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Privacy Notice

Atlas Pre-Seed Programme · Administered via SWC Field (KEYSTRA Ltd.)

Privacy Notice

Effective Date: 26 August 2026

1. Controller

The controller of personal data processed through the SWC Field platform is KEYSTRA Ltd., an International Business Company incorporated in the Republic of Seychelles on 17 March 2026 under the International Business Companies Act 2016, registration number C984038, registered office at Suite 9, Ansuya Estate, Revolution Ave, Victoria, Seychelles.

Data subject requests may be submitted through the SWC Personal Account or by email to the Administrator at compliance@swcfield.com.compliance@swcfield.com

2. Personal Data We Process

Identity and contact details; account information and User ID; KYC/AML documents and results; sanctions and PEP status; payment and contract information; technical logs, IP address, device and cookie data; and information contained in enquiries and complaints.

3. Purposes and Legal Bases

Processing is necessary to respond to an application, verify eligibility, enter into and perform the agreement, prevent fraud, comply with AML/KYC and sanctions requirements, maintain the Register, handle complaints, protect legal rights and ensure platform security. Consent is obtained where required.

4. Recipients

Data may be disclosed, strictly to the extent necessary, to the Seller for entering into and performing the agreement; Veriff for identity verification; banks and payment institutions; technical and professional service providers; auditors and advisers; courts, arbitral tribunals and competent authorities.

5. International Transfers

Because the Administrator is incorporated in Seychelles, the Seller is located in the UAE and service providers may operate in other countries, data may be transferred internationally subject to contractual, organisational and technical safeguards.

6. Retention Period

Data is retained for the term of the agreement and thereafter for as long as necessary for KYC/AML, accounting, dispute resolution and the protection of legitimate interests. It is then deleted or anonymised unless further retention is required by law.

7. Rights

A data subject may request access, rectification, erasure or restriction of processing, object to processing, withdraw consent and request data portability where the relevant right is available under applicable law. Certain requests may be restricted by mandatory AML/KYC or evidentiary requirements.

8. Automated Checks

The results of automated and semi-automated checks are used for risk assessment. A rejection may be reviewed by an authorised member of staff upon a request submitted through the Personal Account, unless disclosure of the reasons is prohibited by law.

Published programme document. If a later signed version is issued by the parties, that version prevails in case of conflict.