Privacy policy

1. General Provisions

The Operator seeks to protect the privacy of Platform Users and Investors. The Operator collects, processes and uses Users' and Investors' personal data in accordance with applicable legal provisions, including inter alia the Swiss Data Protection Act (DPA) and the European General Data Protection Regulation (GDPR), as applicable. The Operator is the controller of the data file within the meaning of Article 3(i) of the DPA (and the controller within the meaning of Article 4, paragraph 7 GDPR, if applicable).

The following provisions form an integral part of the Platform's T&Cs. By accessing the Platform or one of its subdomains, the User confirms that he has read and understood these provisions and declares that he unconditionally approves them, notwithstanding any registration on the Platform. He may withdraw consent for personal data processing at any time. Such withdrawal shall not affect the lawfulness of prior processing.

2. Data collection

The Operator collects and processes personal data provided by the User. This particularly includes data provided by the User on registering on the Platform, [subscribing for other services offered by the Platform (e.g., signing up for the newsletter), using the contact form or reporting problems on the Platform.] The Operator may request additional personal data from the User at any time if this proves to be necessary to carry out an investment or perform any existing contractual relationship.

The User's personal data includes inter alia his first name and last name, date of birth, address, nationality, e-mail address, telephone number and any other information which is useful to the Operator to provide the services offered by the Platform and, in particular, to approve an investment or enter into and perform an agreement with the Investor.

Each time the User visits the Platform, the Operator automatically collects some information, such as the type of browser used, the User's IP address, language, cookies, operating system and any other information relating to use of the Platform.

The Operator shall take all measures reasonably necessary to ensure the security of the processing of the User's personal data and to implement strict procedures and appropriate security arrangements to prevent unauthorised access to Users' data.  However, the Operator cannot ensure absolute security of personal data.

3. Data processing and retention

The Operator processes the User's personal data in order to provide him with the services offered by the Platform, manage any existing contractual relationship with the User and administer the User's investments. The Operator also processes the User's personal data for marketing or market research purposes.

The Operator retains the User's personal data [at least throughout the whole term of his registration on the Platform, and then for a period of one year.

4. Data transfers

The Operator may transfer the User's personal data to affiliated companies or partner companies and entrust them with processing such data for the purpose of the services provided by the Platform. In this case, the Operator makes sure that these service providers are contractually bound by a confidentiality obligation. In addition, for the purpose of the services offered by the Platform, the Operator may transfer the User's personal data to the financial institution which grants a loan to finance the property investment published on the Platform and to all persons, companies or authorities involved in administering and managing (in particular, to the Administrator or Representative under the relevant building's rules of use and management) as well as completing, holding and selling the property investments published on the Platform. For example, this includes the public notary in charge of executing the property sale agreement or the land register.

The Operator transfers the User's personal data to third parties for other purposes only with his approval. The cases where the Operator is required to transfer personal data to third parties in accordance with the law or an administrative or judicial decision are reserved.

It is possible that the User's personal data is transferred to third parties abroad, to a country which does not the guarantee the same level of data protection as Switzerland. If this is the case, the Operator shall ensure that the foreign third party provides appropriate protection of personal data and takes the protection measures required for this purpose.  Subject to compliance with these terms and conditions, the User expressly grants his prior acceptance of the transfer of his personal data abroad.

5. Cookies

The Platform uses cookies. Cookies are text files which collect data on browsing history. They are used to ensure the proper functioning of the Platform and to only save anonymous data.

By using the Platform without changing his browser settings, the User accepts the use of cookies.  The User can reject or delete cookies by changing his browser settings at any time.  However, it is possible that some functionalities of the Platform will not be available. Therefore, the Operator recommends that the User keeps the cookies activated.

6. Google Analytics

The Platform uses Google Analytics, a web analytics service provided by Google Inc. ("Google").

Data generated by cookies relating to the User's use of the Platform (including the IP address) shall be sent and stored by Google on servers located in the United States or in other foreign countries. Google uses such data with the aim of evaluating use of the Platform, compiling Platform activity reports for the editor or providing other services relating to the Platform's activities and web use.

Google may transfer this data to third parties if it is bound by a corresponding legal obligation or when third parties process data on behalf of Google, including the Platform editor. Google does not match up the IP address with any other data held by Google. 

By using the Platform without changing his browser settings, the User accepts that Google processes his data in accordance with the terms and conditions and for the purposes described above.

7. Social Media Plugins

The Platform integrates social media plugins for the social networks Facebook (run by Facebook Inc.), Twitter (run by Twitter Inc.), LinkedIn (run by LinkedIn Corporation) and Google Plus (run by Google Inc.).

As soon as the User uses the Platform with an activated social media plugin, his browser directly links to the social network's servers via the social media plugin and shares information with this social network.

Even if the User is not a member of the corresponding social network, it is possible for the social network to have access to and store data such as the User's IP address via the social media plugin.

The Operator has no knowledge of the transferred data or how such data is used by the social network. The User can find additional information on this subject in the social networks' data protection notices.

8. E-mail addresses

The Operator uses the e-mail address provided by the User to send him e-mails relating to his investments or present him investment opportunities. The User can disable such e-mails at any time.  The User can only disable e-mails relating to a given investment which he has committed to carry out or has already carried out except if he withdraws his undertaking to invest or his investment. The Operator cannot guarantee the confidentiality and absolute security of the e-mails and the content thereof.

9. User's additional rights

Insofar as the GDPR applies to the relationship between the Operator and the User, the latter has the following additional rights, in accordance with the provisions of the GDPR: the User has the right to request the restriction of processing of his personal data (Article 18 GDPR), the right to portability of his personal data (Article 20 GDPR), the right not to be subject to a decision based solely on automated processing (Article 22 GDPR) and the right to lodge a complaint with a supervisory authority (Article 77 GDPR).

In addition, the User has the right to object to the processing of his personal data (Article 21 GDPR, if applicable).