Privacy Policy

The protection of our clients' data and the privacy of the users of our website is important to us. The personal data we collect or receive in the course of our business activities is treated confidentially and securely protected against access. Most of our website content can be used freely. However, we use industry-standard technologies to measure and improve the performance of our website and collect data for this purpose. In some cases, we work with external service providers. To the extent that we (or third parties on our behalf) collect and process personal data, we comply with the requirements of the Swiss Data Protection Act. This privacy policy ("Policy") describes how Quality Treuhand ("we", "us" or "our") collects and processes personal data and what rights you have in this regard.

By using our services, you agree to this privacy policy. If you provide us with personal data of other persons, please ensure that these persons are aware of this privacy policy and only share their personal data with us if you are authorized to do so. Quality Treuhand is a company registered under Swiss law, which is subject to Swiss data protection regulations, such as the Federal Act on Data Protection ("FADP"). In this privacy policy, the terms "process" and "processing" as well as "personal data" are used synonymously with the terms "handle" and "handling" as well as "personal data" as defined under Swiss law. When you engage us, Quality Treuhand is the data controller within the meaning of the FADP, which determines the purposes and means of processing personal data. If a client uses our services and there is an agreement between the client and a third party regarding the processing of personal data, the client's privacy policy applies to that third party and not this privacy policy. If you do not agree with this privacy policy, you should not use our services. If you have questions about data protection, please do not hesitate to contact us (Section 11).

Personal data is any information that relates to an identified or identifiable natural person. Data that cannot be attributed to a natural person (anonymous data) does not count as such. We primarily process the personal data that we receive as a fiduciary company in the context of our mandates with our clients and business relationships with other business partners from these and other persons, companies and public bodies involved. Particularly sensitive personal data includes data on religious, philosophical, political or trade union views or activities, data on health, the intimate sphere, including information on sexual life and sexual orientation, data on racial or ethnic origin, genetic data, biometric data that uniquely identifies a natural person, data on administrative and criminal prosecutions or sanctions, and data on social welfare measures. We process, i.e. collect, use, store and transmit various types of personal data such as: a. Data about your identity such as first names, surnames, date of birth, gender, title; b. Contact data such as addresses (billing address, delivery address, email address) and telephone number as well as financial data such as bank details and payment card data; c. Performance data such as information on payments to you or from you as well as other information on services that you have received from us or we from you; d. Identification and background information that you provide to us or that is collected from you as part of our onboarding process; e. Information related to your professional functions and activities (so that we can, for example, with your help, conclude and process business with your employer); f. Data and information, for example in documents or correspondence and discussions with third parties, which are transmitted to us by third parties (Section 2a) or which we obtain from public registers, in particular in the context of a mandate or other contractual relationship; g. Information that is disclosed to us by or on behalf of our clients or that we create in the course of our services to clients; h. Information that is communicated to us for the purpose of participating in meetings, seminars or events; i. Advertising and communication data such as information about when you receive and read newsletters from us, which of our events you attend, and preferences in advertising and communication settings; j. All other information relating to you that you make available to us.

We collect and process personal data when you communicate with us or our employees, register to receive information by email, or when you attend a meeting, seminar or other event. In addition to the data you give us directly, we collect personal data from the following sources: a. Information that our clients, your family, your employer, your contracting parties, our business partners, advisors or other third parties provide to us; b. Information from public registers (e.g. debt enforcement registers, land registers, commercial registers, press, internet); c. Information from media and the internet about your person (to the extent that this is appropriate in the specific case, e.g. in the context of an application, press review, marketing/sales, etc.). When you access our website, data transmitted by your browser and automatically stored by our server is recorded, such as the date and time of access, the name of the file retrieved, the amount of data transferred and the access time, your web browser, browser language and requesting domain (further data is only collected via our website if you provide this information voluntarily, for example as part of a registration or enquiry). If you register to receive our newsletter, we process the contact details you provide, such as salutation, first name, surname, company and email address.

We process your information, including your personal data, for the following purposes: a. Primarily, to conclude and fulfill contracts with our clients and business partners, in particular in the context of providing fiduciary services to our clients; b. For the purpose of purchasing products and services from our suppliers and auxiliaries (such as in particular engaged experts in Switzerland and abroad). If you work for such a client or business partner, you may be affected in this capacity with your personal data; c. To fulfill legal and regulatory obligations and responsibilities, in the context of our general business activities and for other business administration purposes; this includes in particular duties to comply with the supervisory obligations applicable to fiduciaries, including the due diligence obligations under the Federal Act on Combating Money Laundering and Terrorist Financing (AMLA); d. For marketing, advertising and other purposes: To the extent that you have given us consent to process your personal data for specific purposes, we process your personal data within the scope of and based on this consent, unless we have another legal basis and we need one. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place; e. For the further development of our offers, services and websites and other platforms on which we are present; communication with you; communication with third parties and processing of their enquiries (e.g. applications, media enquiries); f. In the context of asserting legal claims and defense in connection with legal disputes and official proceedings; g. For the purpose of ensuring our operations, in particular IT, our websites and other platforms as well as measures for IT, building and facility security and protection of our employees and other persons and assets entrusted to us (such as access controls, visitor lists, network and mail scanners); h. In the context of any corporate transactions and the associated transfer of personal data as well as measures for business management, compliance with legal and regulatory obligations and internal regulations of Quality Treuhand.

Depending on the purpose of the processing activity (see Section 3 above), the processing of your information and personal data takes place when: a. it is necessary for the conclusion or performance of a contract for the requested services or for the fulfillment of our obligations under such a contract, e.g. when we process your data for some of the purposes mentioned in Sections 3a – 3c (as well as for some of the data disclosures described in this Section 4); b. it is necessary for the legitimate interests of Quality Treuhand, without unreasonably impairing your interests or fundamental rights and freedoms; c. it is necessary to comply with our legal or regulatory obligations, including conducting checks to identify you and disclosing information to authorities, regulatory bodies and government agencies (Sections 5b and 5c); d. when we process particularly sensitive personal data or special categories of personal data that are necessary for the establishment, exercise or defense of legal claims, or when the processing relates to personal data that are manifestly made public; or e. they are processed with your consent, which we obtain from you from time to time (e.g. when required by law), or which are processed with your express consent where necessary, in the case of particularly sensitive personal data or special categories of personal data. Examples of the above-mentioned "legitimate interests" are: f. the pursuit of certain purposes of Sections 3d to 3h; g. exercise of our rights under Articles 26 and 27 of the Federal Constitution of the Swiss Confederation, including our entrepreneurial freedom and our right to property; h. when we make the disclosures mentioned in the following Section 5, provide products and services and want to ensure a consistently high standard of service and the satisfaction of our clients, employees and other stakeholders; and i. the fulfillment of our accountability obligations and legal requirements; j. in any case, provided that your interests in the protection of privacy do not outweigh these interests.

In the context of our activities, we are subject to professional secrecy. To the extent permitted, we may share your personal data as follows: a. We may share personal data within our company; when we do so, the use and disclosure of your personal data is subject to this Policy. b. We may disclose personal data to comply with the law, legal proceedings, a court order or other legal process, including arbitration proceedings, e.g. in response to a court order or subpoena. c. Where necessary, we disclose personal data to public and judicial authorities, supervisory authorities or government agencies, such as in particular tax authorities (FTA, cantonal tax offices), social insurance authorities (AHV/IV/EO/ALV), the commercial register office and other competent authorities, including when required by laws or regulations, under a code of conduct or by these authorities or bodies. d. We may share your data with third-party providers, service providers, contractors or representatives who perform service functions that we need for the operation of our business, such as banks, insurance companies, counterparties and their representatives as well as other involved persons (guarantors, financiers, affiliated companies, information providers, experts, etc.), providers of hosting, email communication, customer services, analytics, marketing and advertising, on the basis of our instructions and in accordance with this Policy and other appropriate confidentiality and security measures. The aforementioned recipients may be located outside Switzerland. In these cases, except where the relevant country has been classified by Switzerland as providing an adequate level of protection, we take appropriate safeguards (e.g. by concluding the EU Commission's standard contractual clauses, including the adjustments necessary for Switzerland) to ensure that such transfer is carried out in accordance with applicable data protection regulations. A transfer of personal data to recipients or service providers in countries that do not offer an adequate level of protection is normally carried out when this is necessary for the performance of a contract with the data subject(s) concluded in their interest and for the assertion, enforcement or defense of legal claims. You can request additional information in this regard and receive a copy of the relevant safeguards (e.g. standard contractual clauses) by contacting us at the address given at the end of this notice.

We retain your information, including personal data, only for as long as necessary to fulfill the purpose for which it was collected and as long as we have a legitimate interest in retaining personal data, for example for the conduct or defense of legal claims or for archiving purposes and IT security. For business books, receipts and related personal data, a statutory retention period of 10 years applies pursuant to Art. 958f CO. Furthermore, we store your personal data if and as long as this is required by any further statutory retention obligation.

We do not use cookies on our website that collect data from website visitors.

Our service may contain links to third-party websites. Access to and use of such linked websites is not governed by this privacy policy, but by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

We have taken appropriate precautions to protect the data we collect against loss, misuse and unauthorized access, disclosure, alteration and destruction.

10.1 What rights do you have? Persons located in Switzerland or the European Economic Area (EEA) have certain rights with respect to their personal data. Quality Treuhand offers you the opportunity to exercise your rights, including: a. the right to access your personal data; b. the right to correct or rectify inaccurate personal data; c. the right to restrict or object to the processing of personal data; d. the right to have your personal data deleted; and e. the right to portability of personal data. These rights are available to you in accordance with the provisions of the Data Protection Act. Please note that these rights are not unconditionally applicable and may be subject to restrictions. 10.2 How can you exercise your individual rights? The exercise of your rights requires that you prove your identity (e.g. by means of a copy of your ID). To assert your rights, you can contact us at the address listed in Section 11. You also have the right to enforce your claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

Quality Treuhand AG Holbeinstrasse 22 8008 Zurich Switzerland Tel. +41 44 557 20 80

This Policy is effective as of the effective date stated above. We may change this Policy from time to time, so you should review it regularly.