Cofund Investment AG
Last update – 4 April 2023

About us

This privacy policy ("Privacy Policy") explains how we process and protect your personal data whenyou use this Website or our services provided via (together, the "Website").

The Website is operated by Cofund Investment AG, Gartenstrasse 6, 6300 Zug, Switzerland (the"COMPANY", "we", "our", or "us"). The Company is the controller for the data processing described below.

Unless otherwise defined in this Privacy Policy or our General Terms & Conditions, the definitions usedin this Privacy Policy have the same meaning as in the Swiss Federal Act on Data Protection.

1 Personal data we collect

We may collect or receive personal information for a number of purposes connected with our businessoperations when you use our website or our services. This may include the following:
● Contact details.
● Login details.
● Investment details.
● Device details.
● Due Diligence (“DD”) and Know Your Customer (“KYC”) details.

2 How we collect personal data

We collect information about our users when they use our Website or our services, including takingcertain actions within it.


● When users access, use, or otherwise interact with our Website.
● When users correspond with us by electronic means.
● When users submit their data to us.
● When user registers as a user of our Services with the intention of becoming an Investor or Sponsor.


● From public sources, such as public directories.
● From third parties, such as social media plugins and third-party cookies.

3 Legal basis and purposes

Our legal basis for collecting and using the personal data described in this Privacy Policy depends onthe personal data we collect and the specific purposes for which we collect it.

Contract: To perform our contractual obligations or take steps linked to a contract with you. In particular:

● To provide our services.
● To recruit you.

Consent: We may rely on your freely given consent at the time you provided your personal data.

Legitimate interests: We may rely on legitimate interests based on our assessment that the processingis fair and reasonable and does not override your interests or fundamental rights and freedoms. Inparticular:

● To maintain and improve our Website and services.
● To develop new services.

Necessity for compliance with legal obligations: To meet regulatory and public interest obligations.In particular:

● To comply with applicable regulations and legislation, namely regarding DD and KYCprocesses.
● For the legal enforcement of claims and rights.
● For security and fraud prevention.

4 Data retention

We retain personal data for so long as it is needed for the purposes for which it was collected or in linewith legal and regulatory requirements or contractual arrangements. In particular:

● Active accounts – In order to provide, improve, and administer our Services, we may retain allpersonal information collected about you so long as you are a User with an active account.
● Ownership records – In order to create reliable property and investment records, we willsecurely store information about properties and investments, including DD information andsuccessive title ownership, indefinitely. This may include certain details considered as yourpersonal information.
● Record retention policies and regulations – We comply with tax, accounting and other legalrecord retention requirements. For risk management reasons, we may adopt policies to retainrecords for a longer time period than the legal minimum.

5 Service providers

The Company may engage third party companies ("Service Providers") to facilitate the operation ofour Website, assist in analyzing the usage of the Website, or perform Website and service-relatedservices, such as payment and the provision of IT infrastructure services. These third parties haveaccess to the user’s personal data only to the extent necessary to perform these tasks on behalf of the

Type(s) of service providers who might access your personal data:

● Accounting firms
● Consultants
● Lawyers
● Appraisers
● Public authorities
● Affiliates. We may share your information with our affiliates, such as our shareholders,subsidiaries, joint venture partners, and companies that we control or that are under commoncontrol with us.
● Other group entities

6 Data transfers

The Company and/or the Service Providers may transfer your personal data to and process it in thefollowing countries:

● Switzerland

We may use service providers who are partly located in so-called third countries (outside Switzerland)or process personal data there, i.e. countries whose level of data protection does not correspond to thatof Switzerland.

We safeguard your personal data per our contractual obligations and applicable data protectionlegislation when transferring data abroad.Such safeguards may include:

● the transfer to countries that have been deemed to provide an adequate level of protectionaccording to lists of countries published by the Federal Data Protection and Information Commissioner;
● applying standard data protection model clauses, binding corporate rules or other standardcontractual obligations that provide appropriate data protection.

If a third country transfer takes place and there is no adequacy decision or appropriate safeguards, it ispossible and there is a risk that authorities in the third country (e.g. intelligence services) can gainaccess to the transferred data and that the enforceability of your data subject's rights cannot beguaranteed.

7 Cookie usage

Our website uses cookies and similar technologies (collectively “tools”) provided either by us or by thirdparties. A cookie is a small text file that is stored on your device by the browser. Comparable technologies are in particular web storage (local / session storage), fingerprints, tags or pixels. Mostbrowsers are set by default to accept cookies and similar technologies. However, you can usually adjustyour browser settings so that cookies or similar technologies are rejected. If you refuse cookies orsimilar technologies, you may not be able to use all of our services without problems.

In order to improve our website, we use tools to collect statistics and analyse general usage behaviour based on access data. We also use analytics services to evaluate the use of our various marketingchannels.

7.1 Google Analytics 4

Our website uses the web analytics service Google Analytics 4, which is provided by Google IrelandLimited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). If you have not consented to theuse of the analytics tools, your data will not be collected as part of Google Analytics 4.

Google Analytics 4 uses JavaScript and pixels to read information on your terminal device and cookiesto store information on your terminal device. This is used to analyse your usage behaviour and toimprove our website. The access data is compiled by Google on our behalf into pseudonymous usageprofiles and transferred to a Google server in the USA. We will process the information obtained in orderto evaluate your use of the website and to compile reports on website activities.

The data collected as part of the usage analysis of Google Analytics 4 is enriched with data from theGoogle Search Console and linked to data from Google Ads, in particular to measure the success ofour advertising campaigns (so-called conversions).

The following data may be processed by Google Analytics 4: IP address; user ID and device ID; referrerURL (previously visited page); pages viewed (date, time, URL, title, length of stay); downloaded files;clicked links to other websites; achievement of certain goals (conversions); technical information(operating system; browser type, version and language; device type, brand, model and resolution);approximate location (country, region and city, if applicable, based on anonymised IP address).

Cookies used:
Cookie Name
Expiration Time
1 year, 1 month and 4 days
Used to store and count pageviews, and track unique visitors
1 day
Stores information about howvisitors use the website andcreates an analytics report of thewebsite’s performance
1 minute
Used for behavioral tracking andmanaging the rate of requests tothe server
1 minute
Keeps track of how many times auser visits the website, how theuser came to the website, and the country where the user islocated
3 months
Used to store and trackconversions that occur viaGoogle Ads
90 days
Stores campaign information forthe user, such as the source andmedium of the user’s visit
2 years
Used to distinguish users and tothrottle request rate
90 days
Used to track conversions fromGoogle Ads
90 days
Used to track conversions fromGoogle Ads
Determines if the user’snavigation should be registeredin a certain statistical placeholder
30 minutes
Used to detect if the user isactively engaged with thewebsite
1 year
Sets a unique ID for the session.This allows the website to obtaindata on visitor behaviour forstatistical purposes
This cookie is used to determineif the visitor has visited thewebsite before, or if it is a newvisitor
Used to determine the mostgeneric cookie path to use, inorder to avoid conflicts whenmultiple subdomains are in use
2 minutes
Determines if the user’snavigation should be registeredin a certain statistical placeholder
All of these cookies are used by Google Analytics to collect analytical data and information about userbehavior on the website. They are stored in the user's browser for the duration of time specified above.The cookies may be deleted earlier if the user clears their browser cache or manually removes them intheir browser settings.

To know more about Google's cookie usage, consult its privacy policy here.

7.2 Meta Pixel

Our website uses Meta Pixel, a service provided by Meta Platforms Ireland Limited, 4 Grand CanalSquare, Grand Canal Harbour, Dublin 2, Ireland. Meta Pixel is a tool that allows us to measure theeffectiveness of our advertising by understanding the actions people take on our website. It helps usimplement JavaScript code on our website to track and dynamically provide content to site visitors, bysetting tracking cookies in order to help us understand how our website is used, as well as advertisingcookies in order for us to reach customers in the future through Facebook ads. Site visitors are matchedto their respective Facebook accounts and identified through cookies set on their devices. The MetaPixel tracks URLs and domains visited, as well as the devices used by site visitors.

Tool used:

● _fbp (3 months): used to display advertisements when either on Facebook or on a digitalplatform powered by Facebook advertising, after visiting the websiteTo know more about Meta's cookie usage, consult its privacy policy here.

7.3 Yandex Metrica

Our website uses Yandex Metrica, a service provided by Yandex LLC, a Russian company located at16 Lva Tolstogo St., Moscow, 119021, Russia. Yandex Metrica is a tool that allows us to measure thetraffic to our website, thus enabling us to monitor where traffic comes from, as well as to provide usinformation on our audience, namely their location, device, browser, trends and patterns, pageviewsand sessions. It also allows us to measure any interactions users have with our website, in order totrack conversion funnels.

The Yandex.Metrika counter script uses several cookies to collect and store information about websitevisitors. The specific cookies used by this script are:
Cookie Name
Used to identify unique visitors
1 year
Used to determine the user's firstvisit to the website
Used to determine whether theuser has ad blockers enabled
1 day
Used to record mouse andkeyboard interactions on thewebsite for the purpose ofwebsite optimization
Used to indicate whether theYandex Metrica script is enabledon the website
1 day
All of these cookies are used to collect information for analytical and statistical purposes, such asmeasuring website traffic and user behavior. They are stored in the user's browser for varying durationsas indicated above, and can be manually deleted by the user or cleared when the browser cache iscleared.

● To know more about Yandex Metrica's cookie usage, consult its privacy policy here.

8 Data disclosure

We may disclose your personal data in the good faith belief that such action is necessary:
● To comply with a legal obligation (i.e., if required by law or in response to valid requests bypublic authorities, such as a court or government agency);
● To protect the security of the Website and defend our rights or property;
● To prevent or investigate possible wrongdoing in connection with us;
● To defend ourselves against legal liability.

9 Data security

We take reasonable technical and organisational security measures that we deem appropriate to protectyour stored data against manipulation, loss, or unauthorised third-party access. Our security measuresare continually adapted to technological developments.

We also take internal data privacy very seriously. Our employees and the Service Providers that weretain are required to maintain secrecy and comply with applicable data protection legislation. Inaddition, they are granted access to personal data only insofar as this is necessary for them to carryout their respective tasks or mandate.

The security of your personal data is important to us but remember that no method of transmission overthe Internet or electronic storage is 100% secure. While we strive to use commercially acceptablemeans to protect your personal data, we cannot guarantee its absolute security. We recommend usingantivirus software, a firewall, and other similar software to safeguard your system.

10 Your rights

You have the below data protection rights. To exercise these rights, you may contact the above addressor send an e-mail to: Please note that we may ask you to verify your identity beforeresponding to such requests.

Right of access: You have a right to request a copy of your personal data, which we will provideto you in an electronic form.
Right to amendment: You have the right to ask us to correct our records if you believe theycontain incorrect or incomplete information about you.

Right to withdraw consent: If you have provided your consent to the processing of your personaldata, you have the right to withdraw your consent with effect for the future. This includes caseswhere you wish to opt-out from marketing communications. Once we have received notificationthat you have withdrawn your consent, we will no longer process your information for thepurpose(s) to which you initially consented unless there is another legal basis for processing.To stop receiving emails from us, please click on the 'unsubscribe' link in the email you receivedor contact us at

Right to erasure: You have the right to request that we delete your personal data when it is nolonger necessary for the purposes for which it was collected or when it was unlawfullyprocessed.
Right to restriction of processing: You have the right to request the restriction of ourprocessing of your personal data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial purpose, but where we are notable to delete it due to a legal obligation or because you do not want us to delete it.
Right to portability: You have the right to request that we transmit your personal data toanother data controller in a standard format such as Excel, where this is data which you haveprovided to us and where we are processing it on the legal basis of your consent or to performour contractual obligations.
Right to object to processing: Where the legal basis for our processing of your personaldata is our legitimate interest, you have the right to object to such processing ongrounds relating to your particular situation. We will abide by your request unless wehave a compelling legal basis for the processing which overrides your interests or if weneed to continue to process the personal data for the exercise or defence of a legal claim.
Right to lodge a complaint with a supervisory authority: You have the right of appeal to adata protection supervisory authority if you believe that the processing of your personal dataviolates data protection law. The competent data protection authority in Switzerland is theFederal Data Protection and Information Commissioner (

11 Links to third-party apps and sites

Our website may contain links to websites or apps that are not operated by us. When you click on athird party link, you will be directed to that third party's website or app. We have no control over, andassume no responsibility for, the content, privacy policies, or practices of any third party websites or services.

We maintain online presences on social networks to, among other things, communicate with customersand prospective customers and to provide information about our products and services. If you have anaccount on the same network, it is possible that your information and media made available there maybe seen by us, for example, when we access your profile. In addition, the social network may allow usto contact you. The content communication via the social network and the processing of the contentdata is thereby subject to the responsibility of the social network. As soon as we transfer personal datainto our own system, we are responsible for this independently. This is then done in order to carry outpre-contractual measures and to fulfil a contract. For the legal basis of the data processing carried outby the social networks under their own responsibility, please refer to their data protection declarations.
Below is a list of social networks on which we operate an online presence:

● Facebook:
Privacy Policy
● Instagram:
Privacy Policy
● LinkedIn:
Privacy Policy
● Twitter:
Privacy Policy
● Telegram:
Privacy Policy
● Medium:
Privacy Policy
● Tokeny:
Privacy Policy
● Referral Factory:
Privacy Policy
Privacy Policy
● Webflow:
Privacy Policy

12 Changes to this privacy policy

We may update our Privacy Policy from time to time. We, therefore, encourage you to review thisPrivacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

13 Contact us

If you have any questions about this Privacy Policy, do not hesitate to get in touch with us at:

Contact Details: