Privacy policy

Data protection is of a particularly high priority for 3V Asset Management AG. With this privacy policy, we inform data subjects about the processing of their personal data and inform data subjects about the assertion of their rights. We process personal data when data subjects visit our website, enter into a client relationship or other type of contractual relationship with us and/or purchase services and products from us, apply to us or otherwise have dealings with us. We will inform the data subjects in good time of any additional processing activities not mentioned in this privacy policy.

The processing of personal data is carried out in accordance with Swiss data protection legislation and, insofar as applicable, the General Data Protection Regulation.

We process personal data that we receive from data subjects or third parties. Where permitted and appropriate, we then obtain personal data ourselves, e.g. from publicly accessible sources such as the Internet, newspapers and reports.

If you provide us with personal data of other persons, you must be authorised to do so, e.g. by having obtained the permission of the persons concerned. The data must then be correct. Please also ensure that the persons have read and understood this privacy policy.

The 3V Asset Management AG website can generally be used without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data.

As the controller, 3V Asset Management AG has implemented numerous technical and organisational measures to ensure that personal data is protected as completely as possible. Nevertheless, data transmissions may in principle have security gaps, meaning that absolute protection cannot be guaranteed.

1. Definitions

We use the following terms, among others, in this privacy policy:

1.1 Personal data and personal data

Pursuant to Art. 4 (1) GDPR, "personal data" within the meaning of the GDPR means any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

According to Art. 5 lit. a FADP, "personal data" within the meaning of the FADP is all information relating to an identified or identifiable natural person.

1.2 Person concerned

"Data subject" within the meaning of the GDPR is any identified or identifiable natural person whose personal data is processed by the controller in accordance with Art. 4 para. 1 GDPR.

"Data subject" within the meaning of the FADP is a natural person about whom personal data is processed in accordance with Art. 5 (b).

1.3 Processing and finishing

"Processing" within the meaning of the GDPR means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, in accordance with Art. 4 (2) GDPR.

According to Art. 5 lit. d of the FADP, "processing" means any handling of personal data, regardless of the means and procedures used, in particular the collection, storage, retention, use, modification, disclosure, archiving, erasure or destruction of data. In this document, this term is used synonymously with processing, but all types of processing are to be understood in accordance with the GDPR and the FADP.

1.4 Controller or controller responsible for the processing

"Controller" within the meaning of the GDPR pursuant to Art. 4 (7) GDPR or "controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

"Controller" within the meaning of the FADP is, according to Art. Art. 5 lit. j FADP a private person or federal body which alone or jointly with others determines the purposes and means of the processing.

1.5 Processors and data processors

"Processor" within the meaning of the GDPR is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller in accordance with Art. 4 (8) GDPR.

"Processor" within the meaning of the FADP is, according to Art. Art. 5 lit. k FADP a private person or federal body that processes personal data on behalf of the controller.

1.6 Recipient

"Recipient" within the meaning of the GDPR pursuant to Art. 4 para. 9 GDPR is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not it is a third party. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law shall not be regarded as recipients.

1.7 Third party

"Third party" within the meaning of the GDPR pursuant to Art. 4 (10) GDPR is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Name and address of the controller

The responsible party is:
3V Asset Management AG
Wolleraustrasse 9
CH-8807 Freienbach
Switzerland

T. +41 44 227 10 10
E-mail: info@3vam.ch
Website www.3vam.ch

3. Rights of the data subject

To assert their rights, data subjects can contact the specialist centre listed under point 2 in writing. We would like to point out to data subjects that their rights may not be enforceable or may be restricted under certain circumstances. If this is the case, we will inform the data subjects accordingly.

Finally, data subjects have the right to assert their claims through the courts and/or to lodge a complaint with the competent authority. Such an authority may be based in Switzerland or abroad.

3.1 Right to confirmation

Any data subject may assert the right to request information from the controller as to whether personal data concerning them is being processed.

3.2 Right to information

Every data subject can assert the right to receive information about the personal data stored about him/her and a copy of this information from the controller at any time and, as a rule, free of charge.

Furthermore, the data subject may assert a right to information as to whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject may also assert the right to obtain information about the appropriate safeguards in connection with the transfer.

3.3 Right to rectification

Each data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him or her. Furthermore, the data subject may assert the right granted by the European legislator of directives and regulations to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

3.4 Right to erasure (right to be forgotten)

Data subjects may assert the right to erasure of their personal data. Any data subject may assert the right to request the controller to restrict or block processing.

3.5 Right to data portability

Any person affected by the processing of personal data has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where the processing is based on consent or on a contract and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability, the data subject may obtain that the personal data be transmitted directly from one controller to another, unless this right has been restricted by Swiss or European directives and regulations.

3.6 Right to object

Any person affected by the processing of personal data has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her.

3V Asset Management AG shall no longer process the personal data in the event of the assertion of the right to object, which is enforceable and not restricted, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If 3V Asset Management AG processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. If a data subject exercises his or her right to object to processing for direct marketing purposes vis-à-vis 3V Asset Management AG, which is enforceable and not restricted, 3V Asset Management AG will no longer process the personal data for these purposes.

3.7 Right to withdraw consent under data protection law

Any person affected by the processing of personal data may assert the right granted by the European legislator of directives and regulations to revoke consent to the processing of personal data at any time.

4. Data processing

4.1 Visitors to our website

We process personal data when data subjects visit our website [https://3vam.ch/] or use our app.

In particular, we process the following data:

• Technical data, such as IP address, browser used, operating system, cookies, logs, etc.
• logs etc.
• Data in connection with the use of our contact form

Data in connection with the registration for our customer area

• Data in connection with the sending of mailings and newsletters

Further information on visiting our website and the associated data processing is listed below in section 6.

4.2 Customers

We process personal data that we receive as part of the (initiation of) a client relationship. We receive the data directly from you as part of the provision of our asset management services or in some cases through third parties, such as banks, asset managers, auditors or we obtain the data ourselves.

In particular, we process the following data:

• Master data (e.g. name, address, email address, telephone number, date of birth, gender, nationality, social media profiles, copies of ID cards)
• Contract data, i.e. the data we need to process the contractual relationship with you (e.g. type of contract, services, financial data, etc.)
• Data that we need to fulfil our due diligence checks, e.g. data for identification or background checks
• Data on their preferences, e.g. based on the products and services requested by the data subject
• Financial information
• Communication data

4.3 In the application procedure

In principle, we process the data that we receive from data subjects or from third parties in the context of an application or that we obtain ourselves.

In particular, we process the following personal data:

• Master data (e.g. name, address, email address, telephone number, date of birth, gender, nationality, social media profiles, copies of ID cards)
• Communication data
• Data from the data subject's CV
• Data from the data subject's employment references
• Information from reference persons
• Criminal record extract, debt enforcement register extract or other government information, confirmations, etc.
• Data that we obtain as part of further clarifications (e.g. creditworthiness information, personal data in media reports, etc.)

It is possible that particularly sensitive personal data may be processed. If the consent of the data subject is required for this, we will inform the data subject of this separately.

4.4 Business partners & other third parties

We process personal data that we receive as part of the (initiation of the) business relationship with data subjects or with a business partner or in another context. We receive the data directly from the data subject, from third parties or obtain it ourselves.

In particular, we process the following data:

• Master data (e.g. name, address, email address, telephone number, date of birth, gender, nationality, social media profiles, copies of ID cards)
• Contract data, i.e. the data we need to process the contractual relationship with you (e.g. type of contract, services, financial data, etc.)
• Communication data
• Data that we obtain as part of further clarifications (e.g. creditworthiness information, personal data in media reports, etc.)

5. Purpose of processing

The purpose of processing, i.e. the way in which we process personal data, depends on how the data subject interacts with us.

We process data in particular for the following purposes:

We process data for the establishment, administration and processing of customer and contractual relationships, e.g.

• Provision of our services/offer of our products to you
• Fulfilment of contractually defined obligations
• Fulfilment of our due diligence obligations, e.g. in the context of "Know your Customer" clarifications or supply chain management
• Further development of services and products
• Marketing, including the organisation of events Market and opinion research, statistical surveys, review and optimisation of needs analysis procedures for the purpose of direct customer contact and the collection of personal data from publicly accessible sources for the purpose of customer acquisition
• Sending publications, information on events and for sending newsletters
• Media monitoring
• Assertion of legal and other claims and defence in connection with legal disputes and official proceedings
• Prevention and investigation of criminal offences and other misconduct, including conducting investigations

For communication with you, e.g.

• Making contact
• Exchange of information and answering enquiries
• Relationship management
• Asserting the rights of data subjects

Communication can take place using all common means of communication, e.g. by letter, via e-mail, via an app, by telephone via social media, via chat, via forms on our website, etc.

In connection with ensuring compliance, i.e. if laws and regulations, orders/recommendations etc. from authorities, internal regulations etc. must be complied with or as part of our due diligence investigations.

To operate the website https://3vam.ch/, including authentication when visiting the customer area. Further information is listed below under point 8.

For other purposes such as safeguarding our legitimate interests and our rights, to ensure the functionality of our company (incl. accounting, risk management, granting signatory authorisations, creating employee directories on the intranet, etc.), in the context of M&A transactions, to ensure operational security and to clarify facts/misconduct, for training and educational purposes, etc.

6. Data transfer and data transmission abroad

We may disclose the data of data subjects to third party recipients where necessary based on their consent, or if they need the data to fulfil our contractual and legal obligations or to perform their respective tasks. We may then pass on the data of data subjects to protect our legitimate interests.

In particular, the recipients listed below may receive data from data subjects:

• Third parties such as consultants, accountants, trustees, marketing companies, translation agencies or providers of IT services that process the data of data subjects, as well as other external service providers and bodies, such as banks, asset managers, insurance companies, auditors and associations
• Our contractual partners including our customers, i.e. possibly the employer of data subjects
• Public bodies and authorities (e.g. FINMA, tax authorities) in the event of a legal or regulatory obligation or quality controls
• Third parties who have access to the personal data processed during visits to our website
• Other third parties, e.g. different delivery recipients, payment and service recipients, third parties in the context of M&A transactions, lawyers, industry organisations, etc.

The recipients of the data of data subjects may in turn involve third parties. We restrict the processing by some selected third parties, e.g. by contract For other third parties, this is not always possible (e.g. public bodies and authorities as well as financial intermediaries)

The recipients of the data of data subjects may be located in Switzerland, in Europe and, in exceptional cases, in any other country in the world.

If the data recipient is located in a country without adequate statutory data protection and is not already subject to a recognised set of rules to ensure data protection, corresponding additional protective measures will be necessary, e.g. through contractually agreed specific data protection clauses. However, exceptions to this rule (e.g. in direct connection with the conclusion or execution of a contract, legal proceedings abroad, overriding public or private interest or consent by the data subject) may occur.

7. Routine deletion and blocking of personal data

Personal data will only be stored until the purpose of the processing has been achieved. Personal data will not be deleted if we are obliged to retain it due to a legal or regulatory provision, orders e.g. from authorities or a contractual agreement.

Different retention obligations are also possible if claims can be asserted against our company and if we are otherwise legally obliged to do so or if we have an overriding interest in retaining the data (e.g. for evidence and documentation purposes).

8. Use of our website

If data subjects visit our website (hereinafter referred to as website, internet presence, etc.), this generally leads to data processing.

When the website is visited, log files containing the following information in particular are stored:

• The name of the file accessed
• The time (date and time) of access by the data subject
• The amount of data transferred
• A message about successful retrieval
• Web browser, operating system and the requesting domain
• The IP address

This data is analysed exclusively to improve our offer and does not generally allow any conclusions to be drawn about the person concerned.

However, if the data subject wishes to make use of services offered by us on our website, it is necessary for the data subject to provide further data. This is the data required for the respective processing.

By using our website and any other services based on it, the data subject expressly consents to the associated processing of their personal data.

8.1 Use of data

We use the data we collect about a data subject to provide the products and services we offer, to answer their questions and to operate and improve our websites and applications. We then use personal data to offer the data subject a comprehensive service via our website. Further purposes can be found in section 7.

We will not pass on personal data transmitted online to third parties unless this serves one of the purposes listed in section 8 or, if necessary, the data subject has not given their express prior consent. Data may be passed on to the recipients listed in section 9.

8.2 User profiles

We do not create any personal user profiles. In connection with the retrieval of the information requested by a data subject, data is only stored on our servers in anonymised form for the provision of our various services or for evaluation purposes. General information is logged, for example when which content from our website is accessed or which pages are visited most frequently.

8.3 Cookies

The Internet pages of 3V Asset Management AG use cookies. Cookies are text files that are placed and stored by our web server on a data subject's computer system via an internet browser when they visit our website.

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 string of characters that can be used to assign websites and servers to the specific internet browser in which the cookie was stored. This enables the websites and servers visited 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, 3V Asset Management AG can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimised for the benefit 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 taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of 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 of 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 programmes. 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.

8.4 Collection of general data and information

The website of 3V Asset Management AG collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website can be recorded, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using these general data and information, 3V Asset Management AG does not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the content of our website, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. Therefore, 3V Asset Management AG analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

8.5 Registration on our website

The data subject has the option of registering on the controller's website by providing personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller's own purposes. The controller may arrange for the data to be passed on to one or more processors, such as a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.

By registering on the controller's website, the IP address assigned by the data subject's Internet service provider (ISP), the date and time of registration are also stored. This data is stored against the background that this is the only way to prevent the misuse of our services and, if necessary, to enable criminal offences to be investigated. In this respect, the storage of this data is necessary to safeguard the controller. This data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.

The registration of the data subject with the voluntary provision of personal data serves the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller's database.

The data controller shall provide any data subject with information at any time on request as to which personal data relating to the data subject is stored. Furthermore, the controller shall rectify or erase personal data at the request or notice of the data subject, provided that this does not conflict with any statutory retention obligations.

8.6 Subscription to our newsletter

On the website of 3V Asset Management AG, users are given the opportunity to subscribe to our company's newsletter. The input mask used for this purpose determines what personal data are transmitted to the controller when the newsletter is ordered.

3V Asset Management AG informs its customers and business partners regularly by means of a newsletter about enterprise offers. Our company's newsletter can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation e-mail will be sent to the e-mail address entered by a data subject for the first time for sending the newsletter using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the data subject has authorised the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject's e-mail address at a later date and therefore serves as legal protection for the controller.

The personal data collected when registering for the newsletter is used exclusively to send our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for the newsletter dispatch, can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the controller's website or to inform the controller of this in another way.

8.7 Newsletter tracking

The newsletters of 3V Asset Management AG contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails sent in HTML format to enable log file recording and log file analysis. This allows the success or failure of online marketing campaigns to be statistically analysed. Based on the embedded tracking pixel, 3V Asset Management AG may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimise the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After cancellation, this personal data will be deleted by the controller. The 3V Asset Management AG automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8.8 Contact option via the website

The website of 3V Asset Management AG contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the data controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

8.9 Data protection provisions about the application and use of LinkedIn

The data controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is an Internet-based social network that enables users to connect with existing business contacts and make new business contacts. Over 400 million registered people use LinkedIn in more than 200 countries. This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible for data protection matters outside the USA.

Each time you visit our website, which is equipped with a LinkedIn component (LinkedIn plug-in), this component causes the browser used by the data subject to download a corresponding representation of the LinkedIn component. Further information about the LinkedIn plug-ins may be accessed under developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn recognises with each call-up to our website by the data subject and for the entire duration of their stay on our Internet site, which specific sub-page of our Internet page was visited by the data subject. This information is collected by the LinkedIn component and assigned by LinkedIn to the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores this personal data.

8.10. Data protection provisions about the application and use of Google Analytics (with anonymisation function)

The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analysis is the collection, collation and evaluation of data about the behaviour of visitors to websites. Among other things, a web analysis service collects data about the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analysis 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 data controller uses the addition "_gat._anonymiseIp" for web analysis via Google Analytics. This addition is used by Google to shorten and anonymise the IP address of the data subject's Internet connection if our website is accessed 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 the flow of visitors to our website. Google uses the data and information obtained, among other things, to analyse the use of our website, to compile online reports for us that show the activities on our website and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject's IT 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 is accessed, which is operated by the data controller and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. During the course of this technical procedure, Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which access was made and the frequency of visits to our website by the data subject. Each time our website is 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 process to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the data subject's IT system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programmes.

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 about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is recognised by Google as an objection. If the data subject's IT 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 who is attributable to their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and the applicable data protection provisions of Google may be retrieved under www.google.de/intl/de/policies/privacy/ and under www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link www.google.com/intl/de_de/analytics/.

8.11. Google Maps

Google Maps, a map service of Google Inc ("Google"), is also integrated on this website. Google Maps uses so-called "cookies", text files that are stored on your computer if the data subject uses the map function on our website.

When the data subject clicks on the link, a direct connection is established between the data subject's browser and the Google server. Google thereby receives the information that the data subject has visited our website with their IP address. If the data subject clicks on the Google Maps link while they are logged into their Google account, Google can assign the visit to our pages to their user account.

We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Google. Details on data collection (purpose, scope, further processing, use) as well as on the rights of data subjects and setting options can be found in Google's data protection information.

9. Existence of automated decision-making

We do not use automated decision-making or profiling.

10. Data security

In order to ensure the confidentiality, integrity, availability and traceability of the data we store and process, we take extensive technical and organisational security precautions in our area of responsibility, which are regularly reviewed and adapted to technological progress.

In particular, the following measures have been taken:

• Access restrictions and controls
• Data backups
• IT network and security solutions
• Encryption of data carriers and transmissions
• Instructions
• Training courses
• Controls

11. Changes

This privacy policy may be amended at any time without prior notice. The version published on our website or sent to you by other means shall apply, insofar as it is more recent. Unless otherwise agreed, the data protection declaration is not part of any contract concluded with you.

Update date: 01.09.2023

Legal

Contact Address

3V Asset Management AG
Wolleraustrasse 9
CH-8807 Freienbach

Authorized Representatives

Martin Lehmann, CEO

Commercial Register Information

Registered name of the company: 3V Asset Management AG
Register number: CHE-108.624.972
Commercial registry: Zürich