Your privacy is important to us. As the data controller, Close SA is committed to processing the personal data you provide to us in a transparent manner and in accordance with applicable law.
Close SA, hereinafter referred to as CSA, we, us or our, is a joint stock company registered in the Geneva Commercial Register with its registered office at route de Saint-Julien 198, 1228 Plan-les-Ouates, Switzerland.
This privacy policy (the Policy) is dated September 1st, 2024. It may be amended at regular intervals (see section 12).
By accessing the website www.closeventures.ch (the Site), which we operate, you expressly consent to our processing of your data in accordance with the Policy.
Should you have any questions about the Policy or the use of your data, please contact us at [email protected] or by telephone on +41 (0)58 255 83 00.
We also invite you to consult our terms of use and our cookies policy.
1. What is personal data?
By personal data, we mean any data that relates to an individual (the Data). Such Data can either identify you directly (e.g. your first and last name, your email address or your social security number) or indirectly by cross-referencing various information about you (e.g. your computer’s IP address, your telephone number or your credit card number).
2. What kind of Data do you communicate to CSA?
The Data that CSA collects automatically when you access the Site or the Data you provide on a voluntary basis when you communicate with us by using the “contact us” link or subsequently (the fields preceded by an asterisk are necessary and the additional fields may be communicated according to the user’s wishes, on an optional basis):
- *your name;
- *your first name;
- *if applicable, the name of the company you represent;
- *whether you act as an investor or a company;
- *your email address;
- your phone number;
- any personal information that you spontaneously communicate to us during email exchanges;
- all other Data collected by the cookies and the web server.
More information about automatically collected Data can be found in our cookies policy.
3. Why does CSA collect this Data?
We only process your Data if we have a legitimate reason to do so, among those clearly identified below, or on the basis of your consent:
- your first and last name and, if applicable, the name of the company you represent, as well as whether you are an investor or a company, to identify you and help us offer you the most appropriate services. This Data is also necessary for the conclusion of a contract;
- your email address and telephone number so that we can contact you. This Data is necessary for business purposes. When it is used to send you our newsletter or any other advertising communication, this use is based on your consent;
- Data transmitted by the Site’s cookies for internal analysis and statistical purposes. This Data is processed on the basis of our legitimate interest in improving our services and for advertising purposes, and with your consent where required by applicable law;
- all Data submitted may be processed in order to comply with our legal obligations and other legal requirements;
- browser and/or device data as well as login and navigation data on the website are collected for the following purposes: (i) to enable you to navigate our site easily, (ii) to inform you in a targeted manner via paid advertising (social networks, Google Ads, etc.) about our news and products, and (iii) to measure and analyze the traffic on the Site.
In all cases where the above-mentioned reasons may not be considered a legitimate reason, you consent to the processing of Data for the purposes described above by approving this Policy.
Further non-personally identifiable data, including on an aggregated or anonymized basis, may be used to administer services, improve customer relations, diagnose and manage technical problems, and obtain demographic information in aggregate form.
4. With whom can CSA share your Data?
CSA may share your Data in the following ways:
- to any third party to whom we are obliged to communicate this Data following an injunction issued by a judicial or governmental authority or in accordance with our legal obligations;
- to any third party whose involvement is necessary to allow the proper execution of the services (for example, our employees and affiliates, our host and our IT staff);
- In the context of any merger, acquisition or restructuring in any form whatsoever, as well as in the event of any bankruptcy proceedings, your Data may be transferred to third parties as an asset of CSA. In this case, we will make every effort to inform you of such transfers before they take place, but we cannot guarantee that you will have the opportunity to object to such a transfer.
By accessing the Site and submitting Data to us, you expressly agree to such transfers.
5. Where is your Data hosted?
The Data collected by CSA is hosted and processed by Google Workspace.
6. How does CSA process your Data?
We may or may not process your Data in an automated way, and in any case we take appropriate security measures.
We process your Data in accordance with applicable law, in particular Swiss and European data protection law, and adopt appropriate security measures to prevent unauthorized access, disclosure, modification, alteration or destruction of your Data.
We may process your Data to remove any personally identifiable information (anonymization) and then use the anonymized Data for purposes not contemplated by the Policy (including for benchmarking, directing campaigns or developing and marketing new services).
7. How does CSA protect your Data?
CSA makes every effort to ensure the security of your Data and thus prevent any undue access, use, modification or disclosure of the latter.
CSA also makes every effort to ensure that any third party to whom your Data is communicated (as described above) processes it in a secure manner to ensure its confidentiality and integrity.
As the case may be, in order to protect the confidentiality of your Data, it is your responsibility to keep your identifiers in a safe place known only to you and not to disclose them to anyone. You are responsible for any use that may be made of the services offered on the Site based on an authentication with your identifiers. We ask you to kindly inform us immediately by email of any suspected or proven abuse of your identifiers. Remember, however, that no security measure whatsoever is absolute.
8. How long does CSA keep your Data?
CSA only keeps your Data for as long as is necessary to achieve the purpose for which such Data was collected, i.e. in principle for 3 years after your last contact with CSA.
Pursuant to our legal obligations, certain information relating in particular to the contractual relationship between you and us must be kept for at least 10 years.
In any case, you are free to ask CSA to keep your Data longer, in the perspective of a possible new agreement, or to the extent necessary to continue receiving our newsletter.
Instead of destroying or deleting your Data, CSA may decide to make it permanently anonymous so as to make it impossible to identify you.
9. What are your rights in relation to your Data?
You have the right to know what Data we process about you and to request that it be deleted, corrected or updated.
Unless otherwise provided by applicable law, you have the right to know at any time whether we are processing Data concerning you and exercise your right of access in accordance with art. 25 of the Swiss Data Protection Act (DPA). You may contact us to find out what such Data contains, verify its accuracy, and to the extent permitted by applicable law, in particular art. 32 DPA, request that it be completed, updated, corrected or deleted. You also have the right to request that we cease any specific processing of Data that has been obtained or processed in breach of applicable law, and to object to any processing of Data where there are legitimate grounds.
If you would like us to remove your Data from our systems, you can send us a request using the contact details below, which we will comply with unless we need to retain your Data for a legal reason or for any other legitimate reason.
Where we rely on your consent to process your Data, we will seek your independent and specific consent by providing you with as much detail as possible. You may revoke your consent at any time.
You also have the right to request the portability of your Data processed automatically on the basis of your consent or contractual necessity, i.e. that the Data you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format, without hindrance from us, subject to our confidentiality obligations and within the limits of applicable law, in accordance with art. 28 and 29 DPA.
If you are a resident of the EEA, you have the following rights:
- the right to access your Data (art. 15 RGPD),
- the right to be forgotten (art. 17 RGPD),
- the right to rectification (art. 16 RGPD),
- the right to lodge a complaint with a supervisory authority in your place of usual residence or work, or in the place where the breach is alleged to have occurred (art. 77 GDPR),
- the right to limit processing on request (art. 18 RGPD),
- the right to object to the processing of your Data and to withdraw your consent (art. 21 GDPR), as well as
- the right not to be subjected to an automated individual decision (a process which CSA does not use).
For more information on the scope of your rights or to exercise them, we invite you to contact us at: [email protected].
You are under no legal or contractual obligation to provide us with any Data. However, refusing to provide certain Data or exercising the rights set out in this section 9of the Policy may preclude us from providing you with our services, including access to the Site.
10. What about links to other sites?
We have not reviewed any of the websites linked to the Site and are not responsible for the content of any such other websites. You access all other websites than the Site at your own risk.
11. Cookies
Please refer to our cookies policy on the following link: https://closeventures.ch/cookies-policy/.
12. Update of legal information
We reserve the right to make changes and corrections to these provisions. Please check this page regularly for changes and new information.
