RWAmarket.place – Privacy Policy
Last updated: October 10, 2025
1. Scope
This Privacy Policy applies to:
– Visitors and registered users of RWAmarket.place
– Buyers and sellers of RWA-backed NFTs (e.g., LOTOSS Token Ownership NFTs)
– Participants in platform utility functions (e.g., custody, secondary marketplace trades)
– Linked services operated by Maritime DAO LLC
2. Information We Collect
Directly from You:
– Identification documents (passport, ID card, driver’s license) for KYC/AML compliance
– Proof of residence and tax identification numbers
– Contact details (name, email, phone number)
– Payment and wallet details when engaging in transactions
Automatically Collected:
– Log files, IP addresses, browser/device details
– Blockchain wallet addresses interacting with our smart contracts
– Cookies and tracking data for site functionality and analytics
3. How We Use Your Information
We use personal data to:
– Verify identity and meet KYC/AML requirements
– Facilitate NFT purchases, sales, and custody
– Maintain platform security, fraud detection, and sanctions compliance
– Communicate about your account, policies, or platform changes
– Improve services and user experience
4. Legal Basis for Processing
We process personal data based on:
– Contractual necessity (to provide services)
– Legal obligations (AML/CTF, sanctions, financial reporting)
– Legitimate interests (platform security, service improvement)
– Consent (for optional communications, cookies)
5. Sharing of Information
We may share your data with:
– Regulators and authorities where legally required (AML/CTF, sanctions, tax)
– Service providers (KYC vendors, blockchain analytics, IT, and payment processors) under confidentiality agreements
– Legal entities within Maritime DAO ecosystem (e.g., rwatradex.com) for operational purposes
We do not sell your data to third parties.
6. Data Retention
– KYC and transaction records are retained for 5 years (or longer if required by law)
– Other user account data is kept as long as you maintain an account or as needed for compliance
7. International Data Transfers
Where data is transferred outside the EU/EEA, safeguards such as standard contractual clauses (SCCs) or equivalent mechanisms are applied.
8. Your Rights
You may have rights under applicable law, including:
– Access to your personal data
– Correction of inaccurate data
– Erasure (“right to be forgotten”) where legally possible
– Restriction or objection to processing
– Data portability
– Withdrawal of consent (where consent is the basis for processing)
Requests can be submitted to: welcome@maritimedao.com
9. Security
We use encryption, secure storage, and restricted access to protect personal data.
However, blockchain transactions are public and immutable by design; users should exercise caution when sharing wallet addresses.
10. Cookies & Tracking
RWAmarket.place uses cookies and analytics tools to improve site performance. Users can control cookies through browser settings.
11. Policy Updates
We may update this Privacy Policy from time to time. The latest version will always be posted on rwamarket.place/legal/privacy-policy with a revised “Last Updated” date.
12. Contact
For privacy-related questions or rights requests:
Maritime DAO LLC
Email: welcome@maritimedao.com
Jurisdiction: Marshall Islands
Note
⚓ This Privacy Policy is designed to work alongside the AML/CTF Policy and Terms of Service of RWAmarket.place.
RWAmarket.place – Terms & Conditions
Last updated: October 10, 2025
Overview
These Terms govern your use of the RWAmarket.place Platform and Services operated by Maritime DAO LLC (Marshall Islands).
Contact: welcome@maritimedao.com
Acceptance & Eligibility
By accessing or using the Platform, you accept these Terms on your own behalf or for the entity you represent. You must be 18+ or the age of majority in your jurisdiction.
Key Policies
The Privacy Policy, AML/CTF Policy, and Community Guidelines posted at rwamarket.place/legal are incorporated into these Terms.
Accounts
Register with accurate information and maintain security of your credentials. If compromised, contact us at welcome@maritimedao.com immediately. Verification (KYC/AML) may be required to access certain features.
KYC/AML & Sanctions
Use of certain Services requires identity verification and ongoing screening. We may restrict or terminate access for compliance reasons.
Services
We provide an intermediary technology platform for compliant listing, purchase, and custody interactions for RWA-backed NFTs and utility features. We may modify, suspend, or discontinue Services.
Fees & Gas
Fees may apply and can change. Blockchain Gas Fees are separate and outside our control.
Prohibited Uses
No illegal activity, infringement, abuse, market manipulation, or violations of Community Guidelines. We may monitor, suspend, or terminate accounts for violations.
Intellectual Property
All Platform IP belongs to the Company or licensors. No rights granted except as expressly stated.
No Warranty; Limitation of Liability
Services are provided “as is” and “as available.” We disclaim all warranties to the maximum extent permitted by law and limit liability as described on the site-wide legal pages.
Governing Law & Disputes
Non‑US users: Marshall Islands law and courts (or where required by consumer law). US residents: binding individual arbitration under AAA Consumer Rules; no class actions or jury trials.
Contact
Maritime DAO LLC
Email: welcome@maritimedao.com
RWAmarket.place – AML / CTF Compliance Policy
(Applicable to all RWAmarket.place primary sales, secondary trading, and custody of asset-backed NFTs, including LOTOSS Token Ownership NFTs)
1. Purpose & Scope
This AML/CTF Policy governs activities conducted on RWAmarket.place and affiliated services, including primary sales, secondary marketplace trading, custody, and redemption/utility actions related to real-world-asset (RWA) backed NFTs (e.g., ship ownership certificates such as the LOTOSS Token Ownership NFTs) and associated utility tokens used strictly for platform functions.
The Policy aligns with:
– EU AMLD5 & AMLD6
– FATF Recommendations (including Travel Rule expectations for VASP‑to‑VASP transfers where applicable)
– Marshall Islands DAO Law (for Maritime DAO LLC)
– Applicable US OFAC, EU, and UN sanctions regimes
This Policy applies to all users (individuals and entities), vendors, and contractors interacting with RWAmarket.place.
2. Governance & Oversight
- AML Compliance Officer (CO): Appointed by Maritime DAO LLC (operator of RWAmarket.place). Serves as the primary liaison with competent authorities and oversees KYC, monitoring, reporting, and recordkeeping.
- Compliance Team (as needed): Legal, accounting, and blockchain analytics specialists engaged during high‑volume periods or audits.
- Authority & Controls: The CO may suspend transactions, freeze assets held in platform custody, block wallet addresses, or terminate access where AML/CTF or sanctions risks are identified.
3. Customer Due Diligence (KYC/CDD)
Individuals (buyers/sellers/beneficiaries):
– Valid government photo ID; proof of residence (≤ 3 months); Tax/ID number
– Email and phone verification
– Wallet ownership verification (challenge/attestation or custodial linkage)
Legal entities (corporates, funds, DAOs):
– Certificate of incorporation/formation; company register extract
– Directors and Ultimate Beneficial Owners (UBOs >25%); proof of registered address
– Company tax number; authority to act (e.g., board resolution, PoA)
– Foreign documents may require notarization, legalization, or apostille
PEPs & HIOs:
– Politically Exposed Persons and close associates/family members are subject to Enhanced Due Diligence (EDD), including source‑of‑funds/wealth verification and ongoing monitoring.
Ongoing CDD:
– Identity data must be kept current. Trigger events (risk score changes, sanctions updates, unusual activity) require re‑verification.
4. Risk Assessment & Scoring
Each participant is risk‑rated (Low/Medium/High) considering:
– Jurisdiction of residence/incorporation; cross‑border factors
– Source of funds (fiat/crypto), counterparties, and payment rails
– Ownership transparency and structure complexity
– Product/use‑case risks (e.g., high‑value maritime assets, frequent flips)
– On‑chain behavior (mixers, obfuscation, sanction‑adjacent exposure)
If any category is High Risk, the overall rating becomes High and EDD is required. High‑risk users may be refused or off‑boarded at the CO’s discretion.
5. Monitoring & Red Flags
Automated and manual monitoring cover fiat and on‑chain activity. Examples of indicators:
– Rapid bulk purchases/sales inconsistent with profile; structuring just below thresholds
– Use of privacy tools/mixers; chain‑hopping to obfuscate provenance
– Refusal to provide KYC updates or source‑of‑funds documentation
– Links to sanctioned vessels, ports, shipowners, or high‑risk jurisdictions
– Patterns suggesting market manipulation or wash trading
Alerts are escalated to the CO for review and action.
6. Thresholds, EDD & Travel Rule
- Transactions ≥ €10,000 (or crypto equivalent) trigger enhanced verification.
- Higher‑risk corridors, assets, or user profiles may require additional documents (bank statements, contracts, invoices, proof of wealth, beneficial‑ownership attestations).
- Where the FATF Travel Rule applies to VASP‑to‑VASP transfers, RWAmarket.place will make reasonable efforts to collect/share required originator/beneficiary information via compliant channels or restrict such transfers.
7. Sanctions Screening
All users and relevant wallets are screened against OFAC SDN, EU and UN consolidated lists, and any applicable Marshall Islands maritime sanctions.
Positive or potential matches result in immediate holds, internal review, and notifications to competent authorities within required timelines. Assets in platform custody may be frozen pending instructions from authorities.
8. Marketplace Rules (Primary & Secondary)
- No listing, purchase, transfer, or redemption without successful KYC/AML clearance.
- Wallets used on RWAmarket.place must be linked to approved profiles (or a regulated custodian).
- RWA‑backed NFTs (including LOTOSS) may be delisted or frozen if compliance concerns arise.
- RWAmarket.place may refuse any transaction or relationship, reverse a trade where lawful/feasible, and report suspicious activity to authorities.
9. Recordkeeping & Audit Trail
KYC files, transaction logs, blockchain hashes, sanctions screenings, alerts, and SAR/STR documentation are retained for at least 5 years (or longer if law requires). Records must remain complete, accurate, and retrievable for audits and lawful requests.
10. Data Protection & Confidentiality
Personal data is processed only for compliance, contractual, and legal purposes, consistent with applicable data‑protection laws. Access is restricted to authorized personnel and trusted service providers under confidentiality and security obligations.
11. Training & Independent Review
Personnel and contractors with compliance‑relevant duties complete AML/CTF training at onboarding and at least annually. The AML program is reviewed at least every 6 months, with findings and remediation plans reported to governance. Material updates are approved by Maritime DAO LLC and published on RWAmarket.place/legal.
12. Reporting & Cooperation
Suspicious activity is documented and, where required, reported to competent authorities. RWAmarket.place cooperates with lawful requests, court orders, and regulator examinations while protecting user data in accordance with the law.
13. Policy Administration
This Policy enters into force upon publication and supersedes prior AML/CTF statements for RWAmarket.place. The CO is responsible for maintenance and version control. The latest version will be posted at RWAmarket.place/legal.