Version: May 2019
Protecting the data of each of our existing or prospective investors or, in general, of the user of this website (together, the “User” or “You”) is of the highest importance to CRDH Capital Ltd. (“CRDH Capital” or “Us”), and we go to great lengths to make sure that we keep it safe. We take your trust and right to privacy seriously. Nevertheless, in the course of serving our Users with this website, we may process information which constitutes Personal Data (as defined in section “What Is Personal Data?”) under data protection laws such as the General Data Protection Regulation of the European Union, the Swiss Act on Data Protection or equivalent laws in other jurisdictions around the globe.
1. What Is Personal Data?
Your name, address, email address, age and your IP address are elements of data processed by Us, that describe You and that may be correlated with You as an individual.
Additional information that CRDH Capital may request from You in order to register and create your personal access to the Site (i.e., gender, nationality, profession, etc.) may qualify as data that describes You and that may be correlated with You as an individual.
Your name, address of residence, IP address, email address, age, profession and any other personal information required for the creation of your personal access to the Site are deemed to be “Personal Data”.
2. How and Where Does CRDH Capital Process Personal Data?
We store and process the Personal Data that You have provided to Us as well as data that we may infer from your use of the Site (the latter generally being in anonymous form).
Your Personal Data may be subject to storage, collection, registration, organization, preservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, transmission, cancellation and destruction (the “Processing”). Any of these operations may be performed applying those electronic or physical instruments and legal means that we deem appropriate for the security, confidentiality and protection of Personal Data.
Personal Data is processed at operating offices of CRDH Capital and at any other places where the parties involved in the Processing are located. More details on the parties involved in the Processing can be found in section “Who Processes My Personal Data?”.
CRDH Capital uses its own servers and may use third-party providers servers, located within the European Union.
While processing Personal Data, we make sure to take all reasonably possible security measures, both technically and organizationally, to keep Personal Data safe. If You would like to know more about how we keep You and your Personal Data safe, please see section “How Safe Is It to Use the Site?”.
3. Why Does CRDH Capital Process Personal Data?
CRDH Capital may process Personal Data for the following purposes:
(1) to improve the content, functionality and performance of the Site;
(2) to provide services to You;
(3) to enhance your browsing experience;
(4) to recognize You when You return to the Site;
(5) to provide (technical) support when You reach out to Us;
(6) to assess and manage risk and fulfil our legal and regulatory requirements;
(7) to exercise and defend our legal rights; and
(8) for any other legitimate business purposes.
4. Is the Processing Legally Justified?
Our Processing activity is executed in conformity with the applicable legal requirements:
- the processing activities set forth in items (1) to (5) above are necessary for the use of the Site and your consent;
- the processing activities set forth in items (6) and (7) above are necessary to comply with our legal obligations; and
- the processing activities set forth in items (8) above are based on our legitimate interest.
5. For How Long Is My Personal Data Processed?
Our retention periods for Personal Data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When Personal Data is no longer needed, our policy is to either irreversibly anonymize Personal Data (and we may further retain and use the anonymized information) or securely destroy such Personal Data.
Based on your consent for the processing activities set forth above, we keep your Personal Data in our database for as long as required for the use of the Site and for a maximum time period of five (5) years thereafter, subject to statutory limitation periods, whereupon it will be deleted.
You have the right at any time to request the deletion of all of your Personal Data (more details on deletion of Personal Data can be found in sections “What Are My Rights As User?” and “Questions?”) in accordance with the Terms & Conditions.
6. Who Processes My Personal Data?
CRDH Capital Ltd., Beustweg 12, 8032 Zürich, Switzerland, registered with the Zurich commercial register under no. CHE-175.568.236, is the data controller.
CRDH Capital has several data processors to operate the Site and we may need to share some of your Personal Data with them.
CRDH Capital’s data processors can be categorized as:
- CRDH Capital’s directors, officers, employees, agents, counsels or other advisers (the “Representatives”);
- CRDH Capital’s legal advisors;
- CRDH Capital’s IT persons;
- CRDH Capital’s auditors;
- CRDH Capital’s administrators; and
- [CRDH Capital’s third-party service providers entrusted with its client relationship management.]
Unless we tell You differently, our data processors do not have any right to use the Personal Data we share with them beyond what is necessary to assist Us in providing the Site to You.
When we cooperate with data processors and they process your Personal Data on our behalf, we make sure that your Personal Data will be handled with the same integrity and security as we do.
7. How Safe Is It To Use the Site?
CRDH Capital carries out the Processing of Personal Data in compliance with the principles of correctness, fairness, lawfulness, transparency and confidentiality, and in accordance with any applicable law (such as the European GDPR and the Swiss FADP) or additional rules protecting these principles.
CRDH Capital takes appropriate technical and organizational measures to protect your Personal Data against loss or other forms of unlawful processing.
8. What Are My Rights as a User?
The rights with respect to Personal Data include your rights, at any time: (i) to receive confirmation regarding the Processing of Personal Data and the persons involved in the Processing of Personal Data, (ii) to access Personal Data, (iii) to obtain Personal Data in a structured and organized way, (iv) to object to the Processing of Personal Data, (v) to obtain rectifications of, to apply restrictions on, Personal Data and (vi) to be informed about any data breach of Personal Data.
As we Process your Personal Data for the performance of services to You, You may ask Us to refrain from Processing your Personal Data or have Personal Data erased or transformed into anonymous form only in accordance with the Terms & Conditions. If You do not agree on the Processing of your Personal Data, we will no longer process your Personal Data, but we will no longer be able to provide You with the services. If You no longer want Us to Process your Personal Data, simply terminate your use of the Site in accordance with the Terms & Conditions and ask Us to delete your Personal Data. Be aware that the termination of contract does not suspend You from other obligations according to the Terms & Conditions.
If You need more information on your Personal Data, let Us know by sending Us an email to email@example.com.
What is a cookie?
A cookie is a small text snippet sent from the web server to the User’s internet browser and saved in the User’s computer. Cookies are designed to hold a small amount of data specific to the User or the website that had sent them. At your next visit on that website, these files will be re-sent to the website that generated them in order to improve your use of the site in question.
“Third parties” cookies, on the other hand, are sent from websites that You are not directly visiting. It occurs namely when accessing certain elements (like images, links, etc.) that are hosted by a different server from the one of the visited website.
Some cookies are necessary for the correct use of the website and cannot be disabled. Others, like the ones regarding memorization of preference parameters, can be disabled.
There are various kinds of cookies, each one having a specific purpose. CRDH Capital uses the following cookies:
Technical cookies or “first-party” cookies
These cookies are managed by the owner and/or the publisher of the website and are strictly needed for the proper operation of the website but also provide aggregate data for internal surveys regarding the numbers of website-visits, the popularity of the website and traffic flow information.
Technical cookies do not collect information that may be used for advertisements, neither do they track the User’s personal browsing history.
In order to install these cookies, the consent of the User is not required (as all data collected remains anonymized). If the User refuses the installation of these cookies, his/her access to the website will automatically be denied.
“Third party” cookies
These cookies are installed on the User’s browser by a party that is not the owner and/or the publisher of the visited website. There are various types of such “third party” cookies, among which: Analytics Cookies: used to collect and analyze data. They do not identify the individual User.
What are cookies needed for?
Cookies help to improve our services and your browsing experience. The advantage for a User to have cookies installed on his/her computer consists in the fact that he/she is no longer required to provide the same information every time he/she accesses the same website, as his/her personal information is remembered by the website through the cookies. Examples are: your language preferences, logging into an account, remembering your email address, and acceptance of the Terms & Conditions.
How to disable cookies?
Through the use of the Site, the User’s consent to the installation of cookies is assumed by CRDH Capital. Users who do not wish to receive cookies may block “first party”, and/or “third party” cookies following the instructions provided by each browser, set forth hereinafter.
If You have any questions, email Us. If You have questions about the way CRDH Capital processes your Personal Data or the personal information CRDH Capital stores about You, please contact CRDH Capital by sending an email with your question to firstname.lastname@example.org.