Effective date: 01/09/2019

Elvinvest Capital SA (hereinafter referred to as “Elvinvest”) operates the www.elvinvest.ch website (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

1. Service. Service is the www.Elvinvest.ch website operated by Elvinvest Capital SA
2. Personal Data. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
3. Usage Data. Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
4. Cookies. Cookies are small files stored on your device (computer or mobile device)
5. Data Controller. The data controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are or are to be processed. For the purposes of this Privacy
   Notice, Elvinvest is the data controller of your personal data.
6. Data processor (or Service Providers). The data processor (or Service Provider) means any natural or legal person who processes the data on behalf of the data controller. We may use the services of several suppliers in order to process your data more effectively.
7. Data subject (or user). The data subject is a living individual who is using our service and is the subject of personal data.

While using our Service, we may ask you to provide us with certain personally identifiable
information that can be used to contact or identify you (“Personal Data”). Personally identifiable
information may include, but is not limited to:

● Email address
● First name and last name
● Phone number
● Address, State, Province, ZIP/Postal code, City

We can gather information about the user:
● Directly by the person concerned, for example through a contact request originating from the user;
● Indirectly from external sources, including all publicly available sources, information available through subscription services or information provided by third parties.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us:
● By email: [email protected]
● By mail: Elvinvest Capital SA, 12 Place de la Fusterie, 1204 Geneva, Switzerland

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier.
Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
Most browsers are set up to accept cookies by default but you can amend your preferences through your browser settings to refuse cookies.
There are a number of ways in which you can manage your cookie preferences depending on the browser or device you are accessing our services from. You can refer to your browser’s ‘help’ function for further details.

However, please remember that cookies are often used to enable and improve certain functions. If  you choose to switch some cookies off, it is likely to affect how our website works. Examples of  Cookies we use:

● Session Cookies. We use Session Cookies to operate our Service. These cookies collect statistical information such as number of users, frequency and duration of visits, number of pages visualised, response time of our systems, frequency of use of our online functions, etc.
This information is used to improve our website’s features such as system performance and user navigation, as well as the most frequently accessed pages and related services. These cookies may use third-party technologies such as Google Analytics, which collect such data as the number of visitors, where visitors have navigated from, and the pages they have visited on our website. That data allows us to monitor how visitors use our website, to compile reports and to improve our systems. For further information, please see Google’s privacy policy here.
● Preference Cookies. We use Preference Cookies to remember your preferences and various settings, these cookies are used to make your online experience more personalized and seamless. For example, they may remember the device you connect from, the choices you make such as the country you visit from, your preferred language, and your search settings.
The information collected may be personally identifiable, such as your user name. These cookies are active only when you are on our website and become inactive when you leave.
● Security Cookies. We use Security Cookies for security purposes.

Elvinvest uses the collected data for various purposes:

● To provide and maintain our Service
● To notify you about changes to our Service
● To allow you to participate in interactive features of our Service when you choose to do so
● To provide customer support
● To gather analysis or valuable information so that we can improve our Service
● To monitor the usage of our Service
● To detect, prevent and address technical issues
● To provide you with news, special offers and general information about goods, services and events which we offer unless you have opted not to receive such information
● To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
● Purpose profiling: assess certain characteristics of the user on the basis of personal data processed automatically, inter alia, propose offers, provide advice or information to customize our services

If you are from the European Economic Area (EEA), Elvinvest’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Elvinvest may process your Personal Data because:

● We need to perform a contract with you
● You have given us permission to do so
● The processing is in our legitimate interests and it is not overridden by your rights
● For payment processing purposes
● To comply with the law
● To provide you with news, special offers and general information about goods, services and events which we offer unless you have opted not to receive such information
● To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Elvinvest will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Elvinvest will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Switzerland and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Elvinvest will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

If Elvinvest is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Under certain circumstances, Elvinvest may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Elvinvest may disclose your Personal Data in the good faith belief that such action is necessary to:

● To comply with a legal obligation
● To protect and defend the rights or property of Elvinvest
● To prevent or investigate possible wrongdoing in connection with the Service
● To protect the personal safety of users of the Service or the public
● To protect against legal liability

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Elvinvest aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

● The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
● The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
● The right to object. You have the right to object to our processing of your Personal Data.
● The right of restriction. You have the right to request that we restrict the processing of your personal information.
● The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
● The right to withdraw consent. You also have the right to withdraw your consent at any time where Elvinvest Capital SA relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).