PRIVACY POLICY

We thank you very much for your interest in our services. This privacy policy is to inform you about how we process personal data (i.e. information relating to an identified or identifiable natural person; hereinafter “personal data” or “data”) at Elementarum AG.

Contact for data protection issues: mail@elementarum.com

We process personal data in particular in the following categories of processing. A detailed description of the personal data processed and further information can be found in Section 5 of this data protection declaration:

• If you are our customer and we provide or have provided services for you

• If we have not received your personal data directly from you when providing the service, but from our customer.

• When you visit our website.

• When you participate in one of our events.

• When we communicate with you or provide you with information about our services and advertise our services.

• When you have some other contractual relationship with us, e.g. as a supplier, service provider or consultant.

• If you apply for a job with us.

• If we are required to do so for legal or regulatory reasons.

• If we perform our due diligence or pursue other legitimate interests, e.g. to avoid conflicts of interest, to prevent money laundering or other risks, to ensure data accuracy, to check creditworthiness, to ensure security or to enforce our rights.

What personal data we process depends on your relationship with us and the purpose for which we process it (see section 3). In addition to your contact details, we also process other information about you or about people with whom you have a relationship. Under certain circumstances, this information may also be sensitive personal data.

We collect the following categories of personal data, depending on the purpose for which we process it:

– Contact information (e.g. last name, first name, address, telephone number, e-mail, incl. marginal data as well as any recordings and image and video recordings)

– Customer information (e.g. date of birth, nationality, marital status, occupation, title, job title, passport/ID number, AHV number)

– Risk management data (e.g. credit information, commercial register data, WorldCheck information

– Financial information (e.g. bank details)

– Mandate data, depending on the order (e.g. tax information, business data (articles of association, minutes, projects, contracts), employee data (e.g. salary, social security), accounting data, beneficial owners, ownership structure

– Website data (e.g. IP address, device information (UDI), browser information, website usage (analysis and use of plugins, etc.)

– Job application data (e.g. CV, references)

– Marketing information (e.g. newsletter registration)

More detailed information can be found in the description of the respective categories of processing (see Section 5).

We generally collect this data directly from you. It may also be the case that we receive information from our customers about persons who do not have a direct relationship with us but rather with the customer (e.g. data about the customer's employees). We collect certain data from public or official sources, such as the commercial or debt collection register (see Section 5.2). We may also collect data from third parties, such as credit reference agencies or providers of information for risk assessment, and share data with them.

So-called cookies, pixels, tags and other tracking technologies may be used on the website of W Ltd. (hereinafter referred to as “cookies”). Cookies are small files that are stored on your computer or mobile device when you visit our website or receive the newsletter. We use cookies to enable various functions and to provide you with an optimal browsing experience, for example by saving your settings.

5.1 Web analysis, newsletter analysis and tracking technologies

In order to obtain information about the use of our website and to improve our internet services, we may use the following web analysis tools and re-targeting technologies: Google Analytics, Facebook Pixel, Squarespace Analytics.

These tools are provided by third-party providers. As a rule, the information collected for this purpose about the use of a website is transmitted to the third-party provider's server using cookies or similar technologies. Depending on the third-party provider, these servers may be located abroad.

The transmission of the data usually takes place by shortening the IP addresses, which prevents the identification of individual end devices. A transfer of this information by third-party providers only takes place due to legal regulations or in the context of order data processing.

5.2 Google Analytics

We use Google Analytics, the web analytics service provided by Google LLC, Mountain View, California, USA, on our websites. Google Limited Ireland (“Google”) is responsible for Europe. Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address, which is, however, anonymized using a method that means it can no longer be assigned to a connection) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google may associate your IP address with other data held by Google. Google has undertaken to sign and comply with the EU standard contractual clauses for data transfers to the USA. If we evaluate your visit to our website based on your consent, you can revoke your consent for the future here if you no longer wish this.

5.3 Google Maps

On our website, we use Google Maps (API) from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Google Limited Ireland is responsible for Europe, “Google”). Google Maps is a web service for displaying interactive maps that visually presents geographical information. By using this service, our location is displayed to you and it is easier for you to find us. When you access sub-pages that have an embedded Google Maps map, information about your use of our website (such as your IP address) is transmitted to and stored by Google on servers in the United States. This happens regardless of whether Google provides a user account that you are logged in to, or if there is no user account. If you are logged in to Google, your information will be directly associated with your account. If you do not want this information to be associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as user profiles and evaluates them.

Google has undertaken to sign and comply with the EU standard contractual clauses for data transfers to the United States. If you do not agree to the future transmission of your data to Google when using Google Maps, you also have the option of completely deactivating the Google Maps web service by switching off the JavaScript application in your browser. Google Maps and thus the map display on this website cannot then be used. The additional terms of use for Google Maps can be found at https://www.google.com/intl/de_US/help/terms_maps.html. Detailed information on data protection in connection with the use of Google Maps can be found at http://www.google.de/intl/de/policies/privacy/.

5.4 Social media plugins

Our website may use social media plug-ins (“plug-ins”) from third-party providers. The plug-ins can be recognized by the logo of the respective social network. We use the plug-ins to offer you the opportunity to interact with social networks and other users. We use the following plug-ins on our website: Facebook, Twitter, LinkedIn, YouTube. When you visit our website, your browser establishes a direct connection to the servers of the third-party provider. The content of the plug-in (e.g. YouTube videos) is transmitted directly to your browser by the respective third-party provider and integrated into the page.

The data transfer for displaying content (e.g. publications on Twitter) takes place regardless of whether you have an account with the third-party provider and are logged in there. If you are logged in to the third-party provider, your data collected by us will also be assigned directly to your account with the third-party provider. If you activate the plugins, the information will also be published on the social network and displayed to your contacts there. For information on the purpose and scope of the data collection and the further processing and use of the data by the third-party providers, as well as your rights and setting options for protecting your privacy, please refer to the data protection information of the third-party providers. The third-party provider stores the data collected about you as a user profile and uses this for the purposes of advertising, market research and/or the needs-based design of its website. This type of analysis is also carried out for users who are not logged in, in order to display targeted advertising and to inform other social network users about your activities on our website. If you do not want third-party providers to associate the data collected through our website with your personal profile on the respective social network, you must log out of the corresponding social network before visiting our website. You can also completely prevent the loading of plug-ins with specialized add-ons for your browser, such as “Ghostery” (https://www.ghostery.com/) or “NoScript” (http://noscript.net/).

We store personal data for as long as is necessary to achieve the purpose for which we collected it. If there are legal or regulatory obligations or overriding interests in longer storage, we will store the personal data. This period is regularly at least ten years, e.g. to fulfil archiving obligations under tax law and accounting regulations or to ensure the enforcement of claims. Web analysis data is only stored for a short period of time. After the retention period has expired, the personal data is deleted or anonymized.

You have the following rights in connection with our processing of personal data:

• Right of access to the personal data we hold about you, the purpose of the processing, the origin and the recipients or categories of recipients to whom the personal data is disclosed.

• Right to rectification if your data is incorrect or incomplete.

• Right to restrict the processing of your personal data.

• Right to request the deletion of the processed personal data.

• Right to data portability.

• Right to object to data processing or to revoke consent to the processing of personal data at any time without stating reasons.

Right to complain to a competent regulatory authority, where provided for by law.

To exercise these rights, please contact us at the address given in Section 2.

We expressly reserve the right to change this privacy policy at any time.

Last updated:

March, 2025