Disclaimer
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Privacy policy
Contact
ZWEI Wealth Experts AG
Genferstrasse 35
CH-8002 Zürich
Schweiz
Tel.: +41 43 299 22 22
E-Mail: info(at)zwei-we.ch
Website: www.zwei-wealth.ch
The controller, within the meaning of the General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP), is Kevin Graf. All data subjects can contact the address provided above directly at any time with any questions and suggestions concerning data protection.
Introduction
We are delighted that you are interested in our company. Data protection is a high priority for the executive management of ZWEI Wealth Experts Ltd. It is possible in principle to use the website of ZWEI Wealth Experts Ltd. without having to provide any personal details. However, if a data subject would like to take advantage of specific services offered by our company via our website, it may be necessary to process personal data. If the processing of personal data is required and there is no legal basis for processing of this kind, we generally obtain the consent of the data subject.
The processing of personal data, for example, the name, address, e-mail address or telephone number of a data subject, shall always be carried out in line with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to the company. The aim of this data protection statement is for our company to inform the general public about the type, scope and purpose of the personal data we collect, use and process. In addition, this data protection statement also clarifies the rights available to data subjects.
The company, as controller, has introduced numerous technical and organisational measures in order to ensure the most comprehensive protection of the personal data processed via this website. Nevertheless, there may in principle be gaps in security when transferring data on the Internet, which means that absolute protection cannot be guaranteed. For this reason, every data subject is free to also send us personal data via alternative methods, such as over the phone.
Legal basis
The website www.zwei-we.ch is subject to Swiss data protection law, especially the Swiss Federal Act on Data Protection (FADP) and applicable foreign law such as the EU General Data Protection Regulation (GDPR). The EU recognises that Swiss data protection law ensures an adequate level of data protection.
We can amend our data protection statement at any time by publishing it on this website.
Scope of application
This data protection statement is valid for all websites belonging to ZWEI Wealth Experts Ltd. For all third-party websites that do not belong to ZWEI Wealth Experts Ltd. but to which there is a link from www.zwei-we.ch, no liability shall be accepted for complying with data protection provisions.
Disclaimer
The operator of the website accepts no liability whatsoever for information being correct, accurate, up to date, reliable or complete.
Liability claims against the operator of the website due to material or non-material damage or loss that arise from access to or the use or non-use of published information, from misuse of the online connection or from technical faults are excluded.
All offers are non-binding. The operator of the website expressly reserves the right to modify, supplement or delete some pages or the entire website or to suspend publication, either temporarily or permanently.
Liability for links
Our website contains links to external third-party websites and we do not have any influence on their content. For this reason, we are unable to accept any responsibility for this external content. The provider or operator of the linked website is always responsible for its content. The linked pages were checked for potential legal violations at the time the link was created. No unlawful content was apparent at the time of linking.
The permanent checking of the content of linked websites is, however, unreasonable in the absence of specific evidence indicating a legal violation. If a legal violation is detected, the relevant links shall be removed immediately.
Liability for integrated radio and television clips
Our website contains radio and television clips from external third-party websites and we do not have any influence on their content. For this reason, we are unable to accept any responsibility for this external content. The provider is always responsible for the content of these clips in each case. The integrated clips were checked for potential legal violations at the time the link was created. No unlawful content was apparent at the time of integration.
If a legal violation is detected with radio or television clips, we shall remove these media without delay.
Monitoring
Access to our website – just like any use of the Internet – is subject to general, unfounded and indiscriminate mass surveillance without suspicion by security agencies in Switzerland, the EU, the US and other countries. The operator of the website has no direct influence on the corresponding processing of personal data carried out by intelligence services, police forces and any other security agencies.
Encryption
Access to our website is via transport encryption (SSL/TLS).
Server log files
The website www.zwei-we.ch collects a range of general data and information each time it is called up by a data subject or an automated system. This general data and information are stored in the server's log files. The following information may be collected:
Browser types and versions used
- The operating system used by the accessing system
- The website via which the accessing system reaches our website (referrer)
- The subpages on our website that are accessed via an accessing system
- The date and time of access to the website
- The Internet Protocol address (IP address)
- The Internet service provider of the accessing system and any similar data and information that serve as hazard prevention in the event of attacks on our information technology systems.
- When using this general data and information, the company shall not draw any conclusions about the data subject. This information is in fact required in order
- To correctly deliver the content of our website
- To optimise the content of our website and its advertising
- To guarantee the permanent functionality of our information technology systems and the technology of our website and
- For law enforcement agencies to provide the information required for prosecution in the event of a cyber attack.
This anonymous data and information are thus evaluated by the company, both for statistical purposes and with the aim of enhancing data protection and data security at our company in order to ultimately ensure an optimal level of security for the personal data processed by us. The anonymous data on the server log files is stored separately from all other personal data provided by a data subject.
This website is hosted by Intersim AG, Kirchbergstrasse 105, CH-3400 Burgdorf.
Personal data
Personal data is defined as all information relating to a specific or specifiable person. A data subject is a person about whom personal data is processed. Processing includes all handling of personal data, regardless of the means and processes used, particularly the storage, disclosure, procurement, erasure, storage, amendment, destruction and use of personal data.
We process personal data in accordance with Swiss data protection law. Furthermore, we process personal data – if and insofar as the GDPR is applicable – in accordance with the following legal bases:
- Article 6, paragraph 1(a) of the GDPR for the processing of personal data with the consent of the data subject.
- Article 6, paragraph 1(b) of the GDPR for the necessary processing of personal data for the performance of a contract to which the data subject is party or to take relevant steps prior to entering into a contract.
- Article 6, paragraph 1(c) of the GDPR for the necessary processing of personal data for compliance with a legal obligation to which we are subject, in accordance with applicable EU law or in accordance with applicable law of a country in which the GDPR is entirely or partially applicable.
- Article 6, paragraph 1(d) of the GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or of another natural person.
- Article 6, paragraph 1(f) of the GDPR for the necessary processing of personal data for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Legitimate interests are more specifically our business interest, being able to provide our website, information security, the assertion of our own legal claims and compliance with Swiss law.
- ZWEI Wealth Experts Ltd. processes personal data for the duration required for the respective purpose/s. We shall limit processing accordingly in the case of longer retention obligations due to legal and other obligations to which we are subject.
Disclosure of personal data
Personal data shall not be sold or shared with third parties outside the network of ZWEI Wealth Experts.
Cookies
The ZWEI Wealth Experts Ltd. website uses cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.
Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows the visited websites and servers to differentiate between the individual browser of the data subject and other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified via the unique cookie ID.
Through the use of cookies, ZWEI Wealth Experts Ltd. can provide the users of this website with user-friendly services that would otherwise not be possible without the placing of cookies.
The information and services on our website can be optimised in terms of the user using a cookie. As mentioned above, cookies allow us to recognise the users of our website. The purpose of this is to make it easier for users to use our website. The user of a website that uses cookies does not, for example, have to re-enter their login details every time they visit the website as this step is taken by the website and the cookies placed on the user’s computer system. A further example is the cookie for a basket in an online shop. The online shop remembers the items that a customer has put into their virtual basket via a cookie.
The data subject can prevent cookies from being placed by our website at any time via the relevant settings on the Internet browser in use, thus permanently preventing the placing of cookies. Furthermore, cookies that have already been placed can be deleted at any time via an Internet browser or other software programs. This is possible in all current Internet browsers. If the data subject deactivates the placing of cookies in the Internet browser in use, in some circumstances, not all functions of our website will be fully usable.
Forms and e-mail contact
The website of ZWEI Wealth Experts Ltd. may contain forms for contact purposes and/or transferring data. It is also possible to contact ZWEI Wealth Experts Ltd. via e-mail. If a data subject contacts the company through one of these forms or via e-mail, the personal data that the data subject has entered and transferred themselves is automatically stored. Personal data of this kind voluntarily transferred by the data subject to the controller shall be stored for the purpose of processing or to get in touch with the data subject. This personal data is not disclosed to third parties.
Rights of data subjects
Visitors to www.zwei-we.ch as well as other people about whom we process personal data can obtain free confirmation as to whether or not their personal data is being processed by us and, if so, request information about how we are processing their personal data, have the processing of their personal data restricted, exercise their right to data portability, if and insofar as the GDPR is applicable, have their data rectified, erased (“right to be forgotten”) or blocked, withdraw their consent and object to the processing of their personal data.
Persons about whom we process personal data have the right to lodge a complaint with a responsible data protection supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Google Analytics
The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, gathering and evaluation of data on the behaviour of visitors to websites. A web analysis service collects data including the website from which a data subject reached another website (referrer), which subpages of the website have been accessed or how often and for how long a subpage has been viewed. A web analysis is predominantly used to optimise a website and to conduct a cost-benefit analysis of Internet advertising.
The operating company of Google Analytics components is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The data controller uses the suffix “_gat._anonymizeIp” for the web analysis via Google Analytics. Using this suffix, the IP address of the Internet connection of the data subject is truncated and anonymised by Google if access is made to our webpages from an EU member state or from another state which is a signatory to the Agreement on the European Economic Area.
The purpose of Google Analytics components is to analyse the flow of visitors to our website. Google uses the data and information obtained to evaluate the use of our website with a view to drawing up online reports for us that show the activity on our webpages and providing further services associated with the use of our website.
Google Analytics places a cookie on the information technology system of the data subject. The meaning of cookies is explained above. Placing cookies makes it possible for Google to analyse the use of our website. Each time individual pages of this website that is operated by the controller and into which a Google Analytics component is integrated are called up, the Internet browser on the information technology system of the data subject is automatically prompted by the Google Analytics component to transfer data to Google for the purpose of an online analysis. As part of the technical process, Google receives knowledge about personal data such as the IP address of the data subject, which helps Google to track the origin of visitors and what they click on and subsequently enables commission settlements.
Through the cookie, personal information is stored such as the access time, where the access was made and the frequency of visits to our website by the data subject. For every visit made to our website, this personal data, including the IP address of the Internet connection used by the data subject, is transferred to Google in the US. This personal data is stored by Google in the US. Google may disclose the personal data collected through this technical process to third parties.
The data subject can prevent cookies from being placed by our website, as mentioned above, at any time via the relevant settings on the Internet browser in use, thus permanently preventing the placing of cookies. Settings of this kind on the Internet browser used would also prevent Google from placing a cookie on the information technology system of the data subject. Furthermore, a cookie that has already been placed by Google Analytics on an Internet browser or other software program can be erased at any time.
The data subject also has the option to object to and prevent the collection of the data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the following link: tools.google.com/dlpage/gaoptout. This browser add-on uses JavaScript to inform Google Analytics that data and information about the visits to websites may not be transferred to Google Analytics. The installation of the browser add-on will be considered as an objection by Google. If the information technology system of the data subject is erased, formatted or reinstalled at a later date, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person under their control, it is possible to reinstall or reactivate the browser add-on.
You can find further information and Google’s applicable data protection provisions at policies.google.com/privacy and at www.google.com/analytics/terms/us.html.
Date of publication
This data protection statement was published on 1 March 2019 and can be amended at any time.