1. What is this privacy policy about?

DCAP Ltd (hereinafter also "we", "us") obtains and processes personal data, which concerns you oralso other persons (so-called "third parties"). In this privacy policy, we describe what we do with your data when you use dcap.ch (hereinafter "website"), obtain our services or products, otherwise deal with us under a contract, communicate with us or otherwise deal with us.

If you transmit or disclose data to us about other persons, such as family members, we assume that you are authorised to do so, and that this data is correct. By submitting data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.

2. Who is responsible for processing your data?

We are responsible for the data processing described in this privacy policy. You can contact us for your data protection concerns and to exercise your rights pursuant to para. 11 of the privacy policy as follows:

DCAP Ltd
Löwenstrasse 29
8001 Zurich | Switzerland

‍
info[at]dcap.ch

3. What data do we process?

We process different categories of data about you. The main categories are as follows:

• Master and portfolio data such as name, address, date of birth, contract number and duration, documents to establish the customer's identity, information on the account, custody account, concluded transactions or on third parties such as life partners, authorised representatives and advisors who are also affected by data processing.

• Residence for tax purposes and any other documents and information relevant for tax purposes.

• Transaction or order and risk management data such as beneficiary details, mandate details where applicable, details of your assets, investment products, risk and investment profile, and fraud.

• Records of meetings, telephone calls, e-mail exchanges and other interactions between you and us, if applicable.

• Marketing data such as needs, wants and preferences.

• Technical data, such as internal and external identifiers, business numbers, IP addresses, and records/logs of access or changes.

4. For what purposes do we process your data?

We process your data for providing our services and the following purposes (in addition to those we notify you of separately):

• Communication with you

• Contract conclusion/processing with you, your employer and customers

• Operation of the infrastructure, website, app

• Marketing (e.g. mailings, with unsubscribe link/option, occasions), relationship management

• Market analyses, planning, development of products & services, R&D

• Compliance (adherence to laws, industry standards, directives, etc.)

• Legal procedures, investigations

• Safeguarding security, access control

• Risk Management

• Corporate transactions (e.g., M&A)

• Media relations, PR, publications

• Shareholder Services, Investor Relations

• Training, instruction, further education

• Fighting crime and fraud

5. On what basis do we process your data?

Data processing can depend on the products and services provided but is based on the following:

• Entering into, concluding, or performing a contract or business relationship with you or for the performance of our obligations under such contract or business relationship.

• To safeguard our legitimate interests, e.g., statistics, planning or product development, business decisions; monitoring and controlling risks, business auditing; marketing, market research, comprehensive support, advice and information on the range of services, preparation, and provision of tailor-made services - insofar as no objection has been made; safeguarding our interests and securing the claims of our company, customers and employees.

• To fulfil legal or regulatory obligations of our company or the performance of tasks in the public interest.

• Based on your consent.

6. Do we use online tracking and online advertising techniques?

‍We use various techniques on our websites/platforms, enabling us and third parties engaged by us to recognise you when you use our websites/platforms and, in some circumstances, to track you across multiple visits. We inform you about this in this section.

In essence, this is so that we can distinguish accesses by you (via your system) from accesses by other users, so that we can ensure the functionality of the website and carry out evaluations and personalisations. In doing so, we do not want to infer your identity, even if we can do so insofar as we or third parties engaged by us can identify you through a combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of the third parties).

Other techniques may also be used to make you more or less likely to be recognised (i.e., distinguished from other users), e.g. "fingerprinting". Fingerprinting combines various data points that your system communicates to each server, resulting in a technical fingerprint.

Whenever you access a server (e.g., when using a website or an app or because an image is visibly or invisibly integrated into an email), your visits can therefore be "tracked" (traced). If we integrate offers from an advertising contractor or provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in individual cases.

We use such techniques on our website and allow certain third parties to do so as well. However, depending on the purpose of these techniques, we may ask for your consent before they are used. You can program your browser to block or deceive certain cookies or alternative techniques, or to delete existing cookies. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword "data protection") or on the websites of the third parties that we list below.

A distinction is made between the following cookies (techniques with comparable functions such as finger-printing are included here):

Necessary cookies: Some cookies are necessary for the website to function as such or for certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one session (i.e. one visit to the website) if you use this function (e.g. language selected, consent given, the function for automatic login, etc.).

Performance cookies: In order to optimise our website and corresponding offers and to better adapt them to the needs of users, we may use cookies to record and analyse the use of our website, possibly even beyond the session. We may do this through the use of third-party analytics services. We have listed these below.

Marketing cookies: We and our advertising partners have an interest in targeting advertising, i.e., displaying it only to those we want to target. We have listed our advertising partners below. For this purpose, we and our advertising partners - if you consent - may also use cookies that can be used to record the content accessed or contracts concluded. This allows us and our advertising partners to display advertisements that we think you may be interested in on our website and other websites that display advertisements from us or our advertising partners.

In addition to marketing cookies, we use other techniques to control online advertising on other websites. For example, we can transmit the email addresses of our users, customers, and other persons to whom we want to display advertising to the operators of advertising platforms (e.g. social media). If these persons are registered there with the same e-mail address (which the advertising platforms determine through a comparison), the operators show the advertising placed by us to these persons in a targeted manner. In the case of known email addresses, they learn that these persons are in contact with us and which content they have accessed.

We may also integrate further third-party offers on our website, in particular from social media providers. If you have an account with the social media provider, they can assign this information to you and thus track your use of online offers. These social media providers process this data on their own responsibility.

We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set on your computer for advertising purposes):

Adobe Services: Adobe Systems Software Ireland Ltd. General information regarding data protection: Adobe Privacy Center.

AirCall Services: Aircall.io, Inc. General information regarding data protection: AirCall Legal Center, Privacy Policy, Data Processing Agreement (DPA)

Box Services: Box, Inc. General information regarding data protection: Box Privacy Policy.

Cloudflare Registrar Services: Cloudflare, Inc. General information regarding data protection: Cloudflare Trust Hub, Cloudflare Privacy Policy

Google Services: Google LLC(SA) and Google Ireland Ltd (Ireland) for users in the European Economic Area (EEA) and from Switzerland. General information regarding data protection: General information on data protection and security, data protection policy, information on data protection with Google products, and information regarding usage of data from websites and applications.

Pipedrive Services: Pipedrive UK Ltd. (UK). General information regarding data protection: Privacy Policy, Cookie Policy, Data Processing Agreement, Security Policy and Standard Contractual Clauses (SCCs).

Meta Services: Meta Platforms, Inc. and Meta Platforms Ireland Limited. General information regarding data protection: general data protection regulation, Meta privacy policy.

Microsoft Services: Microsoft Corporation and Microsoft Ireland Operations Limited. General information regarding data protection: Microsoft Trust Center, Licensing Resources and Documents.

Webflow Services: Webflow Inc. General information regarding data protection: Terms of Service, Global Privacy Policy, EU & Swiss Privacy Policy, Data Processing Addendum, Subprocessors

Zistemo Services: DAYquiri GmbH. General information regarding data protection: Privacy Policy, GDPR, Data Processing Agreement

7. Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests, we also transfer your personal data to third parties, in particular to the following categories of recipients:

• Service providers (who process your data partly on our behalf, e.g., IT providers, partly on their own responsibility, e.g., financial service providers)

• Domestic authorities and, if applicable, abroad

• Business partners such as suppliers

• Customers, marketing, and project partners

• Third parties who collect data about you via web-services

8. Does your personal data also end up abroad?

Yes, this is possible for the EEA, but exceptionally for any country in the world (conceivable especially for online services we use). If this is a country without sufficient data protection, we conclude contracts (so-called EU SCC), but may also rely on consent or transfer data abroad on a case-by-case basis because it is necessary for the processing of a contract, where it concerns data published by you or it is necessary for legal proceedings abroad.

9. How long do we process your data?

The duration of the storage of personal data is determined by legal retention obligations or the purpose of the respective data processing. As a rule, we store personal data for the duration of the business relationship or the duration of the contract and then for a further five, ten or more years (depending on the applicable legal basis).

10. How do we protect your data?

We take reasonable technical and organizational measures – appropriate to the respective risk – to maintain the confidentiality, integrity, and availability of your personal data and to protect it against the risks of loss, unauthorised disclosure, or access. However, we cannot guarantee absolute data security.

11. What rights do you have?

You have the right to information, correction, deletion, restriction, objection, and - if applicable - the right to data portability. Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority. If you wish to exercise the above rights against us, please contact us in writing, at our premises, or, unless otherwise stated or agreed, by e-mail. You will find our contact details on this page. In order for us to be able to exclude misuse, we must identify you before processing such requests.

12. Can this privacy policy be changed?

This privacy policy does not form part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.