Privacy Policy
Last updated: June 2024
1. Data Protection

General information        
This Privacy Policy has been updated as of September 1st, 2023, due to the entrance into force of the new Federal Act on Data Protection (“FADP”). The following information details the collection and storage of personal data when you visit this website and when you interact with us. The term “personal data” comprises all data that can be used to personally identify you.

Data recording        
The data collected on this website and communicated to us via email or by other electronic and physical means is processed by Van Markl Partners AG (i.e. the “Controller”, “we” “us”, “VM”).

How do we record your data?        
We collect your data as a result of your access of the website and as a result of interactions via email, by other electronic and physical means. Our IT systems automatically record other data when you visit our website. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?        
A portion of the information is generated to guarantee the error-free provision of the website, and might be used to analyse your user patterns. Other data is generally provided to us as a contractual necessity for the lawful provision of our services, such as our client identification and classification duties, or with the assistance in the know your customer processes performed by the administrators of the funds we advise or manage.

What rights do you have as far as your information is concerned?        
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time. You also have the right to demand that your data are rectified or eradicated. Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency (for details kindly refer to the question “Right to log a complaint with the competent supervisory agency”). Under certain circumstances, you have the right to demand the restriction of the processing of your personal data.

Analysis tools and tools provided by third parties        
There is a possibility that your browsing patterns will be statistically analysed when you visit this website. Such analyses are performed primarily with cookies and with what we refer to as analysis programs. As a rule, the analyses of your browsing patterns are conducted anonymously, i.e. the browsing patterns cannot be traced back to you. You have the option to object to such analyses or you can prevent their performance by not using certain tools. For detailed information about the tools and about your options to object, please consult our Data Protection Declaration below.

Data retention        
Personal information will be retained according to our legal record keeping requirements.

2. Hosting

External Hosting

This website and the company’s file and e-mail storage systems are hosted on cloud infrastructure provided by Webflow. This hosting environment ensures the reliability and security of our website and of the file/e-mail storage systems. Personal data collected on this website and communicated to us via email or by other electronic means are stored on the servers of the host and backup systems. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contact information, names, web page access, and other data generated through the web site, and the personal data communicated to us via email or by other electronic means. The processing of personal data is legitimated because it is needed for the purpose of fulfilling the contract with our potential and existing customers (Art. 31 para. 2 lit. a FADP), because the collection and processing is necessary for compliance with legal obligations to which we are subject. Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

3. General Information and Mandatory Information

Data protection        
We take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. Whenever you use this website and when you communicate personal data to us via email or by other electronic means, a variety of personal information will be collected and stored. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.

Information about the responsible party (referred to as the “Controller” in the FADP)

The data processing Controller on this website is:

Van Markl Partners AG        
Baarerstrasse 82      
CH-6300 Zug


Revocation of your consent to the processing of data        
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. To do so, send us a formal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation and to our legal record keeping obligations.

Legal Rights (Art.32 FADP).        
You have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis on which any processing of data is based, please consult this data protection declaration. If you log an objection, we will no longer process your affected personal data, unless we are legally required to do so.

Right to log a complaint with the competent supervisory agency        
In the event of violations of the FADP, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. In Switzerland this is the Federal Data Protection and Information Commissioner (FDPIC).

Right to data portability        
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption        
We take your data security seriously and have implemented Secure Socket Layer (SSL) and/or Transport Layer Security (TLS) encryption on our website. These encryption protocols are designed to safeguard your personal information during its transmission between your browser and our servers.

You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

SSL and/or TLS encryption ensures that the data you exchange with our website remains confidential and cannot be intercepted by unauthorized parties.

Information about, rectification and eradication of data        
Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”

Right to demand processing restrictions        
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data. If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 32 FADP , your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
  • If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails        
We herewith object to the use of contact information published herein to send us promotional and information material that we have not expressly requested.

4. Recording of data on this Website

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files either stored temporarily for the duration of a session (session cookies) or permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.

Please visit Cookies page for a list of cookies used.

Server log files        
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises: the type and version of browser used, the used operating system, referrer URL, the hostname of the accessing computer, the time of the server inquiry, the IP address. This data is not merged with other data sources.

Request by e-mail, telephone or fax        
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. We assume your implicit consent when you send us personal data via electronic or other means. This data remains with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Analysis Tools

Google Analytics        
We utilize Google Analytics to analyze user behavior and improve the functionality and content of our website. Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google Analytics collects various types of data, such as IP addresses, browser details, device information, and user interactions on our website. This data is gathered using cookies and similar technologies. Google's servers, where the data is processed, may be located outside the European Economic Area (EEA). However, Google is certified under the EU-US Privacy Shield Framework, ensuring an adequate level of protection for your data when transferred to the United States. The operator of this website has no control over the data transfer. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR , insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting). This consent can be revoked at any time.

IP anonymization        
We have enabled IP anonymization in Google Analytics, which means that your IP address is truncated before being processed by Google. This helps protect your privacy.

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