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This website of Stableton Financial AG and its affiliates contains two sections: (i) a generally available part that is accessible without client classification and certain documentation made available thereupon (collectively referred to as “Website”) and (ii) a section with additional information and documentation (“Marketplace”) available only to registered persons that are resident in Switzerland and qualify at least as qualified or professional investors as hereinafter described in detail.

1. Website

The Website must not be accessed by any user if and to the extent the access is illegal or for any illegal purpose under the jurisdiction the user/visitor is subject to. In particular, the information is not intended for and must not be accessed by users not domiciled in Switzerland. Persons who access the information made available on the Website by Stableton Financial AG and its affiliates agree to the following: While the material on the Website is often about investments, none of it is offered as investment advice. For members of the public, this means that neither the receipt nor the distribution of information through this Website constitutes the formation of an investment advisory relationship, or any similar client relationship. The materials on this Website are for informational and illustration purposes only and may not be relied on by any person for any purpose and are not, and should not be construed as an investment, financial, legal, tax or other advice, a recommendation nor a research opinion. The information contained herein does neither constitute distribution, nor an offer to sell nor the solicitation of an offer or a recommendation to buy any securities or investment products in any jurisdiction in which such distribution, offer or recommendation is not authorized. This Website may contain forward-looking statements on current expectations and projections about future events. Statements that are predicative in nature, that depend upon or refer to future events or conditions or that include words such as “expects,” “anticipates,” “intends,” “plans,” “believes,” “estimates,” “thinks,” “seeks,” “targets,” “forecasts,” “could” or the negative of such terms or other variations on such terms or comparable terminology. Similarly, statements that describe Stableton’s objectives, plans or goals are forward-looking. Any forward-looking statements are based on Stableton’s current intent, belief, expectations, estimates and projections. These statements are no guarantees of future performance and involve risks, uncertainties, assumptions and other factors that are difficult to predict and that could cause actual results to differ materially. These factors include, among other things, (1) general economic and business conditions; (2) new governmental regulations and changes in, or the failure to comply with existing governmental regulation, (3) legislative proposals that impact our industry or the way we do business, (4) competition, and (5) our ability to attract and retain qualified personnel. Accordingly, there can be no reliance on forward-looking statements as a prediction of actual results and actual results may differ materially from what is expressed or implied by the forward-looking statements. Certain information on the Website is based on information obtained from third-party sources considered to be reliable, however no representation or warranty is given in respect of the correctness of the information contained herein as at the current or any future date. Any projections or analyses provided to assist the recipient of the given information in evaluating the matters described herein may be based on Stableton’s subjective judgments and assumptions and may use various methodologies that produce different results. Accordingly, any projections or analyses should not be taken as confirmed facts and should not be relied upon as an accurate prediction of future results. In addition, this Website may contain performance and other data. Past performance is not indicative of future performance. This Website may contain hyperlinks to websites operated by other parties than Stableton. Activating certain links (if any) on this Website may cause you to leave this Website. These links do not constitute any endorsement, sponsorship or approval of the materials appearing in such websites nor Stableton does control the content or accuracy of these information. Stableton does not accept any liability for the contents, the offered products or services or any other offers of websites linked, or for any loss or damage of any kind arising, whether direct or indirect, caused by the use of any part of the information provided. All information and content on this Website are furnished “AS IS,” without warranty of any kind, express or implied. Stableton will not assume any liability for any loss or damage of any kind arising, whether direct or indirect, caused by the use of any part of the information provided. Stableton and its licensors do not warrant that the content is accurate, reliable or correct; that the Website will be available at any particular time or location; that any defects or errors will be corrected; that unauthorized access to or misappropriation of the content will not occur; or that the content is free of viruses or other harmful components. Your use of the website is solely at your risk. The entire Website is subject to copyright with all rights reserved. No permission is granted to copy, distribute, modify, post or frame any text, graphics, video, audio, software code, or user interface design or logos. The information contained on the website shall not be published, rewritten for broadcast or publication or redistributed in any medium without prior written permission from Stableton.


As a customer-focused company, Stableton puts user satisfaction first. Accordingly, if at any time Stableton does not meet user’s expectations, please let Stableton know immediately to find a way to solve the issue. However, if an amicable solution with Stableton is not reached, users can contact the Swiss Financial Ombudsman Service, FINOS. This is the ombudsman office responsible for complaints against Stableton in Switzerland, which is a neutral information and mediation office, according to FinSA. Address: Finanzombudsstelle Schweiz (FINOS) Talstrasse 20 (1st floor) CH-8001 Zürich Phone: +41 (0)44 552 08 00

  1. By checking the box “Accept Terms and Conditions”

    • if you are the first Authorised User at the Investor, You agree to bind the Investor to these terms and conditions of use pertaining to the Investor’s use of the Website and You warrant that You have the authority to bind the Investor to these terms and conditions

    • if you are the second or subsequent Authorised User at the Investor, You reconfirm that the Investor will comply with these terms and conditions and You warrant that You have the authority to make this confirmation on behalf of the Investor.

  2. The Investor shall not:

    • except as may be allowed by any applicable law which is incapable of exclusion by agreement between the parties and except to the extent expressly permitted under these terms and conditions:

      • attempt to copy, modify, duplicate, create derivative works from, frame, mirror, republish, download, display, transmit, or distribute all or any portion of the Website (as applicable) in any form or media or by any means; or

      • attempt to reverse compile, disassemble, reverse engineer or otherwise reduce to human-perceivable form all or any part of the Website; or

    • access all or any part of the Website in order to build a product or service which competes with the Website; or

    • use the Website to provide services to third parties (other than in the ordinary course of its business); or

    • subject to clause 11.5, license, sell, rent, lease, transfer, assign, distribute, display, disclose, or otherwise commercially exploit, or otherwise make the Website available to any third party except the Authorised Users; or

    • attempt to obtain, or assist third parties in obtaining, access to the Website, other than as provided under this clause 2.

  3. The Investor shall use all reasonable endeavors to prevent any unauthorized access to, or use of, the Website and, in the event of any such unauthorized access or use, promptly notify Stableton.

  4. The rights provided under this clause 2 are granted to the Investor only, and shall not be considered granted to any subsidiary or holding company of the Investor unless expressly agreed in writing by Stableton

  5. Any breach by the Investor of this clause 2 shall be deemed to be a material breach of this agreement.

What data do we collect, for what purposes, and on what legal basis?

Icons made by Geotatah from Privacy Policy The protection of your personal data is very important to Stableton Financial AG, Poststrasse 24, 6300 Zug (“Stableton”, “we”, “us”). Therefore, we process your data exclusively on the basis of the legal provisions, in particular on the basis of the General Data Protection Regulation (GDPR), and Swiss regulations. In this privacy statement, we will inform you about the key aspects of data processing through our website (“website”) and the use of our related services. 1. What data do we collect from you, for what purposes and on what legal basis? Contacting us If you contact us by means of a form on the website or by email, the personal data provided by you (name, email address, company and message content) will be collected and processed. These data are processed, stored and used exclusively for the purpose of answering your request or for establishing contact with you and the associated technical processing or administration. This data processing is therefore necessary to fulfill our (pre-) contractual interests. Sign up for our newsletter – use of your data for direct mail You have the opportunity to subscribe to our newsletter via our website. When you sign up for our email newsletter, we will periodically send you updates and marketing information, such as case studies, tips and user insights related to Conversion Rate Optimization and user research. On the basis of your consent, we therefore process your personal data voluntarily provided during the newsletter registration (your email address, if applicable your name). The data collected by us when registering for the newsletter will be used exclusively for promotional purposes by way of the newsletter for the above mentioned purposes. To register for our newsletter, we use a so-called double opt-in procedure. This means that we will only send you an email newsletter if you have explicitly confirmed to us that you agree to the sending of the newsletter. We will then send you a confirmation email asking you to confirm by clicking on a link that you wish to receive newsletters in the future. The newsletters contain a so-called “web beacon”, a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. In the context of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval is collected. This information is used to improve the technical performance of services based on the technical data or the reading behavior of the newsletter audience based on their locations (which can be determined using the IP address) or access times. You may change your mind at any time and revoke your consent to receive the newsletter with effect for the future. For example, you may unsubscribe from the newsletter by clicking on the unsubscribe link found in the footer of any email you receive from us, or by contacting us at After the cancellation, we will immediately delete your data in connection with the newsletter dispatch. We use MailChimp, a marketing automation platform from The Rocket Science Group LLC as our service provider (processor) to manage our newsletter, including the subscription process to it. Furthermore, we have concluded an appropriate contract data processing contract with MailChimp (Customer EU Data Processing Addendum). There are cases where newsletter recipients are directed to the MailChimp website. For example, the newsletters contain a link that allows recipients to retrieve newsletters online. Furthermore, newsletter subscribers can update their data, e.g. correct their email address at a later point. The Privacy Policy of MailChimp is only available on their page. In this context, we point out that on the websites of MailChimp cookies are used and thus possibly personal data processed by MailChimp, their partners and service providers used (for example, Google Analytics). We have no influence on this data collection. The email addresses of our newsletter recipients, as well as other data of newsletter recipients described in the context of this Privacy Policy, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and analyze the newsletters on our behalf. Furthermore, MailChimp may, according to its own information, use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletters or for economic purposes, in order to determine which countries the recipients come from. However, MailChimp does not use the data of our newsletter recipients to send them newsletters in their name or to pass them on to third parties. For more information on how Mailchimp handles user data, please see the Privacy Policy of MailChimp: Comments function on our blog In addition to your comment, information on the time of writing your comment and the name you have provided for commenting will be saved and published on the website as part of the comments function on the blog of this website. Furthermore, your email address will be logged and saved. The email address will not be published on the website. We need your email address in order to contact you if a third party objects to your published content as unlawful. The processing of personal data is thus based on our legitimate interests in the provision of a (secure) commentary on our blog. We reserve the right to delete comments if they are objected to by third parties as unlawful. Server log files When you use our website, we only collect such data that your browser reports to our server (so-called “server log files”). When you visit our website, we collect the following server log files, which are technically necessary for us to display the website: our visited website, date and time at the time of access, amount of data sent in bytes, source / reference, from which you came to the page, browser used, operating system used, IP address used (possibly in anonymous form). This processing of server log files is based on our legitimate interest in providing the website, improving the stability and functionality of our website. Usage data We also collect information about your use of our website. These usage data are collected via cookies (see in detail in section 2). We use this usage data for (i) web analytics, (ii) improvements to our services and our website, (iii) usability enhancements. This data processing is based on your consent to the use of cookies on our website. You can revoke this consent at any time (for example, via your browser settings for cookies) with effect for the future and free of charge. Feedback and Surveys If you leave us feedback on our services or participate in surveys on our website, we will process the personal information that you provide voluntarily (the email address and the content of your feedback or answers as part of the survey). These data are processed solely for the purpose of processing your feedback or for contacting you if desired, and for improving our services. This data processing is therefore required to fulfill our (pre-) contractual obligations and to safeguard our legitimate interests in the ongoing development of our services and website. Cookies Our website uses so-called cookies. These are small text files that are stored on your device by the browser. They do no harm. On our cookie policy page you will find a detailed list of cookies we use on our website. Our website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. You can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings”. If you have given your consent, we use tracking, marketing and web analytics cookies to make our offerings user-friendly based on your usage data. If you do not want this, you can set up your browser so that it informs you about the setting of cookies and you can then allow this only in individual cases. In this case, only the absolutely necessary cookies are set (Necessary Cookies) and we also record only anonymous data about your visit to our website, for example, to be able to determine the total number of visitors. Disabling cookies may limit the functionality of our website. Here is a link to our cookie policy page, which shows you which cookies we use and gives you the option to change your cookie settings. Google Analytics If you have given consent to cookies, our website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of our website (including the shortened IP address) is usually transmitted to and stored by Google on servers in the United States. Our website uses Google Analytics exclusively with the extension “_anonymizeIp ()”, which ensures anonymization by truncating the IP address and thereby preventing a direct personal reference. By activating IP-anonymisation your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing them with other services relating to website activity and internet usage. The IP-address, that your Browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to make full use of all the functions on this website. You can also opt-out from your data concerning the use of the website (incl. your IP address) being tracked with the use of cookies and processed by Google Analytics with effect for the future by downloading and installing the Google Analytics Optout Browser Addon for your current web browser: For more information on the handling of user data by Google Analytics, please visit the Google Privacy Policy: Hotjar If you have given your consent to cookies, we use Hotjar in order to better understand our users’ needs and to optimize our service and users’ experience. This is provided by Hotjar Ltd, Level 2, St Julians Business Center, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service by means of user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular the IP address of the device (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s Privacy Policy. If you do not want to be recorded by Hotjar, you can disable it by setting the DoNotTrack header in your browser. For more information and more about Hotjar’s data processing, please visit: Salespanel Information about the consent to Salespanel for processing of personal data: We obtain your consent to the processing of personal data on behalf of Vardhaman Syndicate (Legal entity of Salespanel). Information collected from cookies set in your device that qualify as personal data will be processed by Salespanel. Salespaenl stores the IP-address from which you visited our website, email address when you fill in a web form in the website domain and browser meta-information that helps them to uniquely identify and track a visitor. The purpose of the processing of the personal data: Salespanel helps us to identify and qualify relevant leads by tracking their web visit activity and by providing us with publicly available information, for example: social media profiles and your company website. Salespanel uses information collected from the cookie set in your devices which helps us to improve our sales and marketing and to improve their lead generation and lead qualification service. This information is only meant to be used for our internal purposes and can be shared with other GDPR compliant applications to help us serve you. Salespanel stores all client data in a fully encrypted environment and uses ECDSA Signature with SHA-256 for data exchange. To know full information about Salespanel’s privacy policy: You may at any time withdraw your consent to this processing. Such withdrawal may be made either by contacting us or by contacting Salespanel Directly: Salespanel / Vardhaman Syndicate 303, Lunkad Skymax, Viman Nagar, Pune. India – 411014 Email at: support(at) Leadpages In addition, we use the third-party provider LeadPages for landing page creation and associated services. For more information, please see LeadPages privacy notice. DocSend provides a website that enables companies and individuals to organize, manage, and control documents and content they send to individuals within their company or outside their company. DocSend processes personal data from its users and customers, as well as their end-users. This includes IP address, names, email addresses, browser information like operating system and device type. We also process activity data that includes which portions and for how long content within the DocSend platform is used. We use this information to respond to requests for information about our service, to provide our service, to send marketing communications and other announcements to users and prospective users, and for other legitimate business interests including to personalize the site’s experience. Personal Data may be disclosed to certain third party companies and individuals to help us provide, support, analyze, and improve our service (such as providers of data storage services, maintenance services, payment processing, database management, providers of analytics services who help us understand how you use and interact with the Site and the Service, providers of digital advertising services, providers of CRM, marketing, and sales software solutions). These third parties may have access to personal data for the purpose of performing these tasks on our behalf and pursuant to our instructions, under obligations similar to those in our Privacy Policy. 1. Information We Collect When you interact with the Site or the Service and in connection with our events, and sales and marketing activities, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”), as described below: A. Information You Provide as a User When you register an account as a User, you may be asked to provide Personal Data including without limitation, your name, phone number, email address, home address or business address. You may also choose to submit Personal Data to us when you send us an email or use any interactive features that we may make available on the Service. For example, you may ask us to: (a) import your contacts by giving us access to your third party services (such as your email account) or (b) use your social networking information if you give us access to your account on social network connection services. You may also provide us with your contacts’ email addresses when sharing folders or files with them or if you invite them to join DocSend. In addition, if you sign up for our paid Service, you may be asked to provide additional information, including your credit card information, as described below. B. Events We may also collect data from you including without limitation when you attend one of our events, during phone calls with sales representatives, or when you contact customer support. C. Employment Applications When you apply for employment through the Site, our provider of recruiting services will collect your resume and any additional information that you elect to provide to us, including but not limited to your employment history and education. In addition, where permitted by law, we may use a third party to carry out a background check to determine your suitability for a position. D. Information We Receive from Viewers If you are a Viewer, a User may request that you provide them with information (including Personal Data) via the Service in order to view that User’s Content. In particular, in order to access Content that a User wants to share with Viewers, a Viewer may be asked to provide his or her email address upon opening a DocSend User’s link (or Viewers’ email address may be provided by the User). DocSend stores this information on behalf of our Users. In the event you as a Viewer provide a User with this information, you do so in accordance with that User’s privacy practices and policies. DocSend is not responsible for the privacy practices of its Users, and does not access this information except with a User’s permission, in order to provide the Service and related support and assistance. If you are a Viewer of one of DocSend’s Users and would no longer like to be contacted by such User that uses DocSend’s Service, please contact the User that you interact with directly. E. Content In providing the Service, we process on behalf of Users information included in the Content that Users (and as appropriate Users’ representatives, employees or other data subjects as elected by Users) upload, download, or access with, share, or send through the Service (“Content”). If you add Content to your account that has been previously uploaded by you or another user, we may associate all or a portion of the previous Content with your account rather than storing a duplicate. F. Information We Receive from Third Parties We may also receive Personal Data (such as your email address) through other Users, for example if they have tried to share something with you or tried to refer DocSend to you. We may supplement the information that we collected from Users and Viewers (such as an email address) with additional information obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information), and display this information to our Users as a part of our Services. G. Automatically Collected Information i. Log Data. When you use the Service, we automatically record information from your Device, its software, and your activity using the Service. This includes the Device’s Internet Protocol (IP) address, operating system, browser type, the web pages you visited before you came to the Site, the web pages you view immediately after leaving our Site, information you search for on the Site, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning the Content, and other interactions with the Content and the Service. We collect this information in order to deliver the Service and to provide our Users with reporting and analytics relating to the use of the Service. This information is made available to Users via the Service (for example, we provide Users with information on a Viewer’s location based on that Viewer IP address) and may be associated with other information about the User and its Viewers (including Personal Data) that Users provide us. If you are a Viewer who views Content you receive from a User via the Service, we automatically collect information about your interaction with such Content and our Service. The information we collect includes: Whether or not a you have viewed or are viewing Content; Date and time you viewed the Content; Number of times and length of time Content was viewed; Which portions of the Content were viewed; and Your IP address and location. If you have any questions about this Privacy Policy, please contact us at, or by post at: DocSend, Inc. Email: Attention: Privacy 351 California St., STE 1200 San Francisco, California, 94104 United States of America Social Media Sharing We offer the possibility to share blog articles of our website on social media like Facebook, Twitter, LinkedIn and Google+. In order to increase the protection of your data when visiting our website, these buttons are only embedded in the page by means of an HTML link and not fully integrated. This ensures that when you visit a page on our site that contains such buttons, it will not automatically connect to the Facebook, Twitter, LinkedIn, or Google+ servers. If you click the button, a new browser window will open and call up the Facebook, Twitter, LinkedIn or Google+ page, where you can interact with the plugins there (if necessary after entering your login data). Further information on these plugins, which open in a new browser window, can be found here: Facebook-Plugin Our website links to a browser window that uses so-called social plugins (“plugins”) of the social network Facebook operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). For more information on the purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your related rights and settings options for the protection of your privacy, please refer to the Privacy Policy of Facebook: Google+-Plugin Our website links to a browser window that uses so-called social plugins (“plugins”) of the social network Google+, operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The plugins are recognizable for instance on buttons with the sign “+1” on white or colored background. An overview of the Google Plugins and their appearance can be found here: For more information on the purpose and scope of the data collection and the further processing and use of the data by Google as well as your related rights and settings options for the protection of your privacy, please refer to the Privacy Policy of Google: Twitter-Plugin Our website links to a browser window that uses Twitter microblogging plug-ins operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). The plugins are marked with a Twitter logo, for example in the shape of a blue “Twitter bird”. An overview of the Twitter plugins and their appearance can be found here: For more information on the purpose and scope of the data collection and the further processing and use of the data by Twitter as well as your related rights and settings options for the protection of your privacy, please refer to the Privacy Policy of Twitter: LinkedIn-Plugin Our website links to a browser window that uses LinkedIn plugins provided by the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (hereinafter referred to as “LinkedIn”). You can recognize the plugins of LinkedIn by the corresponding logo or the “Recommend-Button”. For details on the collection of data and your legal as well as settings options, visit LinkedIn at: Embedded services and third party content We use third-party services and content within our online offering based on our legitimate interests in the provision, optimization and economic operation of our online offerings to integrate their content and services. This usually requires that the respective third-party providers of this content receive the IP address of the users, as they would not be able to send the requested content to their correct browser without the IP address. The IP address is therefore required for the presentation of this content and the use of the incorporated services. Typeform Our website links to a browser window that uses domain name is provided by TYPEFORM SL, a Spanish entity with registered address at Carrer Bac de Roda, 163, local, 08018 – Barcelona (Spain), and C.I.F. (Spanish tax identification number) B65831836. The Company is registered in the Commercial Registry of Barcelona, page B-421911, folio 145, volume 43262. You may contact us by sending an email to or filling out this Typeform. Your use of the Site and/or the Services may result in the collection and further processing of information, including information of personal nature. We will inform you whenever said collection and processing takes place, and the processing shall be governed and subject to our Privacy Policy and Cookie Policy. Google Web Fonts This site uses so-called web fonts provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) for consistent presentation of fonts. When you visit a page, your browser loads the required web fonts into its browser cache to display texts and fonts correctly. To do this, the browser you use must connect to Google’s servers. As a result, Google learns that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a consistent and attractive presentation of our online services. This constitutes a legitimate interest. If your browser does not support web fonts, a default font will be used by your computer. More information on Google Web Fonts can be found at and in Google’s Privacy Policy Google Maps We use maps by the service Google Maps of the third party Google on our website. Under the links provided you will find the Privacy Policy: and the possibility of objection: Disclosure of personal data to third parties We share your personal information to the extent necessary withthe following external service providers (processors) who assist us in the provision of our services: IT service providers and / or providers of data hosting solutions or similar services; other service providers, suppliers of tools and software solutions who also support us in the provision of our services and act on our behalf (including providers of marketing tools). All our processors process your data only on our behalf and on the basis of our instructions, so that we can make our online offer available to you. In addition, we will transmit your personal data to the extent necessary to the following recipients (responsible persons): any third parties involved in the provision of services to you to fulfill our contractual obligations; external third parties to the extent necessary on the basis of our legitimate interests (for example, auditors and tax consultants, insurances in the event of a claim, legal representatives if required); authorities and other public bodies to the extent required by law (such as tax authorities). If we process your data in a third country outside the European Union (EU) or the European Economic Area (EEA) or in the context of the use of third party services, this will only be done if it is necessary to fulfill our (pre)contractual obligations based on your consent, due to a legal obligation or based on our legitimate interests. Storage duration We only store your personal information for as long as it is necessary for the purposes for which it is processed. In addition, we might be obliged to keep your data for a longer period of time due to applicable statutory retention periods. Specifically, we store your data in connection with contacting us on the basis of corresponding statutory retention requirements for a period of generally seven years, insofar as they are no longer of use to us. Access data and log files are stored for a maximum of 14 days and then deleted. As a rule, we store data on your user behavior for a period of three years, or at the latest until you revoke your consent. Personal data provided by you as part of feedback and surveys will remain stored until deleted by you or us. If you have only registered for our newsletter and are not a customer of ours, we store your data until you revoke your consent and apart from that up to a maximum of three years. In addition, we store your personal data beyond the specified periods if necessary, as long as legal claims can be asserted from the relationship between you and us or until the final clarification of a specific incident or legal dispute. This longer retention is essential for the protection of our legitimate interests in the assertion, investigation and defense of legal claims. Data security We take appropriate technical and organizational security measures within the meaning of Art. 32 GDPR in order to ensure a level of data protection commensurate with the risk, in particular, to protect your personal data against unintentional or unlawful deletion, rectification or loss, and against unauthorized disclosure or access. Your rights You, therefore, have the right to information about the personal data we process of you. In addition, you have the right to rectification of incorrect data and deletion of your data (“right to be forgotten”). You may also revoke your consent to the processing of personal data with effect for the future if processing is based on your consent. You may also be entitled to restrict the processing of your data, to object to it, and to the right to receive the data you provided in a structured, common and machine-readable format (“data portability”). You also have the option to file a complaint with a data protection supervisory authority. The data protection supervisory authority responsible for us is: Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter, Feldeggweg 1, CH-3003 Bern. Before submitting a complaint to the DPA, or in the course of your or other questions, please contact us: Stableton Financial AG, Poststrasse 24, 6300 Zug, Switzerland. In order for us to process your request for your above-mentioned rights and to ensure that personal information is not disclosed to unauthorized third parties, please direct the request with a clear identification of your person and a brief description of the extent to which you exercise your above-listed rights of individuals affected. Changes to the Privacy Policy Changes will be announced on our website. Therefore, you should visit this Privacy Policy regularly to keep up to date with the latest developments. ** Data from sourced by ’Cambridge Associates’ Q3 2019 report. The Cambridge Associates Index is a pooled horizon IRR calculation based on quarterly data compiled from 2,220 funds, including fully liquidated partnerships, formed between 1986 and 2019. S&P 500 Total Return Index as sourced from Yahoo Finance. S&P 500 TR Index data are annual compounded return calculations which are time-weighted measures and are shown for reference and directional purposes only. The CAPE Index is not an investable index and is used solely for illustrative purposes. Due to the fundamental differences between the calculations underlying the CAPE Index and the S&P 500 Total Return Index, a direct comparison of IRRs to time-weighted returns is not recommended.