Ci Fund Solutions – Data Protection

Our offer is primarily aimed at users in Switzerland. We are based in Switzerland and comply with the Swiss Data Protection Act (DSG) in its currently valid version. With this privacy policy, we submit to the DSG regulations applicable from September 1, 2023. The full text of the law can be found here: fedlex.admin.ch/eli/cc/2022/491/en. We assume that we do not currently comply with the EU General Data Protection Regulation (“GDPR”), as we do not create profiles about EU citizens or offer our service to individuals within the meaning of Art. 3 (2) lit. a) GDPR.

4.1 Purpose of processing

We process personal data for various processing purposes, depending on whether you are in contact with us as a client, supplier, interested party, employee, service provider, specialist or applicant, or working with us.

Users' personal data is usually collected directly by SBA when using the website or using our service and client relationship. However, personal data can also be collected indirectly, such as in the case of correspondence with third parties (e.g. counterparties, authorities, courts, etc.) or by further obtaining additional information from publicly available third-party data sources (e.g. social media, creditworthiness checks, etc.).

In particular, SBA processes personal data for the following purposes:

- initiation, conclusion and fulfilment of contractual obligations, in particular in the context of providing legal services, but also to other contractual partners (e.g. suppliers, service providers);
- contacting and communicating with clients and third parties, as well as processing inquiries (e.g. for applications and media inquiries); review and implementation of application processes;
- use of services provided by assistants (in particular consulted law firms and experts in Germany and abroad);
- compliance with legal and regulatory obligations, in particular obligations to comply with regulatory obligations applicable to lawyers;
- provision of the website offering, including using cookies from other technologies to ensure the functionality of the website and improve our website offering;
- ensuring our operations, in particular IT, our websites and other platforms, as well as measures for IT, building and plant security and protecting our employees and other people and values entrusted to us;
- advertising and marketing, preparation, implementation and follow-up of events and events;
- prevention and investigation of crimes and other misconduct;
- enforcement and defense of claims, defense of legal claims, legal disputes, lawsuits, combating abusive conduct;
- sound corporate governance and development;
- company activities in accordance with the articles of association, activities that lie within the scope of fulfilling our corporate purpose;
- other purposes such as training and education purposes, administrative purposes;

4.2 Categories of recipients

We indicate the category of recipients to whom personal data may be disclosed depending on the respective activity. These are:

- Web hosting providers, webmasters, IT service providers (if used), social media services (if used), as well as content management system providers
- Other third parties who provide services and services
- Public and judicial authorities, auditors, regulators, law enforcement agencies, or government agencies (as required or required by laws, regulations, as part of a code of conduct, or by these authorities or bodies)
- Counterparties, as well as their legal representatives and other persons involved (guarantors, financiers, respondents, experts, etc.) in actual or potential proceedings
- Trustees, service providers to fulfill legal or tax obligations
- insurance companies and banks
- acquirers or interested parties to acquire divisions, companies or other parts of SBA.

4.3 Data transmission and transfer

In particular, in all countries in which SBA is represented by group companies, subsidiaries or other branches and representatives, as well as in countries in which SBA service providers process their data, data processing may take place by or as a result of SBA's activity. If data is transferred to countries that do not guarantee adequate protection, SBA ensures adequate protection of the disclosed data.
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The following applies to the disclosure of personal data abroad:
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EU countries: adequate level of data protection.

USA: The USA does not currently guarantee an adequate level of data protection. The European Commission has decided that the USA ensures an adequate level of protection for personal data (hereinafter “adequacy decision”). However, the Swiss Federal Council has not yet passed such a resolution, so that there is currently no adequacy decision within the meaning of the DSG (as of 08/2023). To ensure appropriate data protection, we generally base data transmission on guarantees (standard data protection clauses in accordance with Art. 16 para. 2 lit. d DSG) or exceptions (express consent of the data subject in accordance with Art. 17 para. 1 lit. a DSG or the disclosure is directly related to the conclusion or execution of a contract between the person responsible and the data subjects in accordance with Art. 17 para. 1 lit. b point 1 DSG). We reserve the right to make the transfer on the basis of an exception in accordance with Art. 17 para. 1 lit. b point 2 DSG or Art. 17 para. 1 lit. d-f DSG.

5.1 Cookies

SBA uses tracking technologies (“cookies”) on the website to learn more about how a user interacts with the website and to ensure the functionality of the website, to analyze user behavior and to make our website user-friendly for you. Cookies are small text files that are stored either only for the duration of the visit to the website (so-called “session cookies”) or longer and only deleted after a limited period of time, e.g. to recognize returning users.

On the one hand, SBA uses session cookies, which are automatically deleted when the website is closed and which enable the server to establish a stable connection with the user (so that, for example, the content of a shopping cart is not lost) as long as he is browsing the website. On the other hand, permanent cookies are used, which are only deleted after a specified period of time per website. Persistent cookies are used to remember user preferences on the website and remain on the user's desktop or internet-enabled device even after the browser is closed or the device is restarted. SBA uses these cookies to analyze user behavior and determine visit patterns so that website functionality can be improved for all users.

Cookies do not cause any damage and do not contain viruses. If the user still does not want cookies to be set, the browser can be set so that cookies are only created with the user's consent or are generally rejected. However, it should be noted that if the user rejects cookies on the website, some functions on the website may be limited or unavailable. SBA is authorized to install coding in newsletters and other marketing emails that can be used to determine whether the recipient has opened an email or downloaded images contained in the email. The recipient can block this application in their email program. In any case, the recipient of the newsletter agrees to the use of this technology.

For help managing cookies in popular browsers, click here:

Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-loeschen-daten-von-websites-entfernen
Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
Google Chrome: https://support.google.com/accounts/answer/61416?hl=de
Opera: http://www.opera.com/de/help
Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=de_DE

5.2 Web analysis service

The website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on the user's device and which enable an analysis of the use of the website. The information generated by cookies about the use of the website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, the IP address of users will be abbreviated beforehand by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there. On behalf of the operators of the website, Google will use this information to evaluate the use of users of the website, to compile reports on website activity and to provide other services related to website activity and Internet usage to the website operator. The IP address transmitted by the user's browser as part of Google Analytics is not combined with other data from Google. Users can prevent cookies from being stored by setting their browser software accordingly; it is pointed out that in this case they may not be able to use all functions of this website to their full extent. Users can also prevent Google from collecting the data generated by the cookie (including IP address) and from processing this data by Google by clicking on the following link (https://tools.google.com/dlpage/gaoptout?hl=de) available browser plug-in is downloaded and installed.

With Google Tag Manager, an offer from Google, the marketer can manage website tags via an interface. The Tag Manager tool itself (which implements the tags) is a cookie-free domain and does not collect any personal data. However, other tags are triggered, which in turn may collect data. Google Tag Manager has no access to this data.

More information on terms of use and data protection can be found at https://marketingplatform.google.com/about/analytics/terms/de/

‍5.3 Other services

Webflow

We host our website with Webflow. The provider is Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter: Webflow). When you visit our website, Webflow collects various log files, including your IP addresses.

Webflow is a tool for building and hosting websites. Webflow stores cookies or other recognition technologies that are necessary to display the page, to provide certain website functions and to ensure security (necessary cookies).

For details, see Webflow's privacy policy: https://webflow.com/legal/eu-privacy-policy

Webflow is used on the basis of Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in presenting our website as reliably as possible. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be withdrawn at any time.

Data transmission to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://webflow.com/legal/eu-privacy-policy