In this privacy policy, we explain how we collect and otherwise process personal data. This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation and similar documents may regulate specific matters. Personal data refers to all information relating to an identified or identifiable person.

If you provide us with the personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only provide us with their personal data if you are authorised to do so and if this personal data is correct.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA") and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case.



Gotthard Partners AG is responsible for the data processing described here. If you have any data protection concerns, you can send them to us at the following contact address: Gotthardstrasse 21, 8002 Zurich or via info@gotthardpartners.ch.



We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other persons involved or that we collect when operating our website.

Insofar as this is permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet), from authorities and other third parties. In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information in connection with your professional functions and activities, information about you in correspondence and meetings with third parties, information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. information to comply with legal requirements such as, for example, the legal requirements of the Swiss Federal Data Protection Act), information to comply with legal requirements such as the fight against money laundering, information from banks, sales and other contractual partners of ours for the utilisation or provision of services by you (e.g. payments made, purchases made)), information from the media and Internet about your person (insofar as this is appropriate in the specific case, e.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, your interests. ), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).



We use the personal data we collect primarily to conclude and process our contracts with our clients and business partners, in the context of asset management services for our clients and the purchase of products and services from our suppliers, as well as to fulfil our legal obligations in Switzerland and abroad. If you work for such a client or business partner, your personal data may of course also be affected in this function.

In addition, we also process personal data of you and other persons, to the extent permitted and deemed appropriate by us, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• Offering and further development of our offers, services and website and other platforms on which we are present;
• Communication with third parties and processing their enquiries (e.g. applications, media enquiries);
• Examination and optimisation of procedures for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for the purpose of customer acquisition;
• Advertising and marketing (including the organisation of events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time and we will then place you on a blacklist against further advertising mailings);
• Market and opinion research, media monitoring;
• Assertion of legal claims and defence in connection with legal disputes and official proceedings;
• Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analyses to combat fraud);
• Ensuring our operations, in particular IT, our website and other platforms;
• Other measures for IT, building and asset security and protection of our employees and other persons and assets belonging to or entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone recordings);
• Purchase and sale of business divisions, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and compliance with legal and regulatory obligations and internal regulations of Gotthard Partners AG.

If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place.



We use "cookies" and similar technologies on our website to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. This enables us to recognise you when you return to this website, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. If you block cookies, certain functions may no longer work. By using our website, you consent to the use of these technologies. If you do not want this, you must set your browser or e-mail programme accordingly.



As part of our business activities and for the purposes set out in section 3, we also disclose data to third parties to the extent permitted and deemed appropriate, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following parties:

• Service providers of ours (e.g. banks, insurance companies), including contract processors (such as IT providers);
• Dealers, suppliers, subcontractors and other business partners;
• Customers;
• Domestic and foreign authorities, official bodies or courts;
• The media;
• The public, including visitors to websites and social media;
• Competitors, industry organisations, associations, organisations and other bodies;
• Acquirers or parties interested in acquiring business divisions, companies or other parts of Gotthard Partners Ltd;
• Other parties in potential or actual legal proceedings;

Some of these recipients are located in Switzerland, but some may be located anywhere in the world, as well as in other countries in Europe and the USA where the service providers we use are located.

If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection law (we use the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exception. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the fulfilment of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.



We process and store your personal data for as long as is necessary for the fulfilment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as far as possible. Shorter retention periods of twelve months or less generally apply to operational data (e.g. system protocols, logs).



We take appropriate technical and organisational security precautions to protect your personal data from unauthorised access and misuse, such as issuing instructions, training, IT and network security solutions, access controls, encryption of data carriers and transmissions, checks.



As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfilment of the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or fulfil a contract with you. The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.



You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing, as well as to the disclosure of certain personal data for the purpose of transfer to another organisation (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we may invoke this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature cancellation of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.

The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.

Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner http://www.edoeb.admin.ch).



We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.