Data Privacy

DATA PRIVACY STATEMENT Axelra AG

Version 2.0, August 2023

The following information about data privacy is intended to give you an overview of the processing of your personal data by Axelra AG (hereinafter referred to as Axelra). At the same time it informs you about your rights under data protection legislation.

Further provisions (e.g. Conditions of Use or Cookie Policy) apply to some data processing programmes. These are available on Axelra’s website. All terms referring to persons in this document refer to persons of both genders.

1. Recipients of this Data Privacy Statement

The information about data privacy relates to personal data of:

–  Persons interested in and users of the website who are natural persons.

–  All other natural persons who are in contact with Axelra as well as users of the website axelra.com.

2. Name and address of data controller and contact person

The data controller pursuant to the data privacy provisions is:

Axelra AG
Data Protection Officer
Hagenholztrasse 83
8050 Zurich
info@axelra.com

3. Purpose of processing of personal data and lawful basis for processing

Axelra processes personal data in compliance with the applicable data privacy legislation. The following purposes are pursued:

3.1. Performance of contractual obligations

Personal data is processed in order to provide Tech Venture Building services in the context of the performance of contracts with our users or to implement pre-contractual measures on the basis of requests. Further information and details about the purpose of processing of personal data  can be found in the relevant contract documentation.

3.2. Processing on the basis of consent granted

By giving consent for the processing of personal data for a specific purpose (e.g. evaluation of specific data for marketing purposes), this consent constitutes the lawful basis for the processing of the data. Consent granted to Axelra can be revoked at any time. Please note that such revocation will only have future effects. Processing that was done before the consent was withdrawn will not be affected.

3.3. Protection of legitimate interests

Processing of personal data that go beyond the performance of a specific contract is only done if such processing serves to protect the legitimate interests of us or of third parties. This can apply, for example, in the following cases:

• Measures pertaining to advertising or to market research and public opinion polling, provided that no objection was made to the use of the data.
• Further development measures relating to services, products and business operations.
• Measures pertaining to the assertion and enforcement of legal claims and defence measures in legal disputes.
• Measures to safeguard our IT security and IT operations.
• Measures to prevent and investigate criminal acts and measures relating to the collection of evidence (e.g. in cases of fraud).

3.4. Performance of legal obligations or in the public interest

The processing of personal data may also be required on the basis of legal obligations or public interest. The purpose of processing can therefore also refer to the safeguarding of such interests and have a corresponding lawful basis.

4. Origin and use of personal data

Axelra processes personal data collected in the context of the business relationship with the user.

Processed personal data in particular can include the personal details (name, address and other contact data, date and place of birth and nationality), legitimisation data (e.g. passport, ID data) and other authentication data.

In addition, processed data can also include order data (e.g. payment order), data concerning the performance of our contractual obligations (e.g. data relating to payment transactions), information about your financial situation, advertising and sales data, documentation data and other data comparable to the aforementioned categories.

5. Access to personal data

At Axelra, persons who need such data to secure the performance of our contractual and statutory obligations are given access to personal data.

Service providers and vicarious agents appointed by us can also obtain access to personal data for these purposes, provided that confidentiality obligations and data privacy legislation are observed. Service providers and vicarious agents in this sense are companies providing services in the categories of banking, IT, logistics, printing, telecommunication, debt collection, advisory and consulting services as well as sales and marketing.

When personal data are forwarded to recipients outside of Axelra, attention is paid at all times to compliance with confidentiality obligations and data protection legislation. Personal data are only forwarded against this background if this is ordained by law, the person in question has provided their consent (e.g. to execute a specific transaction), or Axelra has been authorised to provide the corresponding information. Under these conditions, possible recipients of personal data include, among others, public bodies and institutions where a legal or official obligation applies (e.g. criminal prosecution authorities).

6. Transfer of data abroad or to an international organisation

Personal data are transmitted to units outside of Switzerland to the following extent:

• Insofar as required for the execution of orders (e.g. user queries).
• Insofar as prescribed by law.
• Insofar as you have granted us your consent.

7. Storage of personal data

Personal data is processed and stored for as long and insofar as required for the performance of our contractual and statutory obligations.

Personal data no longer required for the performance of our contractual or statutory obligations are deleted regularly, unless the - limited - further processing of personal data is required for a contractual or statutory purpose.

In the context of this information about the storage of personal data, please note that our business relationships are usually structured as a continuing obligation and have a long duration.

8. Data security

Axelra has instigated suitable technical and organisational measures to protect your personal data against loss, misuse, unauthorised access, forwarding and changes. Our security measures include, for example, firewalls, data encryption, physical and technical access restrictions and regular backups.

9. Data privacy rights of individuals

Every affected person has the right to information, the right to correction, the right to deletion, the right to restriction of processing, the right to object to processing and - to the extent applicable - the right to data portability. They also have the right to complain to a data privacy supervisory authority.

Withdrawal of any consent granted to us to process your personal data is possible anytime. Please note that such revocation will only have future effects.

10. Individual’s obligation to provide data

Regarding our business relationship, the user has to provide the personal data required for the establishment and execution of a business relationship and the performance of the related contractual duties or the data which Axelra is obliged by law to collect. Without this data Axelra is usually unable to enter into or perform a contract with any user data. We are in particular obliged to identify the user on the basis of an identity document before establishing a business relationship and to obtain and record the name, place and date of birth, nationality, address and ID data. To allow Axelra to meet this obligation, the user is required to provide Axelra with the required information and documents and inform us of any changes during the course of the business relationship without delay.

11. Notes about automatic decision making and profiling

Axelra generally does not use completely automated decision-making processes with legal effect to establish or execute the business relationship.

Axelra partially applies automated processing to personal data in order to evaluate certain personal aspects (profiling). Such processing is deployed as follows, for example:

• Data processing with a view to legal and regulatory requirements to combat money laundering, terrorism financing and criminal acts that threaten assets. Data evaluations (in payment transactions, among others) are also carried out. These measures also aim to protect the user.
• Evaluation tools are used to provide targeted information about our products. These allow needs-based communication and advertising, including market research and public opinion polling.

12. Information about the use of cookies

Axelra's website use cookies or advertiser IDs. Cookies are text files that are filed and stored on a computer system via an internet browser.

The affected person can prevent cookies from being placed by our website or app at any time by changing the settings on their internet browser, thus permanently preventing the placing of cookies. Furthermore, cookies that have already been placed can be deleted at any time via an internet browser or other software programs.

More information can be found in the Cookie Policy, which can be called up on our website axelra.com

13. Amendments to Data Privacy Statement

Axelra can amend or update this Data Privacy Statement from time to time by sending a revised version to its users or making it accessible on axelra.com.