Privacy Notice

Last modified: 19th of May 2020

Persons who access information published on the website of vestr AG (https://www.vestr.com/) agree to the following conditions.

This privacy notice informs you how we collect, use, share, retain and protect personal data received through the vestr.com family of websites (“website”) and our branded social media pages (such as our LinkedIn page) (“social media”). Our website and social media are hereinafter jointly referred to as “online platform”.

We may occasionally update this privacy notice. We encourage you to periodically review this privacy notice to be informed of how we use your information.

1. Who we are

We are vestr AG (“we”, or “us”), a Swiss company registered at Gubelstrasse 11, 6300 Zug, Switzerland. We are the data controller responsible for the processing of personal data through our online platform.

2. How we obtain personal data

We may collect and receive personal data through our online platform. Personal data means any information relating to an identified or identifiable natural person.

We collect personal data that you choose to voluntarily provide to us for your use of our online platform.

2.1. Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

2.2. Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

2.3. Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

3. The types of personal data we may obtain

We may collect and receive the following personal data from you:

  1. Name and contact details (such as name, address, email, username, phone numbers);
  2. Personal data included in your traffic data;
  3. Personal data included in your comments;
  4. Personal data of individuals included in your uploaded content (such as name and email address).

We may collect other types of personal data if required under applicable law or if necessary, for the purposes listed below.

4. Purposes and legal basis for processing

Handling contact and user support requests:
If you fill out a contact-form or request user support, or if you contact us by other means including via a phone call, we may process your personal data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.

Developing and improving our online platform:
We may process your personal data to analyze trends and to track your usage of and interactions with our online platform to the extent it is necessary for our legitimate interest in developing and improving our online platform and providing our users with more relevant content and service offerings, or where we seek your valid consent.

Identifying customer opportunities:
We may process your personal data to assess new potential customer opportunities to the extent you have provided your prior consent.

Displaying personalized content and ads:
We may process your personal data to conduct marketing research, advertise to you, provide personalized information about us on and off our online platform and to provide other personalized content based upon your activities and interests to the extent you have provided your prior consent.

Managing our relationship with you:
We may process your personal data to send you marketing information, product recommendations and other non-transactional communications about us and our partners, including information about our products, promotions or events to the extent you have provided your prior consent.

Reviewing compliance with the applicable terms and conditions; ensuring the security of our business, preventing or detecting fraud or abuses of our online platform:
We may process your personal data by tracking the use of our online platform, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and conditions to the extent it is necessary for our legitimate interest in promoting the safety and security of the online platform and in protecting our rights and the rights of others.

Complying with legal obligations:
We may process your personal data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our online platform, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.

5. How we may share personal data

We may share the personal data we collect and receive on a need to know basis with the following parties:

  1. Other affiliates of vestr or its agents;
  2. Third-party providers that perform services for us;
  3. Other users of the online platform if you choose to share your messages;
  4. Competent public authorities or other third parties (if required by law or reasonably necessary to protect the rights, property and safety of ourselves or others).
  5. Visitor comments may be checked through an automated spam detection service.

We may also transfer your personal data in the event that we sell or transfer all or a portion of our business or assets on a need to know basis. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with applicable law and this privacy notice.

We do not sell, rent or trade your personal data.

6. Links

Our online platform may contain links to other sites. We are not responsible for the content or privacy practices of such other sites. Pay attention when you leave our website and read the privacy notices of any other site that collects personal data. Your data protection and privacy rights under these third-party platforms will be governed by their respective privacy practices.

7. Use of cookies and similar technologies

We collect certain personal data by using cookies and similar technologies when you visit the website.

Cookies are bits of text that are placed on your computer’s hard drive or mobile device when you visit the website. Cookies hold information that may be accessible by the party that places the cookie, which is either the website itself (first part cookie) or a third party (see section THIRD-PARTY COOKIES).

We use both session-based and persistent cookies on our website. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

To change your cookie settings and preferences for our website, click the “Cookie Preferences” link in the footer of the page. You can also control the use of cookies on your device but choosing to disable cookies on your device may limit your ability to use some features on our website.

8. The purpose of setting cookies and similar technologies

We categorize our website cookies and similar technologies as follows:

  1. Strictly Necessary Cookies (Category 1)
    These cookies are absolutely necessary for you to browse the website and use its features, such as accessing secure areas of the website.
  2. Performance Cookies (Category 2)
    These cookies gather website statistical data to analyze how our users use the website, such as which pages are visited, how long pages were visited, and the paths taken by visitors to our website as they move from page to page.

9. Third-Party Cookies

We may use third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.

Third-party Performance Cookies (Category 2):

We may use Google Analytics by Google, Inc (“Google”) and HubSpot, Inc. (“HubSpot”) to the extent you have provided your prior consent:

  1. Google Analytics is a web analytics service which uses cookies to help analyze the website usage. The information generated by the cookie about your use of our website (such as your IP address, the URL visited, the date and time the page was viewed) will be transmitted and stored by Google on servers in the United States or any other country in which Google maintains facilities. Your IP address will be masked by setting the last octet of your IP address to zero before it is stored by Google. Google will use this information to monitor your use of our website, and to compile reports on website activity for us.
  2. HubSpot is a web analytics service which uses cookies to track visitors of our website. The information generated by the cookies about your use of our website (such as your IP address, the URL visited, the date and time the page was viewed) will be transmitted and stored by HubSpot on servers in in the Republic of Ireland. We use all information collected exclusively for optimizing our marketing measures.

10. How we protect personal data

We maintain appropriate technical and organizational security safeguards designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, due the inherent open nature of the Internet, we cannot guarantee that communications between you and us or the personal information stored is absolutely secure. We will notify you of any data breach that is likely to have unfavorable consequences for your privacy in accordance with applicable law.

11. How long we retain personal data

We retain personal data for as long as necessary to fulfil the purposes for which we collect or receive the personal data, except if required otherwise by applicable law. Typically, we will retain most of the personal data for the duration of your use of the online platform, unless a longer applicable statutory retention period applies.
After expiry of the applicable retention periods, your personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

12. Your rights

You have the following rights in relation to your personal data:

  1. The right to obtain, at reasonable intervals and free of charge, information on whether your personal data are being processed and to receive the personal data that is being processed in an intelligible form;
  2. The right to have your personal data rectified, blocked or deleted if your personal data are incorrect, incomplete, inaccurate, irrelevant, outdated or processed unlawfully;
  3. The right to withdraw your consent at any time;
  4. The right to transfer your personal data to another controller, to the extent possible;
  5. The right to object on legitimate grounds to the processing of your personal data.
  6. If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

To exercise these rights, please contact us using our contact details set out below. We may request you to provide a copy of your ID card or otherwise evidence your identity. We will respond to your request within the applicable statutory term.

13. How to contact us

If you have any comments or inquiries about the information in this privacy notice, if you would like us to update your personal data, or if you want to exercise your rights, please contact us by email at info@vestr.com.