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Privacy Notice
This Privacy Notice informs you about how SwissDirekt AG (Prosperity, we, or us), and, to the extent applicable, our affiliates, treat your personal data (Data) according to the Swiss Federal Act on Data Protection (DPA) and/or (as applicable) the EU General Data Protection Regulation (GDPR and, together with the DPA and other applicable laws, the Data Protection Laws) collected from you, or provided by you, when accessing our website (link) (the Website) and as otherwise specified herein.

1. Controller and Contact Details
For the purposes of Data Protection Laws, the Controller is SwissDirekt AG of Lauriedhofweg 1, 6300 Zug, Switzerland (or, in case of one of our subsidiaries using this Privacy Notice by reference, such subsidiary). You may contact us by email at info@prosperityam.ch.

2. What Kind of Data We Process
We process the following categories of Data:
Usage Data: When accessing our Website, the following information about your device may be collected automatically in so-called server logfiles: server name, IP address, operating system, type of device, browser name and version, date and time of access, address of the Website from which you were redirected to our Website (regarding cookies used on our Website please see our Cookie Notice).

3. Purpose and Legal Basis of Data Processing
We collect and process Data in the following situations for the indicated purpose(s) and, within the scope of applicability of GDPR, based on the legal basis as indicated:
Website: When you access our Website, we process Usage Data for the purposes of operating and securing our Website, in particular for security reasons to ensure the stability and integrity of our systems. Within the scope of the GDPR, such processing is based on our legitimate interest (GDPR 6.1.f). We may also use cookies as set out in our Cookies Notice. Furthermore, we may analyse your use of our Website with web analysis tools, including Google Analytics (with IP anonymization activated), in order to optimise our Website regarding usability and to gain insight about the use of our Website. The collected data will not be merged with other personal data or disclosed to third parties. Within the scope of GDPR, such processing is based on our legitimate interest (GDPR 6.1.f). Further information on the use of data by Google and configuration options can be found here: https://www.google.com/intl/en/policies/privacy/partners. Under certain circumstances, we may also collect and process Data for the following purpose(s) and, within the scope of applicability of the GDPR, based on the legal basis as indicated:
a) To preserve our legal interests, e.g. by enforcing or defending our legal rights. Within the scope of the GDPR, such processing is based on our legitimate interest (GDPR 6.1.f).
b) To comply with a legal obligation to which we are subject. Within the scope of the GDPR, such processing is based on the corresponding legal obligation (GDPR 6.1.c).

4. How Personal Data Is Collected
We use different methods to collect Data. In most cases, you provide such Data to us in your interactions with us, e.g. by accessing our Website.

5. No Obligation to Provide Data
You are under no obligation to provide Prosperity with any Data. However, if you do not make the necessary Data available to us, we may not be able to interact with you or provide the corresponding services to you.

6. How Long we Retain Data
We retain / store Data in general as follows:
Usage Data: As long as (i) required to enable the requested access and secure the stability and integrity of our systems, (ii) where processed for the purpose of website analysis for as long as required to perform such analysis (see also our Cookies Notice), and (iii) as part of any other data category as applicable for such category.
After the above storage periods, your personal data will be deleted (or anonymised), if and to the extent (a) we are not legally obliged to retain such data (e.g. for accounting or document retention purposes) and (b) we do not have an overriding legitimate interest to retain such data for the assessment or exercise of, or for the defence against, legal claims.

7. Data Transfers
We may use service providers (including other members of the Prosperity group) for the hosting and operation of our Website, cloud and database services and further services. Such service providers may have access to your Data, strictly limited to the performance of their services for us. Otherwise, we do not transfer your Data to any third parties. In general, your Data is processed in Switzerland, the European Union (EU) or the European Economic Area (EEA), or in other countries that are considered to guarantee an adequate level of data protection according to the DPA and the GDPR, such as e.g. the United Kingdom. If we transfer Data to (or grant access to Data from) a third country which does not meet this requirement, we ensure that appropriate safeguards are in place, such as the EU Standard Contractual Clauses, amended to comply with Swiss data protection law.

8. Data Security
We have put appropriate technical and organizational security policies and procedures in place to protect your Data from loss, misuse, alteration, or destruction. We limit access to personal data in general. Those individuals who have access to the data are required to maintain the confidentiality of such information.

9. Right to Object
You have the right to object to the processing of your Data if (a) the processing takes place for direct marketing purposes; or (b) the processing is based on our legitimate interest (GDPR 6.1.f), by explaining the particular reasons and circumstances of your objection. Regarding cookies through which certain personal data may be collected, you can block the setting of such cookies at any time by changing the settings in your browser accordingly or taking appropriate steps as set out in our Cookies Notice. You will then be notified whenever your browser attempts to create a cookie and you can decide whether you want to allow the cookie or not. Please note that a deactivation of cookies may result in a limited user experience and you may not be able to use every function of our Website or services or to access the services in an appropriate manner altogether. For further information, please refer to our Cookies Notice.

10. Your Rights
You have the right to request information about your Data we process. In particular, you have – or may have, depending on the circumstances – the right to:
a) Information, i.e. to ask us whether we are processing Data about you, and if so, to provide you with further information related thereto.
b) Correction, i.e. to ask us to correct your Data if it is incorrect or incomplete.
c) Deletion, i.e. to delete your Data (to the extent we are not under a legal obligation or have an overriding legitimate interest to retain such data).
d) Restrict Processing, i.e. to ask us to temporarily restrict our processing of your Data.
e) Data Portability, i.e. to ask us to provide you in electronic form (to the extent technically feasible) the Data you have provided to us.
f) Withdraw Your Consent, i.e. to withdraw your consent (if and to the extent you have previously given your consent) to any specific purpose of processing of your Data. This will not affect the lawfulness of any processing carried out before you withdraw your consent and it may mean that we will no longer be able to provide our services to you.
In case you wish to exercise any of these rights, please contact us as specified in Section 1. Before responding to your request, we may ask for proof of identity. This helps us to ensure that your Data is not disclosed to any person who has no right to receive it.

11. Complaint / Regulatory Authority
If you believe that our processing of your Data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the competent data protection authority. The data protection authority for Prosperity is the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Berne, Switzerland (https://www.edoeb.admin.ch).