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Privacy Policy

With this Privacy Policy we, VT Partners AG (hereinafter «VT Partners AG, «we» or «us»),
describe how we collect and process personal data. This Data Protection Statement is not
necessarily a comprehensive description of our data processing. It is possible that other data
protection statements are applicable to specific circumstances.

In this Privacy Policy, the term «personal data» refers to any information that identifies or
could reasonably be used to identify any natural person.

If you provide us with personal data of other individuals (such as family members or work
colleagues), please ensure that those individuals are aware of this Data Protection
Statement. Only provide us with their data if you are authorized to do so and ensure that the
personal data provided is accurate.

This Privacy Notice is in accordance with the EU General Data Protection Regulation
(«GDPR») and the Swiss Data Protection Act («DPA»). However, the application of these
laws depends on each individual case.

A. Data Controller

The «controller» of data processing as described in this privacy policy (i.e. the responsible
person) is:

VT Partners AG
Boesch 67
6331 Huenenberg

info@vtpartners.com
www.vtpartners.com

If you have any questions regarding how your personal data is processed or any other data
protection concerns, you can contact us using the above-mentioned contact details.

B. Purpose of Data Processing and Legal Bases

We primarily use collected data to enter into and fulfil contracts with our clients and business
partners, particularly in relation to providing financial services to our clients and procuring
products and services from our suppliers and subcontractors. We also process personal data
to comply with domestic and foreign legal obligations.
Additionally, in accordance with the applicable law and where appropriate, we may process
personal data for the following purposes, which are in our (or, where applicable, third parties')
legitimate interest:

  • Providing and developing our products, services and websites, apps and other
    platforms in which we are involved.
  • Communication with third parties and handling their requests (e.g., job applications,
    media inquiries).
  • Advertisement and marketing (including event organization), provided that you have
    not objected to the use of your data for this purpose (if you are part of our client base
    and you receive advertisement, you may object at any time, and we will add you to a
    blacklist to stop further advertising mailings).
  • Asserting legal claims and defending against legal disputes and official proceedings.
  • Prevention and investigation of criminal offenses and other misconduct.
  • Ensuring the smooth operation of our IT systems, websites, apps, and other devices.
  • Acquisition and sale of business divisions, companies, or parts of companies, and other corporate transactions involving the transfer of personal data. This includes measures for business management and compliance with legal and regulatory obligations, as well as internal company regulations.

If you have provided us with your consent to process your personal data for specific
purposes (for example when registering to receive newsletters), we will process your
personal data within the scope of and based on this consent, unless we have another legal
basis if one is required. You have the right to withdraw your consent at any time, but this
does not affect the processing of data that occurred prior to the withdrawal.

C. Collection and Processing of Personal Data

We primarily process personal data that we obtain from our clients, business partners, and
individuals in the context of our business relationships. Additionally, we collect data from
users when operating our websites, apps, and other applications.

Where permitted, we may acquire certain personal data from publicly accessible sources
(e.g., debt registers, land registries, commercial registers, press, internet) or receive such
information from affiliated companies of VT Partners AG, authorities, or other third parties
(such as e.g., distribution agents, custodian banks). In addition to the data provided directly
by you, the categories of data we receive from third parties include, but are not limited to:
information from public registers, data received in administrative or court proceedings,
information related to your professional role and activities (e.g., to conclude and fulfil
contracts with your employer), information from correspondence and discussions with third
parties, information provided by individuals associated with you (family, consultants, legal
representatives, etc.) to conclude or process contracts with your involvement (e.g. powers of
attorney), information regarding legal regulations such as anti-money laundering, bank
details, information about you from media or internet sources (in specific cases, e.g. job
applications, media reviews, marketing/sales, etc.), your address, interests and other socio-
demographic data (for marketing purposes), and data related to your use of our websites
(e.g., IP address, MAC address of your smartphone or computer, device and settings
information, cookies, date and time of visit, accessed content and sites, used applications,
referring website, localization data).In principle, we retain this data for 12 months after the
completion of the processing purpose. However, this retention period may be extended if
necessary for evidentiary reasons or to comply with legal or contractual obligations.

D. Cookies / Tracking and other relevant Information regarding the Use of our Website

Technical Data
When you visit our website, we collect and evaluate user-specific data (e.g. IP address, web
browser, operating system) and technical data (such as URLs of accessed pages, execution
of search queries) in an anonymous manner.
The mentioned data is collected and processed for system security, stability, error and
performance analysis, as well as for internal statistical purposes. This allows us to optimize
our website.

For subscribing to our content or when submitting a contact form/customer login, we process
the necessary data to provide the requested service. Depending on the specific service, the following data may be processed: email address, first name, last name, salutation, full address, subject matter, and message.
If you have given us your consent to process your personal data for specific purposes (for
example, subscribing to a newsletter or making an inquiry), we will process your personal
data within the scope of and based on this consent, unless we have another legal basis, if
required. You have the right to withdraw your consent at any time, but this does not affect the
processing of data that occurred prior to the withdrawal.

In general, we retain technical data for 6 months.

Communication Data
If you contact us via the contact form, e-mail, telephone, chat, letter, or any other means of
communication, we collect the exchanged data between you and us, including your contact
details and relevant communication details. If we record or listen to telephone conversations
or video conferences, e.g. for training and quality assurance purposes, we will inform you of
this practice. Any recordings will be made and used in accordance with our internal
guidelines and applicable laws.
Generally, we retain this data for 12 months from the last interaction with you. However, this
retention period may be extended if necessary for evidentiary reasons, to comply with legal
or contractual requirements or for technical reasons. E-mails in personal mailboxes and
written correspondence are generally retained for at least 10 years. Recordings of (video)
conferences are usually retained for 24 months. Chats records are typically retained for 2
years.

Cookies and Their Use
We use «Cookies» in some cases to customize our offering to better suit your needs.
Cookies are small files that are stored on your computer or mobile device when you visit or
use our websites. These cookies cannot perform any operations on their own. They save
specific settings through your browser and collect data related to your interaction with the
website. When a cookie is enabled, it is assigned an identification number that identifies your
browser and allows the information stored in the cookie to be utilized. There are two primary
types of cookies: temporary cookies and permanent cookies. We use temporary cookies,
which are automatically deleted from your mobile device or computer at the end of the
browser session. We also use permanent cookies to save user settings (e.g. language, auto-
login), understand how you use our services and content, and show you personalized offers
and advertisements (including on websites of other companies; please note that such
companies will not receive your identity from us; they will only know that the same user who
visited their website had previously visited a specific website). Permanent cookies remain
saved on your computer or mobile device for an extended period but are automatically
disabled after a predetermined time.
Despite the above, you may configure your browser settings in a way that it rejects cookies,
only saves them for one session or deletes them prematurely. Most browsers are preset to
accept cookies. However, if you choose to block cookies, certain functions (such as, e.g.,
language settings, shopping basket, ordering processes) are no longer available to you.

VT Partners AG allows partner companies that provide services for VT Partners AG or which
are integrated into our website to save cookies, as long as it is technically necessary and the
use of cookies is proportionate. VT Partners AG has no control over how cookies are used
outside our website.

By continuing to use our website and / or agreeing to this privacy policy, you consent to the
saving of cookies and the collection, storage and use of personal usage data, even after the
browser session ends («permanent Cookies»). You can object to this at any time by changing the browser’s default setting to reject (third-party) cookies.

Google Analytics and Similar Services
We may use Google Analytics or similar services on our website with the objective of
designing and continuously optimizing our website to meet your needs. These services are
provided by third parties, which may be located in any country worldwide (in the case of
Google Analytics Google Ireland Ltd. (located in Ireland), Google Ireland relies on Google
LLC (located in the United States) as its sub-processor (both «Google»), www.google.com).
These services allow us to measure and evaluate the usage of our website on an
anonymized basis. For this purpose, permanent cookies are used, which are set by the
service provider. We have configured the service in a way that ensures IP addresses of
visitors are truncated by Google within Europe before being transmitted to the United States,
making it impossible to trace them back. We have also disabled the "Data sharing" and
"Signals" options. Although we can assume that the information we share with Google does
not constitute personal data for Google, it may be possible that Google may be able to draw
conclusions about the identity of visitors based on the data collected, create personal profiles
and link this data with the Google accounts of these individuals for its own purposes. If you
have registered with the service provider, the service provider will also have knowledge of
your identity. In this case, the processing of your personal data by the service provider will be
conducted in accordance with its own data protection regulations. The service provider only
provides us with data regarding the usage of the respective website, and no personal
information about you is shared.
In the context of using our website, pseudonymized user profiles are created and, as
previously mentioned, through the use of small text files that are stored on your computer.
The information generated by such cookies regarding your usage of our website is
transmitted to the servers of the service providers, where it is stored and processed on our
behalf. In addition to the previously mentioned data, we may also receive the following
information:

  • The navigation path followed by a visitor on the website.
  • The time spent on the website or subpage.
  • The subpage from which you leave the website.
  • The country, region or town / city from which access is made.
  • The end device (type, version, color depth, resolution, width, and height of the
    browser window).
  • Whether the visitor is a new or returning user.

The tools, programs, and instruments we use in the context of analyzing web behavior
include Google Analytics, Google Tag Manager, Google Ads, YouTube (embedded videos),
Userlike and MailChimp.

Information (including your IP address) generated by the cookie when using the
aforementioned Google Analytics tool, is transmitted to a Google server in the USA. Google will use this information to evaluate website usage and compile reports on website activities for us as the website operator, as well as providing other services relating to website and internet use. Google may also transmit this information to third parties if required by law or if third parties process the data on Google’s behalf. Google will never associate your IP address with other Google data. You can prevent the installation of cookies by adjusting your browser settings. However, if you do so, you may not be able to use all the features on the website. By using this website, you consent to Google processing the collected data about you as described above and for the stated purpose.

Social Media Plug-ins
In case social media plug-ins are used In addition, we use plug-ins from social networks such as Facebook, Twitter, YouTube, Pinterest or Instagram on our website. These plug-ins are identifiable by their respective symbols. By default, we have configured these elements to be disabled. If you choose to activate them (by clicking on them), the operators of the respective social networks may
collect information that you are visiting our website, which page you are accessing from, and
may use this information for their own purposes. The processing of your personal data in this
context is the responsibility of the respective operator and is conducted in accordance with
their data protection regulations. We do not receive any information about you from the
respective operator.

E. Sharing Data with Third Parties and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing
outlined above, we may transfer data to third parties, insofar as such a transfer is permitted
and deemed appropriate for them to process the data on our behalf or for their own
purposes. In particular, the following categories of recipients may be concerned:

  • Our service providers (e.g. Risk Management & Compliance, IT-Provider, CRM-
    System)
  • Domestic and foreign authorities, official bodies and courts
  • Other parties involved in potential or ongoing legal proceedings

Certain Recipients are located within Switzerland, but others may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in which VT Partners AG is represented by affiliates, branches or other offices as well as to other countries in Europe and the USA where our service providers are located (such as e.g.
Microsoft). If a recipient is located in a country without adequate statutory data protection, we require the recipient to commit to data protection compliance (for this purpose, we use the revised
European Commission’s standard contractual clauses, which can be accessed here:
https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a
legally accepted set of rules to ensure data protection, or unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, overriding public interest, contractual disclosure requirements, your consent, or if data has
been publicly available and you have not objected to its processing.

F. Duration of data storage

Your data, which includes personal data, will be processed and stored only for as long as
necessary to fulfil our contractual and legal obligations or for the purposes stated in the data
processing activities. This may include the entire duration of the business relationship and
beyond, based on legal retention requirements and documentation obligations. It is possible that personal data will be retained for the time in which claims can be asserted against our
company and insofar as we are otherwise legally obliged to do so, or if legitimate business
interests require it (e.g. for evidence and documentation purposes). Once your personal data
is no longer required for the above-mentioned purposes, it will be erased or anonymized, to
the extent possible. For operational data (e.g. system protocols, logs), shorter retention
periods of 30 days or less apply.

G. Data Security

We have taken appropriate technical and organizational security measures to protect your
personal data against unauthorized access and misuse. These measures include issuing
instructions, training, IT and network security solutions, access controls and restrictions,
encrypting passwords, data storage devices and transmissions, pseudonymization and
controls.
We cannot guarantee the security of data transmission over the internet. When transmitting
data by email, there is a certain risk of access by third parties.

H. Your Rights

In accordance with and as far as provided by applicable law, you have the right to access,
rectification and erasure of your personal data, the right to restriction of processing or to
object to our data processing, in particular for direct marketing purposes, for profiling carried
out for direct marketing purposes and for other legitimate interests in processing in addition
to right to receive certain personal data for transfer to another controller (data portability).
Please note, however, that we reserve the right to enforce statutory restrictions on our part,
for example if we are obliged to retain or process certain data or if we have an overriding
interest (insofar as we may invoke such interests) or need the data for asserting claims.
We have already informed you of the possibility to object/withdraw consent at any time.
Please be aware that exercising your rights may have implications for your contractual
obligations and this may result in consequences such as premature contract termination or
associated costs. If this is the case, we will inform you in advance unless it has already been
contractually agreed upon.

In general, exercising these rights requires that you are able to proof your identity (e.g., by a
copy of identification documents where your identity is not evident otherwise or can be
verified in another way). In order to assert these rights, please contact us via the details
provided above.

In addition, every data subject has the right to enforce his/her rights in court or to lodge a
complaint with the competent data protection authority. The competent data protection
authority of Switzerland is the Federal Data Protection and Information Commissioner
(http://www.edoeb.admin.ch).

I. Profiling and Automated Individual Decision-Making

We may partially process your personal data automatically with the aim of evaluating certain
personal aspects (profiling). In particular, profiling allows us to inform and advise you about
products possibly relevant for you more accurately. For this purpose, we may use evaluation
tools that enable us to communicate with you and advertise you as required, including
market and opinion research.

While establishing and carrying out a business relationship, we generally do not use any fully
automated individual decision-making (such as pursuant to article 22 GDPR). Should we usesuch procedures in certain cases, we will inform you separately and advise you of your
relevant rights if required by law.

J. Changes to this Privacy Policy

We may amend this Privacy Policy at any time without prior notice. The current version
published on our website shall apply. If the Privacy Policy is part of an agreement with you,
we will notify you via e-mail or other appropriate means in case of an amendment.