Privacy policy

1. Controller

The controller for the processing of personal data is [PENDING] (full company name), NOBILITH, [PENDING] (address), Switzerland.

Email: info@nobilithworld.com

No data protection adviser has been appointed at present. Where legally required, a representative for customers in the European Union will be named and published here.

2. Scope

This policy covers the website, the member area, the Private Market, primary sales, auctions, concierge and advisory enquiries, the NOBILITH Academy, Vault and Ownership Pass, the mobile application for iOS and Android, communication with NOBILITH and internal review, security and compliance processes.

NOBILITH processes personal data under Swiss data protection law. Where foreign law additionally applies, its mandatory requirements are observed.

3. Data we process

Depending on use, the following data may arise:

• Account data: name, email address, preferred language, account status, member reference, sign-in and session data, two-factor details. Passwords are stored only as an Argon2id verifier, never in clear text. If you set up a passkey in the NOBILITH app, we store only the public key, a device label and the times of setup and last use; face or fingerprint data never leave your device.
• Identity and compliance data: proof of identity, address and residence, nationality, beneficial owner, sanctions and PEP checks, source of funds, purpose of the transaction, delivery and recipient details.
• ID check in the app (since 29 September 2026): data from the chip in your identity document (name, date of birth, nationality, document type and number, validity, facial image), a selfie with a simple liveness check (head movement, blinking, depth information on iPhone) and the result of the authenticity check. These are biometric and therefore sensitive personal data. They are stored encrypted and viewed only by two members of our customer due diligence team; the facial image and selfie are deleted immediately after the decision. There is no automated face matching – the comparison is made by people.
• Customer due diligence: self-declaration on a politically exposed position, source of funds and – only above a threshold, if you declare a PEP position or on request – supporting documents (stored encrypted). Digital PDF documents are automatically pre-checked on our server (name, date, amount, signs of editing); the pre-check only provides hints, decisions are made by staff. Screening of your verified name and date of birth against the SECO sanctions list at verification and daily thereafter.
• Delivery address when a gemstone leaves bonded storage: street, city, country and telephone number for arranging the value transport; stored encrypted, used only for this delivery and deleted after completion. Delivery is made only to you as the account holder.
• Transaction data: selected gemstones, dossier and certificate data, bids, purchase and sale data, payment status, ownership changes, custody status, delivery and withdrawal requests, invoices and settlements.
• Communication data: emails, messages in the member area, concierge enquiries, appointment and advisory data, service and delivery requests, and processing notes where needed.
• Technical data: IP address, time of access, browser and device details, operating system, pages and interfaces requested, security and error logs, session identifier, plus device identifier and push token where push messages are enabled.
• Server access logs (time, IP address, domain, page or interface requested without parameters, status and response time) are kept for 30 days to operate and secure the platform and to analyse faults, and are then deleted automatically.
• Auction data: auction admission and bidding limit, reserved funds, bidder handle, bids with time stamp, annulled bids with reason, access codes (stored only as a check value), winning bids, invoices, payment deadlines, payments received, defaults and exclusions from future auctions as well as offers to underbidders. The email address you provide when registering for an auction is stored encrypted. To display the number of viewers, only a count is recorded, no personal data.
• Data of auction partners (consignors): partner application (individual or company, address, tax number), payout account (only the country and the last four digits of the IBAN are stored), persons involved (beneficial owners, authorised signatories, owner in case of agency) with name, date of birth and nationality, uploaded verification documents (identity document, proof of address, commercial register extract, signing authority, declarations, proof of acquisition and origin of gemstones) with checksum and review decision, acceptances of the consignment terms with version and time, results of the sanctions screening, and domicile or registered office with proof and confirmation (basis for charging the commission with or without Swiss VAT; the VAT treatment is recorded for each payout).

4. Purposes

We process personal data in particular to:

• open and manage customer accounts and carry out sign-in and two-factor verification
• process purchases, sales and auctions and operate the Private Market, including anonymous offers for gemstones without a listing – only with your consent; your name is never shown, and amounts, times and responses of the negotiation are logged
• document ownership changes, vault and custody, and handle delivery and withdrawal requests
• carry out identity, sanctions and compliance checks
• issue certificate and transaction documents and answer enquiries
• send service and security messages and provide the Academy
• detect and prevent misuse, fraud and attacks
• meet statutory retention and record-keeping duties and pursue or defend legal claims
• to handle payments after auctions: invoices after failed collection, payment deadlines, payments received, defaults and offers to underbidders
• to verify and approve auction partners (identity, beneficial owners, documents) and to handle consignments
• to screen partners and the persons named daily against the public sanctions list of SECO (name and date of birth); the list is downloaded from the SECO website, and no personal data is transmitted to SECO

5. Hosting and infrastructure

The platform runs at Hostpoint in Switzerland. Website and mobile application use the same core logic and the same database (MariaDB 10.11).

As part of hosting, Hostpoint may have access to servers, database, backups and security logs. The contractual classification and backup retention periods will be documented before production launch.

6. External service providers

Where necessary, data may be passed to the following categories of providers:

• Connection set-up and, where necessary, relaying of video meetings (STUN/TURN) via a server operated by NOBILITH at a Swiss hosting provider; until it is in operation, a STUN service from Google (USA) as a fallback
• hosting and database providers, email delivery, IT security and support
• payment providers and banks
• identity, KYC, sanctions and compliance providers
• custodians and bonded warehouses, insurers, secure transport and logistics
• auction partners and gemmological laboratories, in particular GIA, GRS, Gübelin, SSEF and ICA GemLab
• push message services: Apple Push Notification service and Firebase Cloud Messaging
• legal, tax and compliance advisers

7. Payments

Bank transfer, credit card via a payment provider, PayPal and possibly Worldline/Saferpay are planned.

NOBILITH receives only the details and status messages required for processing. Full card data is not stored at NOBILITH. NOBILITH holds no freely available customer balance.

8. Transfers abroad

Personal data may be transferred abroad where required for payment, identity and compliance checks, international delivery, logistics, email or push delivery, operation of the mobile application or technical support.

The countries involved depend on the providers used and the delivery destination and will be added to the provider overview: [PENDING].

Push messages technically run via Apple (USA) and Google (USA). Gemstones are generally held in custody in Switzerland.

9. Cookies and sessions

NOBILITH uses only technically necessary cookies and session data: for sign-in, secure session management, protection against misuse, language and display settings and access to protected areas.

The sign-in cookie is bound to the domain, cannot be read by scripts and is not used for advertising. In the mobile application the same session is carried by a sign-in token instead.

No statistics or marketing services such as Google Analytics, Matomo or Plausible are used. Should optional services be added later, they will be described beforehand and, where required, governed by consent.

10. Email and push messages

NOBILITH sends emails for registration confirmations, staff invitations, sign-in codes, password resets, authenticator re-enrolment, security warnings, payment and transaction status, auction information, delivery and custody status, service replies and messages required by law or contract.

During registration the email address and the password verifier are stored until the link is confirmed; without confirmation the registration lapses after 24 hours and no account is created. Confirmation, invitation and re-enrolment links are single-use and valid for 24 hours.

Push messages go only to devices registered in the app. Under “Security” in your account you can see every registered device and sign it out individually or all at once – including from another device, for example if a phone is lost. If the app is removed, the operating system reports the device as gone and NOBILITH deactivates it.

11. Academy and public content

The public Academy shows approved content only. Internal sources, review notes, audit data and editorial notes are never shown publicly. Product-related content is linked only to confirmed data and approved media.

12. Video meetings and appointment booking

For concierge consultations and viewings NOBILITH offers video meetings and appointment booking. We process name, email address, time zone, chosen appointment and channel (video or phone), for phone the phone number, the invitation, joining and leaving, the waiting room as well as documents shared in the meeting and a log of these actions. The log is kept together with the concierge case.

Video and audio run directly between the participating devices (WebRTC) and are neither stored nor recorded by NOBILITH. To establish the direct connection, the devices technically exchange their IP addresses; participants can technically see them.

To establish the connection, NOBILITH operates its own connection server (STUN/TURN) at a Swiss hosting provider. If a network does not allow a direct connection, video and audio are relayed through this server without being stored; the server receives the IP addresses of the devices in the process. The access codes for it are personal and expire after a few hours. Until the own server is in operation, a STUN service from Google (USA) is used as a fallback and receives the IP address; in that case no relaying is possible.

A meeting is recorded only if all participants have agreed beforehand.

13. Retention and deletion

Personal data is kept only as long as required for the purpose or by statutory retention duties. Commercial records are subject to the ten-year retention duty under Art. 958f CO.

You can request deletion of your account yourself at any time: in your account under “Security”, on any device and in the app. After the request a 30-day period runs during which you can withdraw it.

If something stands in the way of deletion, the request is not rejected but deferred – and the reasons are named to you. These are in particular gemstones in your vault, open purchases, active bids, ongoing transfers and a legal hold arising from official or court proceedings.

Verification documents of auction partners, sanctions screenings, acceptances of the consignment terms and auction protocols are retained for at least ten years. Uploaded documents are accessible only to authorised Operations staff; every access is logged.

• On completion all sessions end and sign-in credentials are invalidated.
• Personal account data is deleted or made unidentifiable.
• Legally required records and ownership and transaction histories remain without personal reference.

14. Your rights

Within the applicable law you may request information about the data processed, correction of inaccurate data, deletion, restriction of processing, release of your data and withdrawal of consent given.

You can obtain the information yourself: in your account under “Security”, “Download my data” provides a complete copy of what NOBILITH stores about you as a file. For security reasons this file contains no sign-in secrets such as password verifiers or session identifiers.

Other requests go to info@nobilithworld.com. To prevent abusive requests NOBILITH may require reasonable identity verification.

15. Data security

NOBILITH applies appropriate technical and organisational measures, in particular:

• encrypted transmission and protected sessions with idle and maximum duration
• two-factor sign-in and password storage as an Argon2id verifier
• central session revocation; a password change ends all sessions, including the current one
• authorisation checks on every request and separation of internal and public areas
• logging of security-relevant events plus backups and tested restore

16. Minors

Accounts, purchases, bids and auctions are intended for adults. Minors may not use NOBILITH for paid or legally binding transactions without the consent of their legal representative.

17. Changes

NOBILITH may adapt this policy when the platform, providers, legal requirements or processing purposes change. The current version is published on the website and in the app.