EFFECTIVE DATE: JULY 1, 2024 12:00 AM CET

This Privacy Notice (the “Notice”, the “Privacy Notice”) applies to the processing of personal data by BoGe Partners a company registered and existing under the laws of Switzerland (registration number xxx ), (“BoGe”, “we”, “us” and “our”) in its capacity as a data controller of personal data.
The Privacy Notice explains our data privacy practices in regard to the processing of personal data of individuals (“data subjects”, “you”, “your”) who visit our website (the “Site”), and/or use the services accessed through the Site (the “Services”) and/or as otherwise described in the Policy below.

I. Categories of data subjects and types of personal data
Website visitors and Service Dashboard Users
a. Definition: the Users who visit, access, use and/or interact with our BoGe Partners’ website.
b. Types of personal data:
Contact information – We may collect personal data such as country, email address, and investor accreditation status when you submit a “Contact us” form through the website.
Personal data, contained in log files – When you visit our Site we may process information such as your IP address, referral URL, exit URL, browser software, operating system, date/time and/or clickstream data.
Personal data collected through website analytics tools – We may collect information about your use of our Site, such as number of visits, pages visited, popularity of certain content. Analytics tools use tracking technologies (such as cookies) to recognise your device and compile information about you. They collect information such as what pages you visit and how much time you spend on these pages, the IP address assigned to you, what operating system and web browser you use, and what site you visited prior to visiting our Site.

II. Purposes of and legal basis for data processing
We strive to collect only the minimum personal data necessary for the completion of the purposes of data processing, as set out below.
If you are residing in a country from the EU, EEA or in the UK, or in any other country where the processing of personal data shall be subject to a legally defined lawful basis, the following purposes and legal basis shall be applicable to the processing of your personal data by BoGe Partners:
To provide, administer, maintain and secure the Site and Services. In such cases the legal basis for the data processing is the performance of a contract.
To notify you for any Service-related matters, to invite you (via separate email or during our interaction with you via any of our communication channels) to give your feedback and/or review regarding the quality of our Services and/or your experience with us and our interaction, to improve and/or develop the Services for the benefit of our Customers, and for statistical purposes. In such cases the legal basis for the data processing is our legitimate interest.
To promote our brand and Services, including to send marketing communication, newsletters, surveys, monitor and analyse activities for advertising purposes etc. In such cases the legal basis for the data processing is your consent. The consent to such marketing communication is voluntary and can be revoked at any time. The revocation can take place in the settings in the Customer account or via the unsubscribe link in every such marketing email sent by us.
To fulfil our legal obligations, such as compliance with court orders, orders/requests or other documents issued by competent authorities, applicable legislation, etc. In such cases the legal basis for the data processing is the compliance with a legal obligation to which we are subject.
For other purposes which may not fall under the scope of the above-mentioned purposes we will obtain your consent.

III. Cookies, beacons, tags, pixels
We use cookies to collect some of the information set out in this Policy. Cookies can store your account identifier, ordering status, personalisation or website tracking. They can also be used for technical purposes such as enabling you to save information which has already been entered, so that we can offer improved and more personalised Services, products and other relevant communication tailored to you.
We also use remarketing pixels provided by third parties to collect the information that you have visited our Site and were interested in certain offers.
We also use beacons, tags, click tracking codes and scripts to analyse trends and movements of users around the Site, gather information about the user base as a whole and how we can improve the Services and Site, to provide advertising based upon activities and interests and to measure advertising effectiveness. As a result we may display targeted, or interest-based, offers to you based on the products you currently own or have recently viewed and deliver other communication more relevant to you and your interests outside of our Site, on other websites part of the third party’s network.
We may share a unique code (such as a hashed email address) with аdvertising platforms and social networks to allow us to track online conversions from different sources and to direct targeted advertising to you or to a custom audience who share similar traits.

IV. Sharing of personal data
We disclose entire or part of your personal data in the following circumstances and always ensure that the appropriate safeguards on your privacy are undertaken:
To provide the Services and run our business – We may engage third-party service providers in the delivery of the Services and also for administrative, billing, tax, compliance and all other purposes related to the management of your account and our operations. In such cases your personal data may be shared with, business partners, independent contractors, external consultants, auditors, collaborators, etc. Those third-party service providers include companies that operate in different industries such as fraud detection, technology service, internet information providers, payments and data processors, couriers, providers from the finance, media and communication, internet content and information industries, advertising and marketing, technologies, analytics, etc. and that may be located worldwide (including but not limited to the EU, EEA, Switzerland, UK, USA, Canada, Australia, Singapore, Japan, Brazil, etc.).
1.1. We also may share data with Google whose invisible reCaptcha service we use to protect our website from malicious activity. Use of the invisible reCaptcha is subject to Google’s Privacy Policy and Terms of Service.
1.2. We may use artificial intelligence (AI) models and tools and integrate them into our Services for various purposes (such as BoGe search tools, text and visual content generation, customer support, including but not limited to quality evaluation and improvement, etc.). We will disclose any such use on the respective webpage where the AI models and tools are integrated. In the course of using the AI models and tools integrated into our Services, we will not disclose any personal data to the third-party providers of AI models and tools. Although we take all necessary and reasonable care to obfuscate/anonymize any personal data before sharing any information with the third-party AI models and tool providers, we strongly advise you not to include any personal data in the AI tools integrated into our Services.
To comply with the applicable legislation and to exercise rights – We may share personal data with companies, organisations or individuals when we believe in good-faith that access, use, preservation or disclosure of such data is necessary to meet any applicable law, comply with regulations, legal procedures, enforceable requests and/or competent authority requirements; to enforce our terms, defend against claims and protect the rights, property or safety of BoGe, our Customers and/or the public as required and/or permitted by law.
In case of business reorganisation, transfers and/or acquisitions – We may share your information to third parties in connection with any prospective or completed business reorganisation, merger, sale of company assets, or acquisition of all or a portion of our business by another entity, or in the unlikely event that BoGe goes out of business or enters bankruptcy. If any of these events happens, we may take any reasonable steps to notify you.
To comply with your instructions – We may share your information with third parties with your explicit consent or at your direction. We will not, however, sell, rent, share or otherwise disclose personal data for commercial purposes in any way that is contrary to the commitments made in this Policy.
We also may use the services of third-party service providers for reviews (such as Trustpilot, etc.) to collect your feedback and/or review regarding our Services, their performance, our overall service quality and/or your experience with us and our interaction. In this case your name, email, chat or ticket ID, or other reference data will be shared with such third-party service providers, and they will process your data under their own privacy policies and practices.

V. International data transfers
In the course of our business operations and for the delivery of the Services we may transfer personal data around the world (including but not limited to the UK, USA, Canada, Australia, Singapore, Japan, Brazil, etc.) where we and/or the third parties, specified in Section V above, use data centers, facilities and/or maintain data processing operations.
When transferring personal data outside the EU/EEA we will use the appropriate transfer mechanisms to ensure that the transfer is in compliance with applicable data protection legislation. Such mechanism shall be transferring the personal data: (i) to a recipient in a country for which the European Commission has decided to provide adequate level of data protection; or (ii) to a recipient that has executed the Standard contractual clauses approved by the European Commission.
In all cases we will ensure that we have provided appropriate and proportional technical and organisational data protection and cybersecurity risk mitigation measures, as well as we have performed the appropriate risk assessments when transferring your personal data outside the EU/EEA.

VI. Security measures
We use Secure Sockets Layer (SSL) protocol to encrypt the information you enter on our Site in order to protect its security during transmission to and from our Site. When storing information, we protect its security by encrypting critical data. Access to this information is severely restricted, logged and reviewed periodically. We maintain physical, logical, electronic and procedural safeguards when collecting, storing and disclosing personal data. Our security procedures require us in some cases to request proof of identity before disclosing personal data to you.
To protect against unauthorised access to your account and information, we implement session management, strong authentication requirements, login expiration mechanisms and the option of using 2-factor authentication for Client Area access. Authentication data is encrypted. As an additional safety measure, we ask you to sign out when you finish using your account and your computer.
Although we take appropriate technical and organisational measures to maintain the safety and security of your personal data against loss, theft and unauthorised use, access or modification, please note that no transmission of information over the Internet is completely secure. Consequently, please note that we cannot fully guarantee the security of any personal data that you transfer over the Internet to us.

VII. Retention periods
Information collected on our Site will only be retained for as long as necessary to fulfil the purpose for which it was collected. In general, we will automatically and securely delete your Client Area account information 2 years after you no longer have any active Services with us. Since we need to comply with applicable regulations in regard to retention of personal information related to contractual agreements, provision of Services, financial, billing, invoicing operations, tax calculations etc., a versioned copy of your order, payment and billing documentation may be stored for a period of 10 years after the termination of your Customer account. Your personal data is deleted automatically by our systems in accordance with these retention periods.

VIII. Your rights
You are entitled to the following rights in relation to your personal data:
Right to be informed: You have the right to be informed about the collection and use of your personal data.
Right to access: You have the right to view and request copies of your personal data.
Right to rectification: You have the right to request inaccurate, incomplete or outdated information be updated or corrected.
Right to erasure (“to be forgotten”): Under certain circumstances you have the right to request your personal data be deleted.
Right to restrict processing: Under certain conditions you have the right to request the restriction of the processing of your personal data.
Right to withdraw consent: You have the right to withdraw your given consent to the processing of your personal data, where we rely on your consent as a legal basis for processing;
Right to object: Under certain conditions you have the right to object to the processing of your personal data (e.g. where we are relying on our legitimate interests as a legal basis for processing);
You can exercise any of your rights by submitting a request to the email address specified in the “Contact information” section of this Policy. Please note that we may ask you to provide us with additional information necessary to verify your identity prior to our response.

IX. Age Restrictions
In accordance with BoGe Partners’ Terms of Use, our Site and Services are designated for use by individuals who are at least 18 years old. If we become aware that we process personal data of a person under the age of 18, we will delete the data and terminate the use of the Services.

X. Changes to the Privacy Policy
We reserve the right to modify this Policy at any time. If we decide to change our Policy, we will post the updates оn the Site and in any other place we deem appropriate, so that you are aware of what personal data we collect, how we process it, and under what circumstances, if any, we disclose it.

XI. Data Protection Authority
You have the right to direct questions or lodge a complaint about the processing of your personal data at any time with the competent supervisory authority for data protection – the Swiss Federal Data Protection and Information Commissioner (FDPIC).

XII. Contact information
For any data processing related questions and/or requests, please contact us at contact@boge-partners.com