Privacy Policy With this Privacy Policy, we provide information about the processing of personal data in connection with our activities and operations, including our website under the domain name www.vector.limited. In particular, we inform you for what purposes, how and where we process which personal data. We also inform you about the rights of persons whose data we process. For individual or additional activities and operations, we may publish further privacy policies or other information on data protection. We are subject to Swiss law as well as any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR). By decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures an adequate level of data protection. By report of 15 January 2024, the European Commission confirmed this adequacy decision. 1. Contact details The controller within the meaning of data protection law is: Vector Limited Sagl Warakorn Luisoni c/o Wullschleger Martinenghi Manzini Servizi Fiduciari SA Via alla Campagna 2A 6900 Lugano privacy@vector.limited In individual cases, third parties may be responsible for the processing of personal data, or there may be joint controllership with third parties. Upon request, we will gladly provide data subjects with information about the respective responsibility in each case. Data protection representative in the European Economic Area (EEA) We have the following data protection representative pursuant to Article 27 GDPR: VGS Datenschutzpartner GmbH Am Kaiserkai 69 20457 Hamburg Germany info@datenschutzpartner.eu The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and in the rest of the European Economic Area (EEA) for enquiries in connection with the GDPR. 2. Definitions and legal bases 2.1 Definitions Data subject: Natural person whose personal data we process. Personal data: Any information relating to an identified or identifiable natural person. Sensitive personal data: Data on trade union, political, religious or philosophical views and activities, data concerning health, the intimate sphere, or membership of an ethnicity or race, genetic data, biometric data that uniquely identify a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures. Processing: Any handling of personal data, regardless of the means and procedures used, for example querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, erasing, revealing, arranging, organizing, storing, altering, disseminating, linking, destroying and using personal data. European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. 2.2 Legal bases We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Ordinance on Data Protection (Data Protection Ordinance, DPO). We process personal data or, as applicable, personal data within the meaning of the GDPR – insofar as and to the extent that the European General Data Protection Regulation (GDPR) applies – on the basis of at least one of the following legal bases: · Article 6(1)(b) GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for the implementation of pre-contractual measures. · Article 6(1)(f) GDPR for the processing of personal data necessary to safeguard legitimate interests – including the legitimate interests of third parties – provided that the fundamental freedoms and fundamental rights as well as the interests of the data subject do not override those interests. Such interests include, in particular, the sustainable, people-friendly, secure and reliable performance of our activities and operations, ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law. · Article 6(1)(c) GDPR for the processing of personal data necessary for compliance with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA). · Article 6(1)(e) GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest. · Article 6(1)(a) GDPR for the processing of personal data based on the data subject’s consent. · Article 6(1)(d) GDPR for the processing of personal data necessary to protect vital interests of the data subject or of another natural person. · Article 9(2) et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects. The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data, and to the processing of sensitive personal data as the processing of special categories of personal data (Article 9 GDPR). 3. Nature, scope and purpose of the processing of personal data We process the personal data that are necessary to carry out our activities and operations sustainably, in a people-friendly, secure and reliable manner. The personal data processed may, in particular, fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. Personal data may also constitute sensitive personal data. We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities and operations, insofar as such processing is permitted. We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to safeguard overriding interests. We may also request consent from data subjects even where their consent is not required. We process personal data for the duration required for the respective purpose. In particular, we anonymize or delete personal data depending on statutory retention periods and limitation periods. 4. Disclosure of personal data We may disclose personal data to third parties, have personal data processed by third parties, or process personal data jointly with third parties. Such third parties may include, for example, specialized providers whose services we use. In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit agencies and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurers and payment service providers. 5. Communication We process personal data in order to communicate with individuals as well as with authorities, organizations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by letter post or email. We may store such data in an address book or by comparable means. Third parties who transmit data to us about other persons are obliged to ensure the data protection of those data subjects independently. In particular, they must ensure that such data are accurate and may be transmitted. We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. Using such services, we may also manage and otherwise process data of data subjects beyond direct communication. 6. Applications We process personal data about applicants to the extent necessary to assess suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data arise in particular from the requested information, for example in the context of a job advertisement. We may publish job advertisements with the assistance of suitable third parties, for example in electronic and printed media or on job portals and recruitment platforms. We also process the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles. We process – insofar as and to the extent that the GDPR applies – personal data about applicants in particular pursuant to Article 9(2)(b) GDPR. 7. Data security We take appropriate technical and organisational measures to ensure a level of data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without being able to guarantee absolute data security. Access to our website and our other digital presence is provided by means of transport encryption (SSL / TLS, in particular using the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption. Our digital communication is subject – as is generally any digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities. We also cannot exclude that a data subject is specifically monitored. 8. Personal data abroad We process personal data principally in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it there or have it processed there. We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law there ensures an adequate level of data protection in accordance with a decision of the Swiss Federal Council and – insofar as and to the extent that the GDPR applies – also in accordance with a decision of the European Commission. We may transfer personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we will gladly provide data subjects with information about any safeguards or provide a copy of any safeguards. 9. Rights of data subjects 9.1 Data protection claims We grant data subjects all claims under applicable law. In particular, data subjects have the following rights: · Right of access: Data subjects may request confirmation as to whether we process personal data concerning them and, if so, which personal data. Data subjects also receive such information as is necessary to assert their data protection claims and to ensure transparency. This includes the personal data as such, and, among other things, information on the purpose of the processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data. · Rectification and restriction: Data subjects may have inaccurate personal data rectified, incomplete data completed, and the processing of their data restricted. · Right to express their point of view and to obtain human review: In the case of decisions based solely on automated processing of personal data that produce legal effects concerning them or similarly significantly affect them (automated individual decision-making), data subjects may express their point of view and request review by a human. · Erasure and objection: Data subjects may request the erasure of personal data (“right to be forgotten”) and object to the processing of their data with effect for the future. · Data portability and transfer: Data subjects may request the release of personal data or the transfer of their data to another controller. We may defer, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We may inform data subjects of any prerequisites to be met for the exercise of their data protection claims. For example, we may refuse to provide information in whole or in part by reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse erasure of personal data, in particular by reference to statutory retention obligations, in whole or in part. Exceptionally, we may provide for costs for the exercise of rights. We inform data subjects in advance of any costs. We are obliged to identify data subjects who request access or assert other rights by appropriate measures. Data subjects are obliged to cooperate. 9.2 Legal remedies Data subjects have the right to enforce their data protection claims through legal proceedings or to lodge a complaint with a data protection supervisory authority. The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC). European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some Member States in the European Economic Area (EEA), data protection supervisory authorities are structured federally, in particular in Germany. 10. Use of the website 10.1 Cookies We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data are not limited to traditional text-form cookies. Cookies may be stored in the browser temporarily as “session cookies” or for a certain period as so-called persistent cookies. “Session cookies” are automatically deleted when the browser is closed. Persistent cookies have a specific retention period. Cookies make it possible, in particular, to recognise a browser when our website is visited again and thereby, for example, to measure the reach of our website. Persistent cookies may, for example, also be used for online marketing. Cookies can be disabled, restricted or deleted at any time in the browser settings, in whole or in part. Browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least insofar as and to the extent required under applicable law – explicit consent to the use of cookies. For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA). 10.2 Logging For each access to our website and our other digital presence, we may log at least the following information, insofar as such information is determined or transmitted to our digital infrastructure by default during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, the specific subpage of our website accessed including the amount of data transferred, and the website last accessed in the same browser window (referrer). We log such information, which may also constitute personal data, in log files. This information is necessary to provide our digital presence sustainably, in a people-friendly and reliable manner. This information is also necessary to ensure data security – including by third parties or with the assistance of third parties. 10.3 Tracking pixels We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can capture at least the same information as is captured by logging in log files. 11. Notifications and communications 11.1 Performance and reach measurement Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and communications effectively and in a people-friendly manner as well as sustainably, securely and reliably, based on the needs and reading habits of the recipients. 11.2 Consent and objection As a general rule, you must consent to the use of your email address and your other contact details, unless the use is permitted on other legal grounds. Where applicable, we may use the “double opt-in” procedure to obtain a double-confirmed consent. In this case, you will receive a communication with instructions for the double confirmation. We may log obtained consents, including IP address and timestamp, for evidentiary and security reasons. As a general rule, you may object at any time to receiving notifications and communications such as newsletters. By objecting, you may also object at the same time to the statistical recording of usage for performance and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved. 12. Social Media We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA). The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the respective operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access. For our social media presence on Facebook, including so-called Page Insights, we are – insofar as and to the extent that the GDPR applies – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights in order to provide our social media presence on Facebook effectively and in a people-friendly manner. Further information on the nature, scope and purposes of the data processing, information on the rights of data subjects, as well as the contact details of Facebook and Facebook’s data protection officer can be found in Facebook’s privacy policy. We have entered into the so-called “Controller Addendum” with Facebook and thereby agreed, in particular, that Facebook is responsible for ensuring the rights of data subjects. The relevant information for the so-called Page Insights can be found on the “Information about Page Insights” page, including “Information about Page Insights Data”. 13. Third-party services We use services from specialised third parties in order to carry out our activities and operations sustainably, in a people-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content into our website. In the context of such embedding, the services used record, for technically necessary reasons, at least temporarily the IP addresses of users. For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This may include, for example, performance or usage data in order to provide the respective service. We use in particular: · Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland), partly for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: “Privacy & security practices”, privacy policy, “More information on how Google uses personal data”, “Google is committed to complying with applicable data protection laws”, “Guide to privacy in Google products”, “How we use data from sites or apps on or in which our services are used”, cookie policy, “Ads that you can control” (settings for personalised advertising). 13.1 Digital infrastructure We use services from specialised third parties in order to use the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers. We use in particular: · Hostinger: Hosting; provider: Hostinger International Ltd. (Cyprus); data protection information: privacy policy. 13.2 Scheduling We use services from specialised third parties to enable appointments to be arranged online, for example for meetings. In addition to this privacy policy, any terms that are directly visible for the services used, such as terms of use or privacy policies, also apply. 13.3 Audio and video conferences We use specialised services for audio and video conferences in order to communicate online. For example, we may hold virtual meetings or conduct online classes and webinars. The legal texts of the respective services, such as privacy policies and terms of use, apply in addition for participation in audio and video conferences. Depending on your circumstances, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or using a virtual background. 13.4 Online collaboration We use third-party services to enable online collaboration. In addition to this privacy policy, any terms that are directly visible for the services used, such as terms of use or privacy policies, also apply. 13.5 Social media features and social media content We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and by other means. 13.6 Maps We use third-party services to embed maps into our website. We use in particular: · Google Maps including the Google Maps Platform: map service; provider: Google; Google Maps-specific information: “How Google uses location information”. 13.7 Payments We use specialised service providers to process payments securely and reliably. The legal texts of the respective service providers, for example general terms and conditions (GTC) or privacy policies, also apply in addition for the processing of payments. We use in particular: · Stripe: payment processing; providers: Stripe Inc. (USA) / Stripe Capital Europe Limited (Ireland) / Stripe Payments Europe Limited (SPEL, Ireland) / Stripe Payments UK Limited (United Kingdom); data protection information: “Stripe Privacy Center”, privacy policy, cookie policy. 13.8 Identity verification We use third-party services to verify the identity of users. We need such services in particular for age verification for content and services that we may only offer, or wish to offer, to persons of full age, and for identity verification for offerings subject to “Know Your Customer” (KYC) obligations. 13.9 Advertising We use the option of displaying targeted advertising with third parties, such as social media platforms and search engines, for our activities and operations. With such advertising, we aim in particular to reach persons who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties who enable such advertising. We may also determine whether our advertising is successful, meaning in particular whether it leads to visits to our website (conversion tracking). Third parties with whom we advertise and with whom you are registered as a user may be able to associate the use of our website with your profile there. We also use the option of embedding advertising from third parties – as a rule against remuneration – into our website or otherwise displaying it on our website. Third parties whose advertising is embedded in our website and with whom you are registered as a user may be able to associate the use of our website with your profile there. We use in particular: · Google Ads: search engine advertising; provider: Google; Google Ads-specific information: advertising, among other things, based on search queries, whereby various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, privacy policy for advertising, “Manage ads directly from ads”. · Google AdSense: personalised website advertising; provider: Google; Google AdSense-specific information: privacy policy for advertising, “Manage ads directly from ads”. 14. Extensions for the website We use extensions for our website to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure. 15. Performance and reach measurement We seek to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party notices or examine how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of the performance and reach measurement, we may in particular remedy errors, strengthen popular content or make improvements. For performance and reach measurement, the IP addresses of individual users are recorded in most cases. In this case, IP addresses are, as a general rule, shortened (“IP masking”) in order to follow the principle of data minimisation through corresponding pseudonymisation. For performance and reach measurement, cookies may be used and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information on screen size or browser window size, and the – at least approximate – location. As a general rule, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are logged in may be able to associate the use of our online offering with the user account or user profile with the respective service. 16. Final notes on the Privacy Policy We may update this Privacy Policy at any time. We inform about updates in an appropriate manner, in particular by publishing the current Privacy Policy on our website.