This Privacy Policy describes how we, Commodity Capital AG, collect and process personal data. This Privacy Policy is in accordance with the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR), as applicable. The relevance and applicability of these legal frameworks are determined on a case-by-case basis.
Please note that this document may not cover all specific data processing activities by Commodity Capital AG. Other data protection statements may be applicable in certain circumstances.
Federal Act on Data Protection
The “Data Controller” as described in this Privacy Policy:
Commodity Capital AG
Industriestrasse 47
CH-6300 Zug
data-protection@commodity-capital.com
If you have any inquiries or concerns regarding the handling of your personal data, or if you wish to exercise your rights as a data subject, please reach out using the contact information provided above.
We define "Personal data" as any information relating to an identified or identifiable natural person (Data Subject). This includes but not limited to:
- Identification and contact details (e.g. name, address, email, phone number, nationality, date of birth)
- Financial and investment-related information (e.g. investment preferences)
- Website usage data (e.g. IP address, browser type, access date/time)
- Communication records (e.g. emails, meeting notes, inquiry logs)
If you provide us with personal data about third parties (e.g., family members or colleagues), you must ensure they are informed about this Privacy Policy and that you have the appropriate legal authority to share their data.
We collect personal data to fulfil our operational, contractual, and legal obligations. This data is obtained directly from clients, business partners, and individuals with whom we maintain business relationships, typically through communications, transactions, and agreements. Additionally, personal data is collected through your use of our websites, and other digital platforms we operate.
In some instances, we may obtain personal data from publicly available sources, such as land registries, commercial registers, debt registers, and other public databases. We may also acquire data from online platforms, media sources, and third parties, including affiliated entities of Commodity Capital AG, public authorities, and third-party service providers, such as custodian banks. This information is used to verify, update, or supplement our records, conduct due diligence, and ensure compliance with relevant legal and regulatory requirements.
We process personal data primarily to fulfill contracts with our clients and business partners, including delivering financial services to our clients and procuring products and services from our suppliers and subcontractors. Additionally, we use personal data to support our core business functions, such as improving and developing our products, services, websites, applications, and other digital platforms. Personal data may also be processed for communication with clients, partners, and third parties, as well as addressing requests such as job applications or media inquiries.
In accordance with applicable laws, we may also process personal data for marketing and promotional purposes, including the organization of events. However, such processing will only occur where you have not objected to the use of your data for these purposes. If you are part of our client base and receive marketing communications, you may opt out at any time, and we will promptly remove you from further mailings.
Personal data may also be processed to assert legal claims, defend against disputes, or comply with judicial or regulatory proceedings. We may further use personal data to prevent and investigate criminal offenses or other misconduct, helping us safeguard our operations and comply with relevant laws.
Moreover, personal data is critical to ensuring the security, functionality, and performance of our IT systems, websites, and other technological infrastructures. In the context of corporate transactions, such as the acquisition or sale of business units or companies, personal data may be transferred.
Where you have given explicit consent for the processing of your personal data for specific purposes—such as subscribing to newsletters or receiving targeted communications—we will process your data based on that consent. You may withdraw your consent at any time, and such withdrawal will not affect the lawfulness of any processing carried out prior to the withdrawal.
In the course of conducting our business operations and in accordance with the data processing purposes outlined, we may transfer data to third parties where such transfers are allowed and deemed necessary. These third parties may process the data on our behalf or, where applicable, for their own purposes. These recipients may include, but are not limited to, our service providers in areas such as risk management & compliance, IT services, accounting, and CRM systems, as well as relevant authorities, courts, and parties involved in legal matters.
The recipients of your data may be located both within Switzerland and internationally. Specifically, your data may be transferred to countries where Commodity Capital operates through subsidiaries, branches, or offices, and to other countries in Europe and the United States where our service providers (e.g., Microsoft) are based.
If a recipient is based in a country with inadequate data protection laws, we ensure proper safeguards are in place. This is done using the European Commission's revised Standard Contractual Clauses, available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj. However, exceptions may apply, such as when the recipient follows adequate data protection standards, or in cases involving legal proceedings, public interest, contract obligations, consent, or where the data was made publicly available by you without objection.
When you visit our website, we collect and anonymize certain user-specific and technical data, such as your IP address, web browser, operating system, and the URLs you access. This data helps us ensure system security, perform error and performance analysis, and generate internal statistics to improve the website.
When you subscribe to our services or complete a contact form, we process the necessary data to provide the requested service, which may include your email, name, address, and message content.
If you have given us consent to process your personal data for specific purposes (e.g., subscribing to a newsletter or making an inquiry), we will process it accordingly unless another legal basis applies. You can withdraw consent at any time, but this will not affect data processed before withdrawal.
When you communicate with us via email, telephone, contact forms, or other methods, we collect and retain the exchanged information, including your contact details and communication metadata. If any telephone calls or video conferences are recorded, you will be informed in advance. Recordings are managed in accordance with our internal procedures and relevant legal obligations.
Typically, communication data is retained for up to 12 months following the final interaction. However, longer retention periods may apply if required by legal, contractual, or operational needs. Written correspondence, such as emails, is generally archived for a minimum of 10 years. Recordings of conferences are retained for up to 24 months, and chat communications are preserved for a maximum of 2 years.
We use session and persistent cookies on our website to improve the user experience and to identify the browser used for functionality and analytics purposes. A cookie is a small file stored on your computer or mobile device by your web browser when you visit our site. This helps us recognize you upon your return, even if we do not know your identity. We use session cookies, which are deleted after your visit, and persistent cookies, which store user preferences and other data for a set period (e.g., two years).
You can manage cookie settings through your browser, including blocking or deleting them. However, blocking cookies may affect certain website features. By continuing to use our website, you consent to the use of cookies. You can withdraw consent at any time by adjusting your browser settings.
To design our website in line with user needs and to continuously optimize it, we may use Google Analytics or similar services. The tools, programs, and instruments we use in the context of analyzing web behavior include Google Analytics, Google Tag Manager, Google Ads, YouTube (embedded videos), LinkedIn, Facebook, Instagram, and Mailchimp. These are third-party services that may be located in any country worldwide. Specifically, Google Analytics is provided by Google Ireland Ltd. (based in Ireland), with Google LLC (based in the USA) as a sub-processor (together referred to as "Google"): https://www.google.com/.
Google Analytics uses cookies that are stored on your device, enabling an analysis of your use of our website.
The use of Google Analytics is based on your consent to the tracking of your browsing behavior on our website and its subsequent analytical evaluation, as outlined in Article 6(1)(a) of the GDPR.
The information generated by these cookies about your use of the website (such as IP address, date and time of visit, duration of visit, referring URL, pages visited, browser type/version, and operating system) is generally transferred to a Google server in the USA and stored there. Google processes this data on our behalf to evaluate the use of our website, compile reports on website activity, and provide other services related to website and internet usage. In the process, pseudonymous user profiles may be created.
We have enabled IP anonymization (IP masking) on this website. This means that Google shortens your IP address within the European Union, other states party to the European Economic Area Agreement, and Switzerland before it is transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
You can prevent the storage of cookies by adjusting your browser settings. However, please note that in this case, some features of the website may not be fully available. Additionally, you can prevent Google from collecting and processing data generated by the cookie (including your IP address) by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=de.
Alternatively, particularly for mobile devices, you can prevent the collection of your data by Google Analytics by clicking the following link: https://support.google.com/analytics/answer/181881?hl=de. This will place an opt-out cookie on your device, preventing future collection of your data when visiting this website. If you delete your cookies, you will need to click the link again.
Further information on how Google Analytics handles user data can be found here: https://support.google.com/analytics/answer/6004245?hl=de.
Please note that Google may also process your data independently, combining it with other data it collects about you from other websites you visit. This is done for its own purposes, such as controlling advertising, and is subject to its own privacy policies:
https://policies.google.com/?hl=de
https://policies.google.com/technologies/partner-sites.
Additionally, our website includes plug-ins from social media platforms such as YouTube, LinkedIn, and Instagram, which can be identified by their respective icons. By default, these plug-ins are disabled. However, if you choose to activate them by clicking on the icons, the operators of these social media platforms may collect information about your visit, such as the pages you are viewing and your source of access and may use this data for their own purposes. The responsibility for processing your personal data in this context lies with the respective platform operator and is governed by their privacy policies. We do not receive any information about you from the platform operators.
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was originally collected or as required by applicable law. Once your personal data is no longer required for these purposes, it will be securely deleted or anonymized to the greatest extent possible. Operational data, such as system logs, will be retained for shorter periods, generally not exceeding 30 days, in accordance with operational requirements and legal obligations.
We employ appropriate technical and organizational security measures designed to protect your personal data from unauthorized access, misuse, loss, or destruction. These safeguards are regularly reviewed and updated to reflect evolving technological advances and regulatory developments.
In accordance with and as far as provided by applicable law, you have the right to request confirmation of whether your personal data is being collected , processed and to obtain sufficient information to exercise your rights. These rights include, but are not limited to:
- Accessing the personal data we hold about you,
- Requesting correction or deletion of your data,
- Restricting processing or objecting to specific uses of your data,
- Requesting a copy of your data,
- Withdrawing consent at any time, where the processing is based on your consent,
- Objecting to automated decision-making, including profiling, where applicable.
Please be aware that exercising your rights may have implications for your contractual obligations and this may result in consequences such as premature contract termination or associated costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.
In general, exercising these rights requires that you are able to proof your identity (e.g., by providing a copy of an identification document if your identity cannot be otherwise verified)). In order to assert these rights, please contact us via the details provided above.
If you believe your personal data is being processed unlawfully, you can lodge a complaint with the relevant supervisory authority. In Switzerland, the Federal Data Protection and Information Commissioner is the competent authority, accessible at https://www.edoeb.admin.ch/de.
We may use automated methods to analyze certain aspects of your personal data (profiling) to provide more tailored advice and information. Profiling helps us recommend products that may be of interest to you by using tools that assess your preferences. These tools also enable us to engage with you more effectively and deliver personalized advertisements, including those related to market and public opinion research.
In the context of our business relationship, we do not typically engage in fully automated decision-making (as outlined in Article 22 of the GDPR). If such procedures are used in specific situations, we will notify you accordingly and inform you of your rights as required by applicable laws.
Commodity Capital AG retains the right to periodically revise this Privacy Policy to account for changes in legal requirements, business practices, or technological developments. The latest version will be available on our website and will replace any previous versions.