Privacy Policy

1. Data Protection at a Glance

General Information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you could be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for the data collection on this website? The data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the responsible party” in this privacy policy.

How do we collect your data? Your data is collected, on the one hand, when you provide it to us. This could be, for example, data you enter into a contact form.

Other data is collected automatically or after your consent by our IT systems when you visit the website. This data is primarily technical data (e.g., internet browser, operating system, or time of the page request). The collection of this data takes place automatically as soon as you enter this website.

What do we use your data for? Part of the data is collected to ensure the error-free provision of the website. Other data can be used to analyze your user behavior.

What rights do you have regarding your data? You have the right to receive information about the origin, recipient, and purpose of your stored personal data at any time and free of charge. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

Analysis tools and third-party tools When you visit this website, your surfing behavior can be statistically evaluated. This happens primarily with so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the servers of the hoster. This may primarily include IP addresses, contact requests, metadata and communications, contract data, contact details, names, website accesses, and other data generated through a website.

The hoster is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 Para. 1 lit. b GDPR) and in the interest of a secure, fast, and efficient provision of our online services by a professional provider (Art. 6 Para. 1 lit. f GDPR).

Our hoster will only process your data to the extent necessary to fulfill its performance obligations and will follow our instructions with respect to this data.

We use the following hoster:

METANET AG
Josefstrasse 218
CH-8005 Zurich

Conclusion of a data processing agreement To ensure processing in compliance with data protection regulations, we have concluded a data processing agreement with our hoster.

3. General Notes and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We would like to point out that data transmission over the internet (e.g., communication by email) can have security vulnerabilities. A complete protection of data against access by third parties is not possible.

Note regarding the responsible party (Data Controller)

The responsible party for data processing on this website is:

Contact:
Email: info@cirqumvest.ch
Phone: +41 41 539 19 68

www.cirqumvest.ch

Responsible for content: Christoph Wainig

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Storage Duration

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

Statutory Data Protection Officer

We have appointed a data protection officer for our company.

Contact:
Email: info@cirqumvest.ch
Phone: +41 41 539 19 68

www.cirqumvest.ch

Responsible for content: Christoph Wainig

Note on Data Transfer to the USA

Among other things, tools from companies based in the USA are integrated into our website. If these tools are active, your personal data may be transferred to the US servers of the respective companies. We would like to point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to release personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g., intelligence services) process, evaluate, and permanently store your data located on US servers for surveillance purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU FILE AN OBJECTION, WE WILL NO LONGER PROCESS YOUR CONCERNED PERSONAL DATA UNLESS WE CAN PROVE COMPELLING LEGITIMATE GROUNDS FOR PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, deletion, and correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient, and the purpose of data processing and, if necessary, a right to correct or delete this data. You can contact us at any time regarding this and other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing applies in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21 Para. 1 GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the assertion, exercise, or defense of legal claims or to protect the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

Objection to promotional emails

The use of contact data published within the framework of the imprint obligation for the purpose of sending unsolicited advertising and information materials is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of promotional information, for example through spam emails.

4. Datenerfassung auf dieser Website

Cookies

Our websites use so-called “cookies”. Cookies are small text files and do not cause any damage to your end device. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your end device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g., cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or to display advertising.

Cookies that are necessary to carry out the electronic communication process (necessary cookies) or to provide certain functions you have requested (functional cookies, e.g., for the shopping cart function) or to optimize the website (e.g., cookies for measuring the web audience) are stored on the basis of Art. 6 Para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies has been requested, the respective cookies are stored exclusively on the basis of this consent (Art. 6 Para. 1 lit. a GDPR); this consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

Insofar as cookies are used by third-party companies or for analysis purposes, we will inform you of this separately within the framework of this privacy policy and, if necessary, request your consent.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and browser version
Operating system used
Referrer URL
Hostname of the accessing computer
Time of the server request
IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, server log files must be recorded.
Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We will not pass on this data without your consent.

The processing of this data is based on Art. 6 Para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries sent to us (Art. 6 Para. 1 lit. f GDPR) or on your consent (Art. 6 Para. 1 lit. a GDPR) if this was requested.

The data you send us via contact requests remains with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.

5. Analysis Tools and Advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, length of stay, operating systems used, and the user’s origin. This data may be summarized by Google in a profile that is assigned to the respective user or their end device.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this analysis tool is based on Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its web offering and its advertising. If a corresponding consent has been requested (e.g., consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; the consent can be revoked at any time.

Data transmission to the USA is based on the Standard Contractual Clauses (SCCs) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP Anonymization

We have activated the IP anonymization function on this website. As a result, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area prior to transmission to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser Plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

More information on how Google Analytics handles user data can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Data Processing Agreement

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Storage Duration

Data stored by Google at the user and event level that is linked to cookies, user IDs, or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) is anonymized or deleted after 14 months. Details can be found at the following link: https://support.google.com/analytics/answer/7667196?hl=de

Hotjar

This website uses Hotjar. The provider is Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (Website: https://www.hotjar.com).

Hotjar is a tool used to analyze your user behavior on this website. With Hotjar, we can record your mouse and scroll movements and clicks, among other things. Hotjar can also determine how long you have remained with the mouse pointer in a certain position. From this information, Hotjar creates so-called heatmaps, which can be used to determine which website areas are preferred by the website visitor.

Furthermore, we can determine how long you stayed on a page and when you left it. We can also determine at which point you abandoned your entries in a contact form (so-called conversion funnels).

In addition, direct feedback from website visitors can be obtained with Hotjar. This function serves to improve the web offerings of the website operator.

Hotjar uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or the use of device fingerprinting).

Deactivating Hotjar

If you would like to deactivate data collection by Hotjar, click on the following link and follow the instructions there: https://www.hotjar.com/opt-out

Please note that the deactivation of Hotjar must be done separately for each browser or each end device.

Further information about Hotjar and the data collected can be found in Hotjar’s privacy policy at the following link: https://www.hotjar.com/privacy

Data Processing Agreement

We have concluded a data processing agreement with Hotjar in order to implement the strict European data protection regulations.

6. Plugins and Tools

YouTube

This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of our web pages where YouTube is embedded, a connection to YouTube’s servers is established. The YouTube server is informed which of our pages you have visited.

Furthermore, YouTube may store various cookies on your device or use comparable technologies for recognition (e.g., device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve user-friendliness, and prevent fraud attempts.

If you are logged into your YouTube account, you enable YouTube to assign your browsing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

The use of YouTube is in the interest of an appealing presentation of our online offerings. This constitutes a legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; consent can be revoked at any time.

For more information on how YouTube handles user data, please refer to YouTube’s privacy policy at: https://policies.google.com/privacy?hl=en.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is intended to check whether data entry on this website (e.g., in a contact form) is carried out by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g., IP address, time the website visitor spends on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run completely in the background. Website visitors are not informed that an analysis is taking place.

Data storage and analysis is based on Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and SPAM. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; consent can be revoked at any time.

For more information about Google reCAPTCHA, please refer to Google’s privacy policy and Google’s terms of use at the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.