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Privacy Policy

Contact

Zwei Wealth Experts AG
Genferstrasse 35
CH-8002 Zurich

Phone: +41 43 299 22 22
E-mail: info(at)zwei-we.ch
Website: www.zwei-wealth.com

The controller within the meaning of the Swiss Federal Act on Data Protection (FADP) is the data protection advisor. Any data subject may contact the address stated above directly by e-mail or by telephone at any time with any questions or suggestions concerning data protection.

Introduction

We are very pleased about your interest in our company. Data protection is of particular importance to the management of ZWEI Wealth Experts AG. The use of the website of ZWEI Wealth Experts AG is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to the company. By means of this privacy policy, our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this privacy policy informs data subjects of the rights to which they are entitled.

As the controller, the company has implemented numerous technical and organisational measures to ensure the most complete protection possible of the personal data processed via this website. Nevertheless, internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

Legal basis

The website www.zwei-wealth.com is subject to Swiss data protection law, in particular the Federal Act on Data Protection (FADP), as well as any applicable foreign data protection law, such as the General Data Protection Regulation (GDPR) of the European Union (EU). The EU recognises that Swiss data protection law ensures an adequate level of data protection.

We may amend our privacy policy at any time by publishing the amended version on this website.

Scope

This privacy policy applies to all websites of ZWEI Wealth Experts AG. No guarantee of compliance with data protection provisions is assumed for third-party websites that are linked from www.zwei-wealth.com.

Disclaimer of liability

The operator of the website assumes no liability whatsoever for the correctness, accuracy, timeliness, reliability and completeness of the information provided.

Liability claims against the operator of the website for material or immaterial damage arising from access to or use or non-use of the published information, from misuse of the connection or from technical faults are excluded.

All offers are non-binding. The operator of the website expressly reserves the right to change, supplement or delete parts of the pages or the entire offering without separate announcement, or to suspend publication temporarily or permanently.

Liability for links

Our website contains links to external third-party websites over whose content we have no influence. Therefore, we cannot assume any liability for this third-party content. The respective provider or operator of the pages is always responsible for the content of the linked pages. The linked pages were checked for possible legal violations at the time of linking. No unlawful content was identifiable at the time of linking.

However, permanent monitoring of the content of the linked pages is not reasonable without concrete indications of a legal violation. If we become aware of any legal violations, we will remove such links immediately.

Liability for embedded radio and television content

Our website may contain radio and television content from external third-party websites over whose content we have no influence. Therefore, we cannot assume any liability for this third-party content. The respective provider is always responsible for the content of such contributions. The embedded contributions were checked for possible legal violations at the time of linking. No unlawful content was identifiable at the time of integration.

If we become aware of legal violations in radio or television contributions, we will remove such media immediately.

Surveillance

Access to our website is – like any use of the internet – subject to general, indiscriminate mass surveillance without cause or suspicion by security authorities in Switzerland, the EU, the USA and other countries. The operator of the website has no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities.

Encryption

Access to our website takes place via transport encryption (SSL/TLS).

Server log files

The website www.zwei-wealth.com collects a series of general data and information with each access by a data subject or an automated system. This general data and information is stored in the server log files. The following information may be collected:

  • browser types and versions used
  • the operating system used by the accessing system
  • the website from which an accessing system reaches our website (so-called referrer)
  • the sub-pages accessed via an accessing system on our website
  • the date and time of access to the website
  • an internet protocol address (IP address)
  • the internet service provider of the accessing system and other similar data and information serving to avert danger in the event of attacks on our information technology systems.
  • When using this general data and information, the company does not draw any conclusions about the data subject. Rather, this information is needed to correctly deliver the contents of our website,
  • to optimise the content of our website and the advertising for it,
  • to ensure the long-term functionality of our information technology systems and the technology of our website, and
  • to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.

This anonymously collected data and information is therefore evaluated by the company both statistically and with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

This website is hosted by Intersim AG, Kirchbergstrasse 105, CH-3400 Burgdorf.

Personal data

Personal data is any information relating to an identified or identifiable person. A data subject is a person whose personal data is processed. Processing includes any handling of personal data, irrespective of the means and procedures used, in particular the storage, disclosure, acquisition, deletion, saving, modification, destruction and use of personal data.

We process personal data in accordance with Swiss data protection law. In addition, we process personal data – to the extent that and insofar as the GDPR is applicable – in accordance with the following legal bases:

  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. b GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for the implementation of corresponding pre-contractual measures.
  • Art. 6 para. 1 lit. c GDPR for the processing of personal data necessary for compliance with a legal obligation to which we are subject under any applicable law of the EU or under any applicable law of a country in which the GDPR is fully or partially applicable.
  • Art. 6 para. 1 lit. d GDPR for the processing of personal data necessary to protect the vital interests of the data subject or of another natural person.
  • Art. 6 para. 1 lit. f GDPR for the processing of personal data necessary to safeguard the legitimate interests of us or of third parties, provided that the fundamental freedoms and rights and interests of the data subject do not prevail. Legitimate interests include in particular our business interest in being able to provide our website, information security, the enforcement of our own legal claims and compliance with Swiss law.
  • ZWEI Wealth Experts AG processes personal data for the duration required for the respective purpose or purposes. In the case of longer retention obligations due to legal and other obligations to which we are subject, we restrict processing accordingly.

Disclosure of personal data

Personal data is neither sold nor shared with third parties outside the ZWEI Wealth Experts network.

Cookies

The website of ZWEI Wealth Experts AG 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 character string by which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from 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 AG can provide the users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimised in the interest of the user. As already mentioned, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website, because this is handled by the website and the cookie stored on the user's computer system. Another example is the cookie for a shopping basket in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting in the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

Web analytics

This website uses various services for website analysis and tracking, which we explain in more detail below. We also show you how you can prevent these services from evaluating your usage behaviour on our website. Insofar as we ask for your consent to the use of third-party services, the legal basis for this form of data processing is your consent. If we do not obtain your consent, your personal data will be processed on the basis of our legitimate interests (i.e. for optimisation and marketing purposes and the design of our website in line with your interests).

Google Analytics

The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. Among other things, a web analytics service collects data on the website from which a data subject came to a website (so-called referrer), which sub-pages of the website were accessed or how often and for what length of time a sub-page was viewed. Web analytics is mainly used to optimise a website and for the cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the addition "_gat._anonymizeIp" for web analytics via Google Analytics. By means of this addition, the IP address of the data subject's internet connection is shortened and anonymised by Google if access to our websites takes place from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our websites, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject's information technology system. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website operated by the controller is called up and on which a Google Analytics component has been integrated, the internet browser on the data subject's information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

By means of the cookie, personal information such as the access time, the location from which an access originated and the frequency of visits to our website by the data subject is stored. Each time our websites are visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of a corresponding setting in the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the data subject's information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of 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 link tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information on visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is regarded by Google as an objection. If the data subject's information technology system is deleted, 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 attributable to their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google's applicable privacy provisions can be found at www.google.de/intl/de/policies/privacy/ and at www.google.com/analytics/terms/de.html.

Google Ads

We use Google Ads, an online advertising programme from Google. Google Ads uses cookies to analyse the use of the website. A cookie is set when you reach our website via a Google ad. Cookies of this type have a limited validity, do not contain any personal data and therefore do not serve the purpose of personal identification. If you visit certain ZWEI Wealth web pages and the cookie has not yet expired, we and Google can recognise that you clicked on the ad and were redirected to this page.

You can generally prevent the storage of cookies by deactivating the storage of cookies in your browser. You also have the option of objecting to interest-based advertising by Google Ads by making the corresponding settings at https://adssettings.google.de.

Further information on data protection at Google Ads can be found at https://policies.google.com/privacy?hl=de and https://policies.google.com/technologies/ads?hl=de.

Google Ads conversion tracking

We use the online advertising programme "Google Ads" on our website and, within this framework, conversion tracking (visit action evaluation). Google Ads conversion tracking is an analysis service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). If you click on an ad placed by Google, a cookie for conversion tracking is set on your device. These cookies have a limited validity, do not contain any personal data and therefore do not serve the purpose of personal identification. If you visit certain pages of our website and the cookie has not yet expired, Google and we can recognise that you clicked on the ad and were redirected to this page. The information obtained with the help of the conversion cookie is used to create conversion statistics. This tells us the total number of users who clicked on one of our ads and were redirected to a page with a conversion tracking tag. However, we do not receive any information that can be used to personally identify users. You can prevent the storage of cookies by selecting the appropriate technical settings in your browser software. However, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You will then not be included in the conversion tracking statistics. Furthermore, you can deactivate personalised advertising in the settings for advertising at Google. Instructions on this can be found at https://support.google.com/My-Ad-Center-Help/answer/12155764.

Google Tag Manager

We use Google Tag Manager, a service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"), to manage website tags via an interface. Google Tag Manager itself (which implements the tags) is a cookie-less domain and does not process any personal data. The service triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it remains in place for all tracking tags implemented with Google Tag Manager.

Through the use of Google Tag Manager, scripts (so-called tags) can be activated automatically on our website and data can be transmitted from your browser to Google. This data may include information about your IP address, the browser you are using, the sub-pages of our website you have visited and other interactions during your visit to our website.

LinkedIn Insight Tag

We have integrated the LinkedIn Insight Tag on our website, a tool from LinkedIn, a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland ("LinkedIn"). The LinkedIn Insight Tag enables us to collect information about the visitors to our website, in particular about the type of LinkedIn functions that visitors to our website use and how they interact with these functions. This tool helps us to create targeted advertisements within the LinkedIn platform and to measure the effectiveness of these advertisements. Through the use of the LinkedIn Insight Tag, cookies are set on your device, which enable the collection of pseudonymised data, such as the URL of the page visited, the referrer URL, IP address (in shortened form), device and browser properties and timestamps. The data collected by the LinkedIn Insight Tag is anonymous to us, which means that we do not receive any personal data of individual users. However, this data is stored and processed by LinkedIn, so that a connection to the respective user profile is possible and LinkedIn can use the data for its own advertising purposes in accordance with the LinkedIn privacy policy. If you are a member of LinkedIn and are logged into your LinkedIn account while visiting our website, the data collected by the LinkedIn Insight Tag will be linked to your LinkedIn account.

The use of the LinkedIn Insight Tag serves the purpose of analysing and optimising the effectiveness of our advertising measures. The data processing is based on our legitimate interest in targeted advertising and the analysis of the effect and efficiency of this advertising.

Meta Ads

Our website uses Meta Ads, an online advertising service of Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA (formerly known as Facebook, Inc.). With the help of Meta Ads, we can place targeted advertisements to draw users' attention to our products or services. When you visit our website, a cookie may be set on your device via Meta Ads, which enables an analysis of your use of the website. In addition, Meta can use this cookie to track your usage behaviour across different websites and devices and place personalised advertisements on this basis. The data collected by the cookie is transmitted to Meta and stored there. This data can be linked by Meta to your Meta account (formerly Facebook account) and used for its own advertising purposes. To generally object to the use of cookies on your computer, you can set your internet browser so that no cookies can be stored on your computer in the future or so that cookies that have already been stored are deleted. However, switching off cookies may mean that some functions of our website no longer work properly.

Further information on the handling of user data at Meta Ads can be found in Meta's privacy policy: https://www.facebook.com/privacy/policy/. If you do not want Meta to use data for advertising purposes, you can adjust the corresponding settings in your Meta account.

Microsoft Clarity

Our website uses Microsoft Clarity, a web analytics service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft Clarity helps us to better understand user behaviour on our website by recording interactions such as clicks, scrolling and mouse movements. This enables us to optimise the user experience on our website. Microsoft Clarity uses cookies and other technologies to collect data such as IP addresses, browser type, operating system, pages visited, time spent and other similar information. This data is anonymised and serves to identify user trends and continuously improve our website. Microsoft stores this data securely and takes appropriate data protection measures to protect it from unauthorised access. The data is not used to personally identify individual users.

Forms and e-mail contact

The website of ZWEI Wealth Experts AG may contain forms for making contact and/or transmitting data. It is also possible to contact ZWEI Wealth Experts AG by e-mail. If a data subject contacts the company via one of these forms or by e-mail, the personal data entered and transmitted by the data subject is stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

Rights of data subjects

Visitors to www.zwei-wealth.com and other persons whose personal data we process may, free of charge, request confirmation as to whether personal data is being processed by us and, if so, information about our processing of 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 personal data corrected, deleted ("right to be forgotten") or blocked, revoke consent given and object to the processing of their personal data.

Persons whose personal data we process have the right to lodge a complaint with a competent data protection supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

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Date of publication

This privacy policy was published on 1 March 2019 and may be amended at any time.