Privacy Policy

Privacy policy

Introduction

Thank you for visiting our website and for your interest in our products. Protecting your personal data is very important to us.

Below, you will find information on how we collect your personal data, what we do with it, for what purposes, and on what legal basis. We also explain what rights and claims this gives you.

What does our privacy policy cover, and to whom does it apply?

This privacy policy applies exclusively to the use of our website “etops.com” and all its subpages. It contains detailed information about what we do with your personal data when you visit our website. We attach great importance to ensuring that your visit to our website is secure and that the processing of your data is transparent for you.

We are jointly responsible for this website within the meaning of the EU General Data Protection Regulation (GDPR):

Etops Group AG

Hinterbergstrasse 17

6330 Cham

Switzerland

together with its subsidiaries:

Etops SK, s.r.o. (Tomasikova 64A, 83104 Bratislava, Slovak Republic); Etops GmbH (Bismarckstraße 6, 96515 Sonneberg, Germany); Etops AG (Hinterbergstrasse 17, 6330 Cham, Switzerland).

and:

niiio finance group AG

Konsulplatz 10

02826 Görlitz

Germany

together with its subsidiaries:

niiio wealth management GmbH (Konsulplatz 10, 02826 Görlitz, Germany); PATRONAS Financial Systems GmbH (Schnewlinstraße 12, 79098 Freiburg, Germany); PATRONAS Global Sales GmbH (Schnewlinstraße 12, 79098 Freiburg, Germany); Fundsaccess Service GmbH (Karlsplatz 3, 80335 Munich, Germany); MiFID-Recorder GmbH (Rüdesheimer Str. 11, 80686 Munich, Germany); FundHero S.A. (6, rue Pierre Risch, 5450 Stadtbredimus, Luxembourg); FinTecc LLC (Saint Petersburg St N1, 0102 Tbilisi, Georgia)

The framework for the joint processing of personal data has been agreed upon between these controllers under the legal requirements. Responsibility is based on the purpose of the data collection and is regulated accordingly.

Data Protection Officer

You can contact our data protection officer with suggestions, complaints and requests. You can reach him using the following information.

For Switzerland:

You can reach our data protection officer at privacy@etops.ch. If you wish to contact him by post, please use the following address: Etops Group AG, Attn: Group Data Protection Officer, Hinterbergstrasse 17, 6330 Cham, Switzerland.

For the  EU:

You can reach our data protection officer at DSB@niiio.finance. If you wish to contact him by post, please use the following address: niiio finance group AG, Attn: Group Data Protection Officer, Konsulplatz 10, 02826 Görlitz, Germany.

How do we protect your data?

We use technical and organizational security measures to protect the data we process against manipulation, loss, destruction and access by unauthorized persons. We continuously improve our security measures in line with technological developments and have them regularly reviewed by an external auditor.

In addition, we use SSL or TLS encryption for security reasons and to protect the transmission of confidential content. You can recognize an encrypted connection by changing the browser’s address line from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, third parties cannot read the data you transmit to us.

Legal basis for the processing of your personal data

In principle, you will find the respective legal bases under the purposes of processing; the following overview is intended to provide a quick overview of all applicable legal bases:

1. If you have given us your consent to process your personal data, this constitutes the legal basis for the processing (Article 6(1)(a) GDPR).
2. For processing personal data to initiate or fulfil a contract with you, Article 6(1)(b) GDPR is the legal basis.
3. Insofar as the processing of your personal data is necessary to fulfil our legal obligations (e.g. to store data), we are authorized to do so under Article 6 (1) (c) GDPR.
4. We also process personal data under Article 6 (1) (f) GDPR for the purposes of our legitimate interests and the legitimate interests of third parties.

As part of the necessary balancing of interests, we consider the type of personal data collected from you, the purpose of processing, the circumstances of processing and your interest in the confidentiality of your personal data.

1. Cookies are stored and read based on Section 25 TDDDG (in Germany) and Section 109 ZEK (in Slovakia).

We want to point out that some functions of our website are linked to providing personal data. If you do not wish to provide us with your personal data in these cases, this may mean that the desired function (e.g. a download) is not available or only available to a limited extent.

1. application form:
2. Responsible party: Etops Group AG and niiio finance group AG
3. Which data: The following data is collected from you when you use our application form: First name and surname (mandatory), email address (mandatory), telephone number (mandatory), address (mandatory), city (mandatory), province (mandatory), zip code (mandatory), country (mandatory), all details in your CV (mandatory), earliest possible starting date (optional), desired salary (optional), your website (optional), your blog (optional) or your portfolio (optional), LinkedIn profile URL (optional), language skills (optional), work permit (optional), position you are applying for (mandatory), consent to extended data storage (talent pool) (optional),
4. Purpose of data processing: We collect the data to handle our application process.
5. Legal basis: Art. 6 para. 1 lit. b and f GDPR, as well as Art. 6 para. 1 lit. a GDPR for the talent pool
6. Duration of storage: If we conclude an employment contract with you, the data transmitted will be stored to process the employment relationship. If no employment contract is concluded between you as an applicant and us, your documents will be deleted six months after notification of the rejection decision, provided that no legitimate interests prevent deletion or you as an applicant have consented to more extended storage. In this sense, a legitimate interest could be a burden of proof in (potential) proceedings under the principle of equal treatment and the respective national legal implementation. If you have consented to a more extended storage period, your personal data will be deleted after this period has expired.
7. Third-party providers/recipients/processors: We have chosen the provider Bamboo-HR (Bamboo HR, LLC, 335 South 560 West Lindon, UT 84042, USA) to carry out the publication of job advertisements and the associated applicant management. For more information about how your personal applicant data is handled in the Bamboo-HR software solution, please refer to the Bamboo-HR privacy policy: https://www.bamboohr.com/legal/privacy-policy
8. Third-country transfer: BambooHR, the provider, is based in the USA, which is why the data you submit is also processed in a third country. We and BambooHR have concluded EU-standard contractual clauses to guarantee an adequate level of data protection.

1. Booking an appointment for a demo:
2. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
3. Which data: When you use our appointment booking service, we collect the following data from you: first and last name, email address, job title, company name, day and time of the meeting, and product you are interested in.
4. Purpose of data processing: We use your data to process appointment bookings and store your contact information in our CRM system, Hubspot, for sales activities.
5. Legal basis: Art. 6 para. 1 lit. b and f GDPR
6. Duration of storage: If we conclude a service contract with you, the transmitted data will be stored to process the contract in compliance with the statutory provisions. If no service contract is concluded with you, we will delete your data two years after your last contact.
7. Third-party providers/recipients/processors: We have chosen the provider Hubspot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA) to coordinate the appointments and the associated offer management. Further information and the data protection provisions can be found in HubSpot’s privacy policy at: https://legal.hubspot.com/privacy-policy
8. If your appointment booking results in email communication, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement
9. Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.
10. Contact form:
11. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
12. Which data: The following data is collected from you when you use our contact form: Title, first name and surname, email address, telephone number, company name, message that you send us
13. Purpose of data processing: We use your data to process your inquiry and store your contact in our CRM system Hubspot if you have expressed an interest in our products in your inquiry.
14. Legal basis: Art. 6 para. 1 lit. b and f GDPR
15. Duration of storage: If your request is independent of our products, we will delete your data six months after the final response to your request. If we conclude a service contract with you based on your inquiry, the transmitted data will be stored to process the contract in compliance with the statutory provisions. If no service contract is concluded with you, we will delete your data two years after your last contact.
16. hird-party providers/recipients/processors: If your contact request results in email communication, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement

If you have expressed interest in our products in your contact request, we will store your contact information in our CRM system, HubSpot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA). Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy

1. Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.
2. Subscribe to our newsletter:
3. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
4. Which data: When you subscribe to our newsletter, the following data is collected from you: Title, first name and surname, email address, and newsletter selection.
5. Purpose of data processing: We use your data to send newsletters.
6. Legal basis: Art. 6 para. 1 lit. a GDPR
7. Duration of storage: Your data will be stored for the duration of the newsletter subscription and then deleted, provided that there are no legitimate interests to the contrary. A legitimate interest in this sense exists, for example, if there is a burden of proof in (potential) proceedings under the Unfair Competition Act and the respective national legal implementation.
8. Third-party providers/recipients/processors: We use the provider Hubspot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA) to coordinate our newsletters. Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy
9. Third-country transfer: The provider HubSpot is based in the USA, so the data you submit is also processed in a third country. We and HubSpot have concluded EU-standard contractual clauses to guarantee an adequate level of data protection.
10. Registration for events:
11. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
12. Which data: The following data is collected from you as part of the event registration process: First name and surname, email address, company name, and event for which you have registered.
13. Purpose of data processing: We use your data to plan and organize events and store your contact information in our CRM system, Hubspot, for sales activities.
14. Legal basis: Art. 6 para. 1 lit. a, b and f GDPR
15. Duration of storage: If we conclude a service contract with you, the transmitted data will be stored to process the contract in compliance with the statutory provisions. If no service contract is concluded with you, we will delete your data two years after your last contact.
16. Third-party providers/recipients/processors: We have chosen the provider Hubspot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA) to coordinate the event dates and, if you are interested in a service contract, to manage the associated offer. Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy

If your event booking results in email communication, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement

1. Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.
2. Registration for the waiting list for future products:
3. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
4. Which data: The following data is collected from you as part of the waiting list: First name and surname, email address, company name, product you are interested in
5. Purpose of data processing: We use your data to provide you with specific information about the product for which you have placed yourself on the waiting list and store your contact information in our CRM system, Hubspot, for sales activities.
6. Legal basis: Art. 6 para. 1 lit. a, b and f GDPR
7. Duration of storage: If we conclude a service contract with you, the transmitted data will be stored to process the contract in compliance with the statutory provisions. If no service contract is concluded with you, we will delete your data two years after your last contact.
8. Third-party providers/recipients/processors: We have chosen the provider Hubspot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA) to coordinate the product information and, if you are interested in a service contract, the associated offer management. Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy

Insofar as email communication is established based on your interest, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement

1. Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.
2. Download of documents:
3. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
4. Which data: The following data is collected from you as part of the document download: First and last name, email address, company name, and downloads you have made.
5. Purpose of data processing: We use your data to provide you with downloads and specific information about the product. We also store your contact information in our CRM system, Hubspot, for sales activities.
6. Legal basis: Art. 6 para. 1 lit. a, b and f GDPR
7. Duration of storage: If we conclude a service contract with you, the transmitted data will be stored to process the contract in compliance with the statutory provisions. If no service contract is concluded with you, we will delete your data two years after your last contact.
8. Third-party providers/recipients/processors: We have chosen the provider Hubspot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA) to coordinate the product information and, if you are interested in a service contract, the associated offer management. Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy

Insofar as email communication is established based on your interest, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement

1. Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.
2. Assertion of data subject rights:
3. Responsible party: Etops Group AG, Etops AG, Etops GmbH, Etops SK, s.r.o., niiio finance group AG, niiio wealth management GmbH, PATRONAS Financial Systems GmbH, PATRONAS Global Sales GmbH, Fundsaccess Service GmbH, MiFID-Recorder GmbH, FundHero S.A., FinTecc LLC
4. Which data: We collect the following data from you as part of the assertion of data subject rights: your first and last name, place of residence, email address, type of request, relationship to the company, and message you send us.
5. Purpose of data processing: We use your data to process your data subject request.
6. Legal basis: Art. 6 para. 1 lit. c and f GDPR
7. Duration of storage: Your data will be stored for the duration of the communication in the context of the data subject request and deleted upon completion of the request. This does not apply to proof that we have correctly processed your request, which will be deleted upon expiry of the limitation period (3 years starting at the end of the calendar year in which we finally processed your request) for the assertion of claims for damages.
8. Third-party providers/recipients/processors: We have chosen the provider Hubspot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA) to coordinate the requests of data subjects. Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy
9. If email communication is established based on your data subject request, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement
10. Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.

Third-party providers

We also use third-party providers on our website. Below are all the third-party providers used. You can view this information at any time in our cookie manager (accessible in the bottom left corner).

Cookie Consent Manager CCM19
Purpose: Our website uses the cookie consent technology of CCM19 to obtain your consent to the storage of certain cookies in your browser and to document them in a data protection-compliant manner.
Provider of this technology is Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn.
What data is collected by the provider: none
Legal basis: Art. 6 para. 1 sentence 1 lit. c GDPR, § 25 TDDDG and Art. 17 sentence 1 b.2 DSB (Switzerland).
Link to the privacy policy of the provider: https://www.ccm19.de/en/privacyclarification.html

HubSpot
Purpose: Marketing and sales activities (CRM tool).
Provider of this technology is HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA.
What data is collected by the provider? The data is entered via the forms. More detailed information can be found in the section Legal basis for processing your personal data.
Legal basis: Art. 6 para. 1 sentence 1 lit. a, b, f GDPR
Link to privacy policy of the provider: https://legal.hubspot.com/privacy-policy

Bamboo-HR
Purpose: Applicant tracking
Provider of this technology is Bamboo HR, LLC, 335 South 560 West Lindon, UT 84042, USA.
What data is collected by the provider: When you use our application form, the following data is collected from you: First name and last name (required), email address (required), phone number (required), address (required), city (required), province (required), zip code (required), country (required), all information in your CV (required), earliest possible entry date (optional), Desired salary (optional), your website (optional), your blog (optional) or your portfolio (optional), LinkedIn profile URL (optional), language skills (optional), work permit (optional), position you are applying for (mandatory), consent to extended data storage (talent pool) (optional)
Legal basis: Art. 6 para. 1 sentence 1 lit. a, b, f GDPR
Link to the privacy policy of the provider: https://www.bamboohr.com/legal/privacy-policy

Google Ads
Purpose: For marketing purposes, it enables us to draw attention to our products with the help of advertising material on external websites and to determine how successful individual advertising measures are.
Provider of this technology is Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.
What data is collected by the provider: This varies depending on your personal Google account settings.
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the privacy policy of the provider: https://policies.google.com/technologies/ads?hl=en

Google Analytics
Purpose: For marketing and analytical purposes, to provide us with insights and statistics on how visitors interact with our website to improve the user experience.
Provider of this technology is Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.
What data is collected by the provider: the browser you use, your operating system, the date and time of your visit, the access status (e.g. whether you received an error message), the use of website functions, the search terms you entered, the frequency with which you access individual sub-pages of our website, the names of files retrieved and how often, the data volumes transferred, the loading times of the sub-pages accessed, the website from which you accessed our website, the website you visited from our website (e.g. by clicking on links), your IP address, the name of your internet service provider, the clicks you have made on our website and their frequency, your movement behavior on our website (behavioral flow analysis and user path), the areas of our website you have selected and clicked on, JavaScript error messages during your visit, whether and how often you clicked on non-functional areas of our website (so-called dead clicks), whether you repeatedly clicked on certain elements and which ones (so-called rage clicks), video retrieval and time of video viewing, a recording of your session on our website (session replay), provided you have authorized this in your own Google account: age, gender, country, location, type of device used, network and your interests, as part of campaign actions: campaign URL, campaign source, campaign medium
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

Google Tag Manager
Purpose: For marketing and analysis purposes.
Provider of this technology is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
What data is collected by the provider: none
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://policies.google.com/technologies/ads?hl=en

Microsoft Clarity
Purpose: For analysis purposes, to better understand what happens on our website from the viewer’s perspective and to use this information to optimize the website in order to provide you with a better user experience.
Provider of this technology is Microsoft Schweiz GmbH The Circle, P.O. Box, 8058 Zurich Airport, Switzerland and Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
What data is collected by the provider: none
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://privacy.microsoft.com/privacystatement

Your rights as a data subject:

– Information (Article 15 GDPR)

You have the right to request confirmation from us as to whether we are processing your personal data. If such processing has taken place, you have the right to request information about the personal data concerning you that we have processed, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the origin of your data if we did not collect it from you, the existence of automated decision-making including profiling and, where applicable, meaningful information about the logic involved and the significance and the envisaged consequences of such processing for you, as well as your right, to be informed of the safeguards under Article 46 GDPR for the transfer of your data to third countries.

– Rectification (Article 16 GDPR)

You have the right to request the immediate correction of incorrect personal data concerning you and/or the completion of your incomplete data at any time. Please provide us with the relevant data using the contact form.

– Data deletion (Article 17 GDPR)

You have the right to request the deletion of your personal data if one of the following reasons applies to you:

1. the personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
2. you withdraw your consent on which the processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2) GDPR and where there is no other legal ground for the processing.
3. You object to the processing under Article 21(1) of the GDPR, and there are no overriding legitimate reasons for the processing. You object to the processing in accordance with Article 21(2) of the GDPR.
4. your personal data has been unlawfully processed.
5. Deleting your personal data is necessary to fulfil a legal obligation under Union or national law to which the controller is subject.
6. your personal data has been collected in relation to information society services offered under Article 8 (1) GDPR.

Suppose we have made your personal data public and are obliged to delete it under Article 17 (1) of the GDPR. In that case, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform those responsible for the processing that you, as the data subject, have requested the deletion of all links to the personal data or of copies or replications of this personal data.

The right to erasure does not apply if processing is necessary for us. If this is the case, we will provide you with comprehensive information.

– Restriction of processing (Article 18 GDPR)

You have the right to request the restriction of the processing of your personal data under the following conditions:

1. If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. During the review, you have the right to demand that the processing of your personal data be restricted.
2. If the processing was or is unlawful, you may request its use restriction instead of deletion.
3. If we no longer need your personal data, but you need it to assert, exercise or defend legal claims, you can demand the restriction of its use instead of deletion or
4. If you have objected to processing under Article 21(1) of the GDPR, a balance must be struck between your interests and ours. If it is not yet clear whose interests prevail, you have the right to demand that the processing of your personal data be restricted.

If you have restricted the processing of your personal data, these data – apart from being stored – may be processed only with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or on the grounds of a significant public interest of the EU or a Member State.

If the processing restriction has been set in accordance with the above conditions, we will inform you before the restriction is lifted.

– Data portability (Article 20 GDPR)

Suppose the processing is based on your consent under Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract under Article 6(1)(b) GDPR and is carried out by automated means. In that case, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller or to request the transmission to another controller as far as technically feasible.

– Revocation of consent

If you have given us consent, you have the right to revoke it at any time in the future. This means that the revocation does not affect the legality of the previous processing of your personal data. We are no longer allowed to process your data based on consent from the time of the revocation. Likewise, your revocation does not affect further processing of this data on another legal basis, such as fulfilling legal obligations.

You can end the revocation of your newsletter subscription at any time by using the unsubscribe option provided in the newsletter. You do not need to assert your rights under point d below.

– Objection (Article 21 GDPR)

Insofar as we base the processing of your personal data on the weighing of interests under Article 6 (1) (f) GDPR, you have the right at any time, for reasons that arise from your particular situation, to object to the processing of your personal data; this also applies to profiling based on this provision. If you file an objection, we will no longer process your personal data unless we can prove compelling reasons for the processing worthy of protection that outweighs your interests, rights and freedoms or the processing serves the assertion, exercise or defence of legal claims. Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object, your personal data will no longer be processed for direct marketing purposes.

1. We ask that you please assert your rights as a data subject in the following contact form if possible:

Your right to complain to the supervisory authority

If you believe that processing your personal data violates legal requirements, you have the right to lodge a complaint with a data protection supervisory authority (Article 77 GDPR). As the data subject, it is your responsibility to choose which supervisory authority to contact.

The supervisory authority responsible for us in Switzerland is:

Federal Data Protection and Information Commissioner (FDPIC)

Feldeggweg 1, 3003 Bern – Switzerland

Phone: +41 584624395

The supervisory authority responsible for us in the EU is:

Saxon Data Protection and Transparency Officer

P.O. Box 11 01 32, 01330 Dresden, Germany

Phone: +49 351 85471-101, Email: post@sdtb.sachsen.de

In addition, you can find all regulatory authorities for the EU at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en and for Germany at https://www.datenschutz-bayern.de/zustaendigkeiten/

Data transfer to recipients outside the European Economic Area

When using service providers and passing on data to third parties with your consent, personal data may be transferred to recipients in countries outside the European Union (“EU”), Iceland, Liechtenstein and Norway (= European Economic Area) and processed there. You can find detailed information on this in the section on the respective purposes for data processing in the section “Which data, for which purpose, with which legal basis, for which duration, to which third country are transferred and, if applicable, with the involvement of which third-party provider are processed by us?”

From the EU’s point of view, countries with adequate protection for processing personal data in line with EU standards can be approved with a so-called adequacy decision. The current list can be found at:

https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

We agree to apply the EU standard contractual clauses (Implementing decision – 2021/914 – EN – EUR-Lex) with recipients in countries without an adequacy decision to create an “adequate level of protection” in accordance with the legal requirements. We will be happy to provide you with information on this. Please use the contact form.

Validity and amendment of this data protection declaration

This privacy policy is valid from 17.03.2025. We reserve the right to change this privacy policy at any time in compliance with the applicable data protection regulations. This may be necessary, for example, to comply with new legislation or to consider changes to our website or new services on our website. The version available at the time of your visit applies.

If this data protection declaration changes, the current version will be available on our website. Please use the contact form if you have any questions about the changes.

Questions about the processing of your personal data?

If you have any further questions or concerns, please feel free to contact us using this contact form. You are also welcome to contact our data protection officers at privacy@etops.ch or DSB@niiio.finance.