PRIVACY POLICY of
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 https://www.cofund.ai/ (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.
Directly
● 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.
Indirectly
● 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
Company.
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
● EU/EEA
● USA
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:
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 https://www.cofund.ai/ (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.
Directly
● 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.
Indirectly
● 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
Company.
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
● EU/EEA
● USA
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: