Privacy Policy

1. Data controller

The data controller responsible for the processing of your personal data is AKIRA RYU GmbH, domiciled in Switzerland. For any privacy-related queries, please contact us at info@akiraryu.com.

2. Data we collect

We collect personal data only to the extent necessary to fulfil the purposes described in this policy. The categories of data we may collect include:

• Identity data — name, title, company name and role
• Contact data — email address, telephone number and postal address
• KYC data — government-issued identity documents, proof of address, source of funds and beneficial ownership declarations, collected as required by our AML obligations
• Transaction data — details of mandates, assets, financial terms and correspondence related to a transaction
• Technical data — IP address, browser type and basic usage data when you visit our website

We do not collect sensitive personal data (such as health, political or religious information) and we do not engage in automated decision-making or profiling.

3. How we use your data

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

• Performance of a contract — to manage and execute mandates you have engaged us for
• Legal obligation — to comply with AML, KYC and sanctions screening requirements under Swiss law and applicable international standards
• Legitimate interests — to communicate with you about mandates and transactions, to maintain our business records and to protect our legal rights
• Consent — where you have specifically agreed to receive communications from us

4. Data sharing

We do not sell, rent or trade your personal data. We may share your data with:

• Counterparties — only with your knowledge and in the context of a specific mandate, and only after applicable NDA and KYC requirements have been met
• Legal and compliance advisors — where necessary to structure a transaction or fulfil our regulatory obligations
• Regulatory authorities — where required by law or court order

Any third parties with whom we share data are bound by appropriate confidentiality obligations.

5. Data retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, and in any event for a minimum of ten years following the completion or termination of a mandate, as required by Swiss AML regulations. KYC documentation is retained for the period prescribed by applicable law.

6. Your rights

Subject to applicable law, you have the following rights in relation to your personal data:

• Right of access — to request a copy of the data we hold about you
• Right to rectification — to request correction of inaccurate data
• Right to erasure — to request deletion of your data where there is no legitimate basis for continued processing
• Right to restriction — to request that we limit the processing of your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests

To exercise any of these rights, please contact us at info@akiraryu.com. We will respond within 30 days.

7. International transfers

Given the international nature of our business, your data may be transferred to and processed in countries outside Switzerland and the European Economic Area. Where such transfers occur, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the relevant authorities.

8. Cookies and website data

Our website uses no marketing or tracking cookies. We collect only basic technical data (such as IP address and browser type) for security and performance purposes. This data is not used to identify individual visitors and is not shared with third parties for marketing purposes.

9. Governing law

This privacy policy is governed by Swiss law, including the Federal Act on Data Protection (FADP/nDSG), and is designed to be consistent with the requirements of the EU General Data Protection Regulation (GDPR) where applicable.