.
- SWIFT Transfers: Typically completed within 2–5 business days, depending on intermediary banking procedures and destination country.
- CHAPS: Same-day processing for GBP payments submitted before daily cut-off.
- Faster Payments: Near-instant GBP processing for supported amounts.
- Internal Transfers: Instant processing for verified Clients on the Platform.

Transaction limits may apply based on account verification status, risk assessments, and compliance reviews.

7.3. Restrictions on Third-Party Transactions

Alterswap does not permit third-party deposits or withdrawals, except for authorised business accounts.

Prohibited activities include:

- Depositing funds from an account not registered in the Client's name.
- Withdrawing funds to an account belonging to an unverified third party.
- Acting as an intermediary for unauthorised transactions.

Business Clients must obtain explicit approval from Alterswap for third-party transaction arrangements.

7.4. General Provisions on Reversals and Refunds

- Once a transaction is processed and submitted to a payment rail, Alterswap cannot guarantee reversals or refunds.
- If a transfer fails due to incorrect account details provided by the Client, recovery is subject to the cooperation of the receiving institution and cannot be guaranteed. Third-party recall fees may apply.
- Refund requests for failed or rejected transactions must be reviewed on a case-by-case basis in compliance with Alterswap's policies.
- International payments are generally irrevocable once submitted to a correspondent banking network. Clients are solely responsible for verifying the accuracy of all beneficiary details before confirming any transaction.

For further details, refer to Section 8.5 (Transaction Processing and General Provisions).

8. PAYMENT SERVICES AND IBAN ACCOUNTS

8.1. Nature of IBAN Account Services Offered

Alterswap provides multi-currency IBAN accounts through regulated banking partners. These accounts allow Clients to send, receive, and manage funds securely in multiple currencies.

Alterswap does not operate as a bank but acts as a regulated financial intermediary facilitating IBAN account access. Funds are held by licensed financial institutions, ensuring security and compliance with Swiss and EU financial regulations.

Through IBAN accounts, Clients can:

- Open personal or business IBANs for secure financial transactions.
- Hold and transact in multiple currencies including CHF, EUR, USD, GBP, and others.
- Execute SEPA, SEPA Instant, SWIFT, CHAPS, and Faster Payments transfers.
- Benefit from automated transaction monitoring and AML screening.

8.2. SEPA, SWIFT, CHAPS and Faster Payments

IBAN accounts support transactions via multiple payment networks, allowing Clients to conduct both domestic and international transfers.

SEPA Transfers (Europe)
- Available for EUR transactions within the European Economic Area (EEA).
- Lower-cost and faster than traditional international wire transfers.
- Typically processed within 1–2 business days.

SEPA Instant (Europe)
- Real-time EUR transfers within the EEA.
- Available where supported by the receiving institution.
- Subject to per-transaction limits set by the payment rail.

SWIFT Transfers (Global)
- Supports cross-border transactions in multiple currencies.
- Processing times typically 2–5 business days depending on destination and intermediary banks.
- May involve correspondent banking fees charged by third-party institutions.

CHAPS and Faster Payments (United Kingdom)
- CHAPS: Same-day settlement for high-value GBP payments.
- Faster Payments: Near-instant GBP transfers for eligible transactions.

All transactions are subject to AML screening and compliance verification.

8.3. Compliance with Banking and Anti-Money Laundering Laws

As a Swiss-regulated financial intermediary, Alterswap follows strict AML and KYC requirements for all payment and account services.

- Mandatory identity verification (KYC/KYB) before account activation.
- Transaction monitoring to detect fraudulent or suspicious activities.
- Compliance with global sanctions screening, including OFAC, EU, and Swiss authorities.
- Reporting obligations for suspicious transactions as required by applicable law.

8.4. FX Conversion Services

Alterswap provides foreign exchange conversion services across 150+ currency pairs. FX conversions are executed at rates based on live interbank market data, with a transparent spread applied per transaction. All indicative rates are valid for a limited period and are confirmed at the time of execution.

Clients are advised to review the applicable rate carefully before confirming any conversion. Alterswap accepts no liability for exchange rate movements that occur between the time of an indicative quote and the time of execution.

8.5. Transaction Processing and General Provisions

- All transactions are processed in accordance with Alterswap's internal policies, regulatory requirements, and third-party banking and payment partner agreements.
- Alterswap is not liable for unsuccessful or delayed transactions caused by external banking networks, payment rail outages, or third-party processing delays.
- Refunds or reversals, if applicable, will be processed according to the policies of our banking and payment partners.
- Transaction processing times depend on banking hours, payment rail operating schedules, and compliance verification requirements.
- Additional verification may be required for high-value or high-risk transactions, which may result in processing delays.
- Clients are responsible for ensuring the accuracy of all recipient details before initiating any transfer.
- Alterswap reserves the right to decline transactions deemed high-risk or non-compliant with applicable regulations.

9. FEES, COMMISSIONS AND CHARGES

9.1. Structure of Service Fees and Transaction Costs

Alterswap applies transparent fees to its financial services, which may include charges for transactions, currency conversions, payment processing, and account services.

General fee categories include:

- Transaction Fees: Charges for bank transfers, international payments, and currency conversions.
- Account-Related Fees: Certain account types, including corporate and premium accounts, may be subject to monthly or annual service fees.
- FX and Conversion Fees: Currency exchange transactions may include a foreign exchange spread based on live market rates. Pricing is shown clearly before you confirm any conversion.
- Compliance-Related Fees: Enhanced due diligence (EDD), document processing, or regulatory reporting requirements may incur additional charges where applicable.

Alterswap reserves the right to adjust fees periodically based on regulatory requirements, third-party costs, and operational changes.

9.2. Fee Adjustments and Notifications

Fee structures may be reviewed and modified by Alterswap at its discretion. When fees are updated:

- Clients will receive prior notification through official communication channels.
- The latest fee structure will be available on the Alterswap Platform.
- Continued use of Alterswap services after a fee update constitutes acceptance of the revised fees.

For full details on how amendments to Terms and Conditions are handled, refer to Section 17 (Amendments and Updates).

10. RISK DISCLOSURES AND LEGAL NOTICES

10.1. General Financial Risk Factors

All financial transactions, including foreign exchange conversion and cross-border payments, carry inherent risks. Clients should be aware of:

- Market Fluctuations: Currency exchange rates may change unpredictably in response to economic, political, and market conditions.
- Economic and Political Risks: Global events, central bank policy decisions, and government regulations may impact the cost, speed, or availability of financial services.
- Liquidity Constraints: Under certain market conditions, liquidity in specific currency pairs may be reduced, which could affect the availability or pricing of FX conversions.

Alterswap does not guarantee the profitability or performance of any financial transaction.

10.2. No Guarantee of Outcomes

Alterswap does not provide investment advice or trading recommendations. Clients acknowledge that:

- Past exchange rates and payment performance do not guarantee future results.
- Losses may occur due to exchange rate movements or the timing of currency conversions.
- All financial decisions made in connection with Alterswap's services are made solely at the Client's discretion and risk.

For detailed risk disclosures, please refer to Alterswap's standalone Risk Disclosure document, available on the Platform.

10.3. Compliance Obligations and Reporting

Alterswap operates under Swiss financial market regulations and complies with:

- AML (Anti-Money Laundering) and CTF (Counter-Terrorist Financing) laws.
- Transaction monitoring and reporting obligations to regulatory authorities.
- Data privacy laws, including the Swiss Data Protection Act (FADP) and GDPR.

Suspicious activities may be reported to relevant Swiss authorities or financial regulators as required by law.

11. CLIENT RESPONSIBILITIES AND PROHIBITED ACTIVITIES

11.1. Compliance with Local Laws and Regulations

By using the services provided by Alterswap, Clients agree to comply with all applicable Swiss laws, European regulations, and international financial compliance standards. Clients are responsible for ensuring that their use of Alterswap's Platform and services is lawful in their respective jurisdictions.

Key compliance responsibilities include:

- Adhering to Swiss Anti-Money Laundering (AML) laws and Counter-Terrorist Financing (CTF) regulations.
- Ensuring that all funds transacted through Alterswap originate from legitimate and identifiable sources.
- Complying with tax reporting obligations in their respective countries of residence or incorporation.
- Providing accurate and truthful information during registration, verification, and transactions.
- Respecting international sanctions and trade restrictions enforced by Swiss authorities, the EU, the UN, and other regulatory bodies.

Failure to comply with these legal and regulatory requirements may result in account restrictions, termination, or referral to the relevant legal authorities as required by Swiss law.

11.2. Prohibited Uses of Alterswap Services

Clients are strictly prohibited from using Alterswap's services for any illegal, fraudulent, or unauthorised activities. This includes, but is not limited to:

- Money laundering, terrorist financing, or any form of financial crime.
- Fraudulent transactions, identity theft, or the use of falsified documents.
- Circumventing economic sanctions or engaging with restricted entities or jurisdictions.
- Darknet market transactions or illicit financial schemes.
- Unlicensed gambling, unauthorised financial services, or pyramid schemes.
- Any attempt to interfere with, exploit, or abuse Alterswap's platform, systems, or services.

If Alterswap identifies any suspicious or prohibited activity, the Client's account may be immediately suspended, funds may be frozen, and regulatory authorities will be notified where required by law.

11.3. Activities Leading to Account Suspension or Termination

Alterswap reserves the right to suspend, restrict, or terminate a Client's account without prior notice if any of the following occurs:

- Violation of these Terms and Conditions.
- Failure to provide accurate or truthful verification documents.
- Engagement in prohibited financial activities.
- Attempts to manipulate, exploit, or abuse Alterswap's services.
- Providing misleading information to avoid compliance checks.
- Use of Alterswap's services in jurisdictions where they are restricted or prohibited.

Clients whose accounts are suspended or terminated will be notified and may be required to complete additional verification or compliance procedures before any potential reinstatement of services. Alterswap reserves the right to retain and report account records as required by applicable law.

11.4. Reporting Suspicious Activities

To maintain a secure and compliant financial environment, Clients are encouraged to report any suspicious activity they observe in connection with Alterswap's services. This includes:

- Unauthorised access attempts or suspicious account activity.
- Suspected fraudulent transactions or financial crime.
- Requests from third parties to use your account for unknown or unexplained transactions.
- Any attempts to bypass or circumvent compliance verification procedures.

Clients can report suspicious activities directly to support@alterswap.ch. Alterswap will review all reports and take necessary action, including notifying Swiss regulatory authorities where required.

12. SECURITY AND DATA PROTECTION

12.1. Security Measures and Fraud Prevention Policies

Alterswap employs security protocols to safeguard Client accounts, transactions, and personal data. Our security framework includes fraud detection, multi-layer authentication, and continuous monitoring to prevent unauthorised access.

Key security measures include:

- Multi-Factor Authentication (MFA): Clients are strongly encouraged to enable MFA for additional account protection.
- Automated Fraud Detection: Real-time monitoring systems analyse transactions to detect unusual or high-risk activity patterns.
- Encryption and Data Protection: Sensitive data is protected with AES-256 encryption and TLS security protocols.
- Regular Security Audits: Alterswap conducts internal and external security assessments to ensure ongoing compliance with security best practices.

12.2. Handling of Client Data and Personal Information

Alterswap processes personal data in accordance with Swiss and EU data protection laws, including:

- Swiss Federal Act on Data Protection (FADP)
- General Data Protection Regulation (GDPR)

Data Usage and Protection Policies:

- Client data is used only for legitimate business, legal, and compliance purposes.
- Personal information is not shared with unauthorised third parties.
- Data is stored securely and retained only for the duration required by applicable law.

Clients may request access, modification, or deletion of their personal data in accordance with GDPR and FADP requirements. For further details regarding data protection rights, please refer to our Privacy Policy.

12.3. Cybersecurity Protocols

Alterswap uses security technologies to protect Client data:

- End-to-End Encryption: AES-256 encryption for secure data storage and transmission.
- Secure Socket Layer (SSL) and TLS: Ensuring data integrity during online interactions.
- Multi-Factor Authentication: Required for account access and sensitive operations.

Alterswap will never request sensitive information such as passwords, account credentials, or authentication codes via email or phone. Clients are advised to remain vigilant against phishing attempts and fraudulent communications purportedly from Alterswap. Any suspected security incidents should be reported immediately to support@alterswap.ch with the subject line: "URGENT: SECURITY ISSUE."

13. THIRD-PARTY SERVICES AND PARTNERSHIPS

13.1. Relationship with Partner Institutions

Alterswap collaborates with regulated third-party financial institutions, liquidity providers, and payment processors to facilitate its services. These partnerships enable access to:

- IBAN account services via licensed banking partners.
- Foreign exchange and currency liquidity providers.
- Identity verification and compliance screening solutions.
- Segregated client fund custody via licensed banking institutions.
- Payment processing networks for bank transfers and international payments.

Alterswap does not directly control or operate these third-party services but acts as a regulated intermediary facilitating Client access to them.

13.2. Liability Disclaimers for Third-Party Services

While Alterswap facilitates access to third-party services, it is not responsible for the performance, availability, or terms of those services.

Clients acknowledge and accept the following:

- Alterswap shall not be held responsible for financial losses, transaction failures, or regulatory issues arising from the services of external third-party providers.
- Alterswap is not liable for service disruptions, operational failures, or policy changes made by third-party banking partners, liquidity providers, or payment processors.
- Alterswap does not guarantee the security, speed, or accuracy of transactions processed by third-party services.
- Alterswap AG shall not be liable for any regulatory enforcement, sanctions, or legal actions taken against third-party service providers, even if such providers are integrated into Alterswap AG's platform.
- Clients are responsible for reviewing and agreeing to the terms and conditions of third-party service providers before using them.
- Any disputes regarding failed transactions, incorrect payments, or service interruptions related to third-party providers must be resolved directly with the respective provider.

13.3. Client Obligations When Engaging with External Providers

Clients using third-party services through Alterswap must adhere to the policies and compliance requirements of those external providers.

Client responsibilities include:

- Providing accurate and verifiable information to third-party services.
- Understanding the terms, risks, and conditions of third-party financial services before initiating transactions.
- Accepting that additional fees, compliance checks, or service limitations may be imposed by third-party providers.

Failure to comply with third-party service policies may result in transaction delays, account restrictions, or denied service requests. Alterswap reserves the right to terminate or restrict access to third-party services for Clients who fail to meet compliance obligations.

14. DISPUTE RESOLUTION AND COMPLAINTS HANDLING

14.1. Internal Process for Handling Client Disputes

Alterswap is committed to fair and efficient dispute resolution. Clients who encounter issues related to transactions, account management, or service performance should follow this process:

1. Initial Inquiry: Clients should review the relevant Terms, policies, and FAQs to determine if their issue can be resolved without formal escalation.
2. Filing a Complaint: If the issue persists, Clients may submit a formal complaint to support@alterswap.ch including a detailed description of the dispute, transaction IDs and timestamps, supporting documentation, and any prior communication with Alterswap regarding the issue.
3. Investigation and Review: Alterswap will acknowledge receipt of the complaint and conduct an internal review.
4. Resolution and Response: Clients will receive a written response outlining the findings and proposed resolution.

All disputes will be handled fairly and impartially under Swiss financial regulations.

14.2. Communication Methods and Response Times

Clients may contact Alterswap through the following channels for disputes and complaints:

- Email: support@alterswap.ch (primary contact for formal complaints)
- Registered Office Address: Alterswap AG, Assetstrasse 37, CH 6438, Ibach, Switzerland

Response Timeframes:
- Complaint acknowledgement: Within 2 business days
- Investigation and response: Within 10 business days
- Complex cases requiring additional review: May take up to 30 business days

Clients will be informed if additional time is required for resolution.

14.3. Escalation of Unresolved Disputes

If a Client is not satisfied with the resolution provided by Alterswap, they may escalate the dispute for independent mediation or arbitration in accordance with Swiss law.

Escalation to VQF

Alterswap is affiliated with the Financial Services Standards Association (VQF). In the event of a dispute that cannot be resolved internally, Clients may initiate proceedings under the VQF Arbitration Regulations.

To qualify for VQF escalation:
- Clients must first exhaust Alterswap's internal dispute resolution process and receive a final written response.
- A formal complaint must be submitted to VQF in writing, including all relevant documentation and proof of the prior attempt at resolution.

Ombudsman Service

In accordance with the Swiss Financial Services Act (FinSA), Clients also have the right to contact a recognised Ombudsman — specifically FINOS (Finanzombudsstelle Schweiz) — for a mediation procedure, which is generally free of charge or low-cost for the consumer.

For more details on VQF's role, refer to Section 18.3.

15. ACCOUNT SUSPENSION, TERMINATION AND CLOSURE

15.1. Grounds for Account Suspension or Termination

Account Suspension

An account may be temporarily suspended if:

- Suspicious or potentially fraudulent activity is detected.
- The Client fails to provide required verification documents within a reasonable timeframe.
- The account is inactive for an extended period and requires reverification.
- The Client is under regulatory or compliance review.

During suspension, access to Alterswap services may be limited or blocked until the issue is resolved.

Account Termination by Alterswap

Alterswap may permanently terminate an account if:

- The Client violates these Terms and Conditions.
- The Client engages in fraud, money laundering, or financial crimes.
- The Client provides false or misleading information during onboarding or compliance reviews.
- The Client fails to comply with Swiss AML/CTF regulations.

In cases of regulatory violations, Alterswap may be required to report the Client to the relevant financial authorities.

15.2. Handling of Remaining Funds Upon Termination

If an account is closed or terminated:

- The Client must withdraw all available funds before account closure where possible.
- If Alterswap terminates the account, funds may be returned to the Client via an approved withdrawal method, held temporarily for regulatory review or fraud investigations, or reported to regulatory authorities if required by law.

Funds may be forfeited if a Client fails to respond to compliance requests or regulatory inquiries within a reasonable timeframe.

15.3. Right to Appeal and Dispute Resolution

Clients may dispute an account suspension or termination decision by submitting a written request to support@alterswap.ch.

- Appeals will be reviewed within 10 business days.
- Alterswap reserves the right to deny reinstatement requests if the termination was due to regulatory violations or financial crime.

For further details regarding disputes, refer to Section 14 (Dispute Resolution and Complaints Handling).

16. FORCE MAJEURE

16.1. Limitations of Liability During Force Majeure Events

Alterswap shall not be held liable for any failure or delay in performing its obligations under these Terms if such failure or delay results from events beyond its reasonable control ("Force Majeure Events"). These events include, but are not limited to:

- Natural disasters (earthquakes, floods, fires, extreme weather conditions).
- Acts of war, terrorism, or civil unrest.
- Government actions, regulatory changes, sanctions, or embargoes.
- Cybersecurity incidents, including hacking, DDoS attacks, or data breaches.
- Banking system failures, payment rail outages, market disruptions, or liquidity shortages.
- Pandemics, health crises, or widespread power or communications outages.

During a Force Majeure Event, Alterswap shall not be liable for losses, delays, or disruptions affecting transactions, account access, or service availability.

16.2. Impact of Force Majeure on Fees and Charges

- During a Force Majeure Event, Alterswap reserves the right to suspend services partially or entirely, depending on the severity of the disruption.
- Any fees, charges, or obligations already incurred before the event remain due unless explicitly waived by Alterswap.
- If services are suspended, Clients will be notified of any adjustments to billing cycles, transaction processing times, or applicable charges.

16.3. Company Obligations in Unforeseen Circumstances

Alterswap will take reasonable steps to minimise disruptions and resume normal operations as soon as circumstances allow. In the event of a prolonged Force Majeure Event, Alterswap may:

- Temporarily suspend or modify transaction processing to maintain financial security.
- Implement alternative solutions to mitigate risks affecting Client accounts.
- Notify Clients via email or platform updates regarding service adjustments.

Alterswap shall not be liable for any indirect or consequential losses arising from a Force Majeure Event, including exchange rate fluctuations or market losses occurring during a period of service disruption.

17. AMENDMENTS AND UPDATES

17.1. Company Rights to Modify Terms and Conditions

Alterswap reserves the right to modify, update, or amend these Terms and Conditions as necessary to comply with:

- Changes in Swiss and international financial regulations.
- Updates to company policies, services, or compliance requirements.
- Adjustments due to banking partnerships or third-party service provider terms.

Alterswap will ensure that Clients are informed of significant updates in a timely manner.

17.2. Notification Processes for Updates

Changes to these Terms will be communicated through:

- Email notifications to registered Clients.
- Platform announcements via the Alterswap dashboard.
- Updated Terms published on the Alterswap website.

Where legally required, Clients may be asked to acknowledge acceptance of the updated Terms before continuing to use services.

17.3. Relationship to Fee Modifications

- Changes specifically related to fees and charges are managed in accordance with Section 9 (Fees, Commissions and Charges).
- Clients should review fee updates regularly to stay informed of applicable costs for services.

Clients who do not agree with updated Terms or fee adjustments may discontinue use of Alterswap services and request account closure.

18. GOVERNING LAW AND JURISDICTION

18.1. Applicable Swiss Laws and Regulations

These Terms and Conditions, as well as all transactions and services provided by Alterswap, are governed by and interpreted in accordance with the laws of Switzerland.

Alterswap AG operates as a Swiss financial intermediary in accordance with FINMA guidelines, ensuring compliance with financial intermediary regulations and applicable Swiss laws. Alterswap is subject to the following legal and regulatory frameworks:

- Swiss Financial Market Supervision Act (FINMASA) — Governing financial market regulations.
- Swiss Anti-Money Laundering Act (AMLA) — Ensuring compliance with AML and CTF obligations.
- Swiss Financial Services Act (FinSA) — Regulating financial services and client protection.
- Swiss Data Protection Act (FADP) and General Data Protection Regulation (GDPR) — Ensuring the security and confidentiality of client data.

18.2. Dispute Resolution Within Swiss Jurisdiction

Any dispute, claim, or controversy arising out of or in connection with these Terms, including the validity, breach, or termination thereof, shall be resolved under Swiss law.

- Primary Dispute Resolution: Clients must first attempt to resolve disputes through Alterswap's internal dispute resolution process (see Section 14).
- Jurisdiction: If a dispute cannot be resolved internally, it shall be subject to the exclusive jurisdiction of the competent courts of Switzerland, unless otherwise required by mandatory legal provisions.
- Legal Proceedings: All legal proceedings shall be conducted in Zurich, Switzerland, or another designated Swiss jurisdiction.

Clients acknowledge that Alterswap is not liable for legal claims that fall outside Swiss regulatory authority or jurisdiction.

18.3. Dispute Resolution and Escalation Through VQF

If a dispute remains unresolved after following Alterswap's internal dispute resolution process (outlined in Section 14), Clients may escalate the matter for independent review.

Independent Mediation (Ombudsman)

In accordance with the Swiss Financial Services Act (FinSA), Alterswap is affiliated with a recognised mediation body. Clients have the right to initiate a mediation procedure through the Finanzombudsstelle Schweiz (FINOS), which serves as a neutral, out-of-court mediator to resolve legal disputes between financial service providers and their clients.

Contact Information for FINOS:
- Finanzombudsstelle Schweiz (FINOS)
- Address: Talstrasse 20, 8001 Zürich, Switzerland
- Website: www.finos.ch

Regulatory Oversight (VQF)

Alterswap is a member of the Financial Services Standards Association (VQF), which acts as a self-regulatory organisation (SRO) officially recognised by FINMA. The VQF ensures that its members comply with Swiss anti-money laundering laws and professional codes of conduct.

Contact Information for VQF:
- Financial Services Standards Association (VQF)
- Address: Gubelstrasse 11, 6300 Zug, Switzerland
- Website: www.vqf.ch

For more details on filing a complaint with Alterswap, refer to Section 14.

19. CLIENT SUPPORT AND CONTACT INFORMATION

19.1. Official Communication Channels

Clients can contact Alterswap for account-related inquiries, compliance requests, and security concerns through the following channels:

- Email Support: support@alterswap.ch
- Registered Office Address: Alterswap AG, Assetstrasse 37, CH 6438, Ibach, Switzerland

Alterswap will never ask for passwords, account credentials, or authentication codes via email or phone. Clients should verify any communication claiming to be from Alterswap before responding.

19.2. Support Availability and Response Times

Alterswap provides dedicated client support during standard business hours.

Support Hours:
- Monday to Friday: 9:00 AM – 6:00 PM CET
- Support inquiries received outside business hours will be addressed on the next business day.

Response Timeframes:
- General inquiries: 1–2 business days
- Compliance and KYC/KYB verification issues: 3–5 business days
- Complex cases requiring regulatory review: Up to 10 business days

Every Alterswap client is assigned a dedicated relationship manager upon completing onboarding. Your manager is your direct point of contact for account queries and time-sensitive payment support. You can reach them directly or contact our team at support@alterswap.ch to arrange a call.

Alterswap prioritises urgent security-related issues. Clients experiencing account security concerns should include "URGENT: SECURITY ISSUE" in their support request subject line.

19.3. Escalation Procedures for Unresolved Issues

If a Client's issue is not resolved through standard support channels, the following escalation process applies:

1. Primary Support: Clients should submit their concerns to support@alterswap.ch, providing all relevant details and supporting documentation.
2. Escalation Request: If the issue remains unresolved, Clients may request review by a senior support manager.
3. Formal Complaint Submission: If unsatisfied with Alterswap's response, Clients may escalate their complaint through the formal dispute resolution process outlined in Section 14.
4. Regulatory Mediation: If necessary, disputes may be escalated to the Financial Services Standards Association (VQF) or the recognised Swiss Ombudsman (FINOS) for independent mediation or arbitration in accordance with VQF regulations.

For security-related issues such as unauthorised access, account breaches, or fraudulent activity, Clients should immediately report the issue to support@alterswap.ch with the subject line: "URGENT: SECURITY ISSUE."

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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