Privacy Policy | OnchainTA Digital Transfer Agent

Overview

OnchainTA safeguards customer information and disposes of it securely as required of SEC-registered transfer agents, including under Regulation S-P. We do not disclose nonpublic personal information to unaffiliated third parties except as described in this Policy or as permitted or required by law.

Akemona TA Services, LLC, a Delaware limited liability company doing business as OnchainTA ("OnchainTA," "we," "us" or "our"), is an SEC-registered transfer agent for tokenized securities and a subsidiary of Akemona, Inc., the software engineering company that develops the platform OnchainTA uses.

This Policy explains how OnchainTA collects, uses, discloses, protects and retains information about visitors, issuers, investors, securityholders, authorized representatives and other users of https://onchainta.com, related websites and applications, and our digital transfer agent services (the "Service"), including Issuer Hub, Investor Portal, tokenized securities registration and servicing, cap table tokenization and CapMark AI.

When we act for an issuer. When we act as transfer agent for an issuer, we process its securityholders' information on the issuer's behalf, under its instructions and our own legal obligations. The issuer's privacy notice also applies to that information.

We do not sell or share personal information for advertising. Some records must be retained or processed to meet legal and regulatory obligations even after an account closes or consent is withdrawn.

Information We Collect

We collect information you provide, information submitted by issuers or authorized transfer agents, information from identity-verification and compliance providers, and information generated when you use the Service. Depending on your role, this may include:

Name, date of birth, contact details and mailing or residence address.
Social Security number, taxpayer identification number or other government identification, where required.
Email address, telephone number, account identifiers and authentication information.
Onboarding records, authorized-representative details and KYC/KYB/AML information.
Securities and financial information, such as issuer relationships, registered holdings, security classes, allocations, restrictions, subscriptions, transfers, payments, distributions and corporate-action records.
Public wallet addresses and wallet activity associated with supported tokenized securities.
IP address and the approximate location derived from it, device and browser data, cookies, usage metrics and diagnostic logs.
Support communications, uploaded documents, instructions, certifications, approvals and audit history.
Where you use CapMark or other AI features, your prompts, messages, uploads, outputs and related workflow history.

We request sensitive information only where a particular service or legal requirement calls for it. If you provide information about another person, you confirm you have authority to do so.

Cookies

We use cookies and similar technologies for sign-in, preferences, security and fraud prevention. Some cookies are necessary for authenticated features and are always on. Analytics cookies are optional: we use Google Analytics to understand website use and improve our services only if you accept analytics cookies. If you decline, we do not load Google Analytics or collect analytics data about you. You can change your choice at any time through the Cookie Settings link in the website footer. We store your choice in a cookie on your device and ask again when it expires, no more than 60 days after your last visit. You can reject or delete cookies in your browser, though some features may not work. Device, IP and cookie identifiers may be personal information depending on context.

Usage Data

We automatically receive information such as IP address, browser and operating system, device identifiers, pages visited, timestamps, event logs and diagnostics. We use it to operate, troubleshoot, secure and improve the Service. We also infer approximate location, such as country or region, from IP addresses, for example to apply jurisdiction-based eligibility rules and to detect suspicious activity. We do not request precise location from your device.

How We Use Information as a Digital Transfer Agent

We use information to:

Provide, administer, secure and improve the Service.
Register and service tokenized securities, maintain securityholder records, and process authorized issuance, cancellation, transfer, replacement, distribution and corporate-action requests.
Perform onboarding, identity verification, KYC/KYB/AML and sanctions screening, eligibility review and fraud prevention.
Enable issuers, investors and authorized transfer agents to use the relevant portals and workflows.
Carry out issuer instructions and communicate with authorized parties, subject to our transfer agent duties and the securities' governing documents.
Handle support requests, complaints, discrepancies and security incidents.
Support payments, escrow coordination, investor communications and integrations where enabled.
Comply with recordkeeping, audit, examination, investigation and legal process requirements.
Operate AI-enabled features you choose to use.
Send service announcements and, subject to your choices, marketing communications.

OnchainTA will never ask for your wallet private key or recovery phrase.

Transfer Agent Records Off-Chain, Tokenized Securities On-Chain

Off-chain. Personally identifiable information, identity-verification and KYC/KYB/AML records, tax identifiers, contact information and other sensitive investor records are kept in secured private systems off-chain, available only to authorized personnel and parties with appropriate access and legal grounds.

On-chain. For tokenized securities, public blockchains record pseudonymous wallet addresses, token balances, transfers and smart-contract events. OnchainTA does not publish investors' identities, KYC files or tax identifiers on public blockchains. Pseudonymous does not mean anonymous: wallet activity can sometimes be linked to a person using outside information, and public blockchain records may be permanent and beyond OnchainTA's ability to change or delete.

DigitalCapTable. DigitalCapTable intentionally publishes organizational information under its own notices; it does not publish personal KYC information.

Artificial Intelligence

Information you submit to AI-enabled features, including CapMark, may be processed by our AI and large language model service providers under contractual safeguards. Submit only information you are authorized to share. AI outputs may require review and approval by authorized users and professional advisers.

We may disclose information, subject to applicable law and appropriate safeguards, to:

Issuers and authorized transfer agents, to administer their securities, fulfill authorized functions and reconcile records.
Akemona, Inc. and our affiliates, for platform development, hosting, support, compliance and security, under access and confidentiality controls.
Service providers, such as hosting, KYC/KYB and sanctions screening, payment, banking, escrow, analytics and support providers, where needed to provide or secure the Service.
AI service providers, to support AI features you use.
Direct Transfer counterparties. When you accept another participant's request to negotiate, each of you sees the other's name; when the transfer executes, each sees the other's wallet address. Your name goes only to that counterparty, and only after you agree to proceed. Wallet addresses and their transactions are also publicly visible on public blockchains, as described below.
Search services and state unclaimed property administrators. We may use search services to locate securityholders we have lost contact with, as transfer agents are required to do. Where state unclaimed property laws require it, we report information to, and deliver securities or distributions to, state administrators.
Tax authorities, where we administer distributions that require reporting.
Regulators, courts and law enforcement, to comply with law, legal process, SEC examinations and regulatory requests.
Professional advisers, such as auditors and legal counsel, under confidentiality obligations.
Parties to a corporate transaction, such as a merger, acquisition or reorganization, subject to applicable notice requirements.
Others, to protect rights and safety, including investigating wrongdoing, preventing fraud and enforcing our terms.

Public blockchains also make pseudonymous wallet addresses, balances and transactions visible, as described above; that is not a disclosure of our private records.

Security

We protect information with administrative, technical and organizational safeguards appropriate to a registered transfer agent. Sensitive information is encrypted in storage and in transit, and access is limited by role and need. We oversee service providers that handle customer information. No system is completely secure, so we cannot guarantee that unauthorized access will never occur.

If sensitive information about you is accessed or used without authorization, we will notify you as required by law, including within the time Regulation S-P requires. Report suspected unauthorized account activity to support@onchainta.com and suspected vulnerabilities to security@onchainta.com. More information is on our Security & Data Protection page.

Your Choices and Rights

Subject to applicable law, identity verification and regulatory obligations, you may ask us to:

Tell you what personal information we hold about you.
Correct or update inaccurate information.
Delete information that is eligible for deletion.
Stop sending you marketing communications (you can also use the unsubscribe link in any marketing email).

Contact support@onchainta.com. We may need to verify your identity or authority and coordinate with the issuer. Official ownership records, identity-check records, transaction history, audit trails and blockchain records may be retained to meet transfer agent, securities-law, fraud-prevention and litigation-hold obligations; corrections may be made by controlled amendment rather than deletion. We will not discriminate against you for exercising your privacy rights.

If you do not provide required information, we may be unable to open an account, process a transfer or provide a service. That does not affect your existing rights in securities you hold.

Data Retention

We keep personal information and business records for as long as needed for the purposes in this Policy and as required by law, including SEC transfer agent recordkeeping rules, contracts, audits, investigations, dispute resolution and litigation holds. Certain regulated and offering-related records, including records of AI-assisted offering workflows, may be kept for at least six years or longer where required; retention periods vary by record type. Usage data is generally kept for shorter periods. Closing an account does not erase securityholder records or blockchain transactions.

International Transfers

Your information may be processed in the United States and other locations where OnchainTA, Akemona and our service providers operate. Where required, we use appropriate safeguards for cross-border transfers.

Where the GDPR applies, we rely on performance of a contract, compliance with legal obligations, legitimate interests not overridden by your rights, and consent where required. You may have rights of access, correction, erasure, restriction, objection and portability, subject to legal exceptions. Contact support@onchainta.com.

California Privacy and Do Not Track

Where California privacy law applies, California residents may have rights to know, correct and delete personal information, subject to statutory exceptions, including for information covered by federal financial privacy law. We do not sell or share personal information. The Service does not respond to Do Not Track signals.

Children

The Service is not directed to children under 18, and we do not knowingly collect their information.

Changes to This Policy

We may update this Policy and will post the revised version with a new date, giving additional notice where required by law.

Contact Us

Akemona TA Services, LLC, doing business as OnchainTA · SEC-registered digital transfer agent for tokenized securities · Subsidiary of Akemona, Inc.

Privacy questions and rights requests: support@onchainta.com Security vulnerabilities: security@onchainta.com Mailing address: Akemona TA Services, LLC, 651 N. Broad St., Suite 206, Middletown, DE 19709

Related: Terms of Use, Security & Data Protection, Tokenized Securities Risk Disclosure.