Privacy Policy
Protecting personal data is an important concern for Matterbase AG. Please use the contact details below to get in touch whenever you have questions regarding your personal data; we will respond to all enquiries as soon as possible.
We at Matterbase AG (hereafter "we", "us" or "our"), are committed to protecting the privacy and security of the personal data that is provided to us or collected by us on our website and during our business. We store and process personal data in accordance with the Swiss Data Protection Act ("FADP") and to the extent applicable the EU General Data Protection Regulation ("GDPR").
This privacy policy explains how we may collect and use any personal data that we obtain about you when you visit our website, contact us or apply for a job with us or when we invest in your company. This privacy policy also explains your rights in relation to the personal data we process about you.
We may provide you with additional privacy notices, in particular when you use our services, where we believe that it is appropriate to do so. In that case, these additional notices supplement this privacy policy and should be read as one.
I Who is the controller of your personal data?
We are Matterbase AG with our registered office at Oberneuhofstrasse 6, 6340 Baar, Switzerland. We are the responsible Controllerfor the personal data that we collect and process about you.
II When and why do we process personal data?
We process your personal data as described in the following.
Please note that where we need to collect information required for our business or required by law and you fail to provide that information when requested, we may not be able to enter into a business relationship with you, consider you for a position you have applied for or otherwise engage with you.
1 Use of our website
When you visit our website, we collect the following information: usage data such as domain name, user settings, browser type, session ID, IP address, authentication data and visit time, as well as other meta data.
We collect this data so that we can offer website content and ensure that our website functions properly as well as to analyze the usage of our website.
In such cases, the legal basis for the processing is our legitimate interest in operating a functioning website and analyzing the use of our website pursuant to Article 6(1)(f) GDPR.
2 Contacting us
We collect your personal data when you contact us by using the contact form on our website, by email or by any other way.
The type of personal data we collect includes name, contact details (such as your address, email address and telephone numbers), business interests, and communication with us.
We use this information to answer your request, send you more information about us or contact you in connection to a potential investment.
The legal basis for processing your personal data for these purposes is our legitimate interest in conducting and developing our business and answering your requests (article 6(1)(f) GDPR) or our contractual obligations (article 6(1)(b) GDPR).
3 Investments and business relationships
In the course of our business, we collect your contact information directly from you, from publicly available sources or from third parties who wish to introduce you to us in connection with prospective investments, investors, suppliers, as well as other business contacts.
The type of personal data we collect includes name, contact details (such as your address, email address and telephone numbers), business interests, and communication with us.
If we are interested in investing in your company, we may request further information to carry out a due diligence and learn more about your company. Such information may include personal data such as names and contact details of shareholders, board of directors, management (including organizational charts), employee lists (including information on their salary), information on your customer and suppliers (including contractual agreements) and any other information you provide to use in the course of our business. All this data is used to decide whether we want to invest in your company or not.
Once we decide to invest in your business, you may provide us further information including personal data in connection with regular reporting and to track the progress of our business venture.
When you provide personal data of third parties to us (e.g., your employees, suppliers or customers), you confirm that you are legally permitted to share that data with us.
The legal basis for processing personal data for these purposes is our legitimate interest in conducting and developing our business (article 6(1)(f) GDPR) or our contractual obligations (article 6(1)(b) GDPR).
4 Business development
We may use the personal data we collect about you to maintain and develop our business relationship with you, identify products or services you may be interested in, to pursue certain business development initiatives, send you publications or invite you to events, to the extent permitted by law.
The legal basis for the use of data for our business development is our legitimate interest (art. 6(1)(f) GDPR) in making our business better and providing you products and services that are useful.
5 Recruiting
If you apply for a job or a recruiting event with us, you may need to provide personal data including special categories of personal data about yourself.
The personal data we may process during our recruitment process includes CVs (including diplomas, professional experience, educational background), evaluation tests and reports, criminal records, family situation, any disability requiring special arrangements of the workplace.
We will use this information to consider your application. With your application you expressly consent to our use of this information, to the extent necessary. We may also use this information to carry out checks to verify the information you provided (including references, background, identity, suitability, excerpts from the debt enforcements register and criminal record checks).
The legal basis for these processing activities is our legitimate interest in recruiting new employees pursuant to article 6(1)(f) GDPR and, in case the application is successful, the conclusion and performance of a contract pursuant to article 6(1)(b) GDPR.
6 Other processing activities
Further, we collect and process information about you if you offer or provide products or services to us, if we evaluate your products or services, and generally when you request information from us or provide information to us. We may also process your personal data to the extent we have a legal obligation (article 6(1)(c) GDPR) to do so or to defend, exercise or establish a legal claim which is in our legitimate interest (article 6(1)(f) GDPR).
III Do we engage in profiling or automated decisions?
Currently, we do not engage in profiling for the purposes described in this privacy policy and we do not use automated decision-making to decide about ways to handle your data. If we should decide to start using a computer program to evaluate any of your data and make automated decisions that have a legal or similar effect on you, we will inform you of this in full transparency.
IV How and why do we share your personal data?
Where necessary or useful for the provision of our services or for other purposes defined in this privacy policy, we may disclose your personal data to third parties.
1 Disclosure to third parties
1.1 Purposes of disclosure
Please note that we may disclose personal data to third parties for the following purposes:
All third parties are required to implement appropriate technical and organizational security measures to protect your personal data in accordance with applicable data protection law.
1.2 Third parties
Specifically, we share your personal data with the following third parties:
2 Transfer of personal data to third parties in foreign countries
During our business activities and for the purposes described in this privacy policy, we may share personal data with third parties located outside of Switzerland.
We only share your personal data abroad to the extent permitted and required by law. Personal data is only transferred to third parties abroad if the relevant legal requirements are met. Third parties located outside of Switzerland are required to maintain the same level of data protection as we do.
If the recipients are located outside of Switzerland, we implement appropriate safeguards to ensure that the level of protection of personal data is equivalent to that in Switzerland, unless the level of data protection in a country is adequate under applicable law.
Currently, we mainly transfer personal data to third parties located in member states of the EU/EEA or third parties located in the UK. No additional safeguards are required for such transfers as these countries provide an adequate level of data protection.
In exceptional cases, we may rely on your consent to disclose your personal data if this is necessary for the performance of a contract, for the establishment, assertion, or enforcement of legal claims or for the protection of overriding interests.
V How do we protect your personal data?
We have put in place technical and organizational security measures to hold your personal data securely in electronic and physical form, to protect it from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss.
Our premises are access controlled and our systems and electronic databases require multi-factor authentication.
Our employees and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations and to the extent required by law, have signed so-called data processing agreements.
Please bear in mind that the transmission of information via the internet (including via email) is not completely secure, and whilst we do our best to protect your personal data, we cannot guarantee the security of data transmitted via our website, or by email, and any such transmission is at your own risk.
VI How long do we store your personal data?
We will retain your personal data for as long as it is necessary for the purpose for which it was collected.
Therefore:
In general, we keep your personal data for 10-15 years. In addition, we may also store your personal data for a longer period (i) if you have consented to this and you have not revoked your consent, (ii) if we have a legitimate interest to do so, (iii) if this is required to fulfil legal or regulatory requirements (for example accounting regulations or tax law) or (iv) for as long as claims could be brought against us.
Personal data of applicants to whom we cannot offer a job will be deleted three months after rejection at the latest. With the consent of applicants, we may store the collected personal data for a longer period in order to offer the applicant other positions in the future.
VII What are your rights?
In connection with the processing of your personal data, you may have the following rights:
In case you have provided your consent to the collection, processing, or transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing activity at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
Please note, that we may sometimes refuse to grant or restrict some of your rights for legal reasons or based on applicable data protection law. We will inform you of the grounds for our decision to the extent permitted or required by law.
In general, you will not have to pay a fee to exercise any of your individual rights. However, we may charge a fee for access to your personal data if applicable data protection law allows us to do so, in which case we will inform you as required by law.
If you feel that we have not handled your query or concern to your satisfaction or if you feel we do not process your personal data in accordance with applicable data protection law, you can file a complaint with the competent data protection authority, which is the Swiss Federal Data Protection and Information Commissioner ("FDPIC") (http://www.edoeb.admin.ch) for Switzerland.
If you would like to exercise these rights, please contact us in writing by email or letter in accordance with section VIII of this privacy policy.
VIII Our contact information
Matterbase AG
Oberneuhofstrasse 6
6340 Baar
Switzerland
Email address
kristina@matterbase.ch
IX Updates and changes to this privacy policy
We reserve the right to update and change this privacy policy from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our privacy policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our privacy policy.
7 March 2024
We at Matterbase AG (hereafter "we", "us" or "our"), are committed to protecting the privacy and security of the personal data that is provided to us or collected by us on our website and during our business. We store and process personal data in accordance with the Swiss Data Protection Act ("FADP") and to the extent applicable the EU General Data Protection Regulation ("GDPR").
This privacy policy explains how we may collect and use any personal data that we obtain about you when you visit our website, contact us or apply for a job with us or when we invest in your company. This privacy policy also explains your rights in relation to the personal data we process about you.
We may provide you with additional privacy notices, in particular when you use our services, where we believe that it is appropriate to do so. In that case, these additional notices supplement this privacy policy and should be read as one.
I Who is the controller of your personal data?
We are Matterbase AG with our registered office at Oberneuhofstrasse 6, 6340 Baar, Switzerland. We are the responsible Controllerfor the personal data that we collect and process about you.
II When and why do we process personal data?
We process your personal data as described in the following.
Please note that where we need to collect information required for our business or required by law and you fail to provide that information when requested, we may not be able to enter into a business relationship with you, consider you for a position you have applied for or otherwise engage with you.
1 Use of our website
When you visit our website, we collect the following information: usage data such as domain name, user settings, browser type, session ID, IP address, authentication data and visit time, as well as other meta data.
We collect this data so that we can offer website content and ensure that our website functions properly as well as to analyze the usage of our website.
In such cases, the legal basis for the processing is our legitimate interest in operating a functioning website and analyzing the use of our website pursuant to Article 6(1)(f) GDPR.
2 Contacting us
We collect your personal data when you contact us by using the contact form on our website, by email or by any other way.
The type of personal data we collect includes name, contact details (such as your address, email address and telephone numbers), business interests, and communication with us.
We use this information to answer your request, send you more information about us or contact you in connection to a potential investment.
The legal basis for processing your personal data for these purposes is our legitimate interest in conducting and developing our business and answering your requests (article 6(1)(f) GDPR) or our contractual obligations (article 6(1)(b) GDPR).
3 Investments and business relationships
In the course of our business, we collect your contact information directly from you, from publicly available sources or from third parties who wish to introduce you to us in connection with prospective investments, investors, suppliers, as well as other business contacts.
The type of personal data we collect includes name, contact details (such as your address, email address and telephone numbers), business interests, and communication with us.
If we are interested in investing in your company, we may request further information to carry out a due diligence and learn more about your company. Such information may include personal data such as names and contact details of shareholders, board of directors, management (including organizational charts), employee lists (including information on their salary), information on your customer and suppliers (including contractual agreements) and any other information you provide to use in the course of our business. All this data is used to decide whether we want to invest in your company or not.
Once we decide to invest in your business, you may provide us further information including personal data in connection with regular reporting and to track the progress of our business venture.
When you provide personal data of third parties to us (e.g., your employees, suppliers or customers), you confirm that you are legally permitted to share that data with us.
The legal basis for processing personal data for these purposes is our legitimate interest in conducting and developing our business (article 6(1)(f) GDPR) or our contractual obligations (article 6(1)(b) GDPR).
4 Business development
We may use the personal data we collect about you to maintain and develop our business relationship with you, identify products or services you may be interested in, to pursue certain business development initiatives, send you publications or invite you to events, to the extent permitted by law.
The legal basis for the use of data for our business development is our legitimate interest (art. 6(1)(f) GDPR) in making our business better and providing you products and services that are useful.
5 Recruiting
If you apply for a job or a recruiting event with us, you may need to provide personal data including special categories of personal data about yourself.
The personal data we may process during our recruitment process includes CVs (including diplomas, professional experience, educational background), evaluation tests and reports, criminal records, family situation, any disability requiring special arrangements of the workplace.
We will use this information to consider your application. With your application you expressly consent to our use of this information, to the extent necessary. We may also use this information to carry out checks to verify the information you provided (including references, background, identity, suitability, excerpts from the debt enforcements register and criminal record checks).
The legal basis for these processing activities is our legitimate interest in recruiting new employees pursuant to article 6(1)(f) GDPR and, in case the application is successful, the conclusion and performance of a contract pursuant to article 6(1)(b) GDPR.
6 Other processing activities
Further, we collect and process information about you if you offer or provide products or services to us, if we evaluate your products or services, and generally when you request information from us or provide information to us. We may also process your personal data to the extent we have a legal obligation (article 6(1)(c) GDPR) to do so or to defend, exercise or establish a legal claim which is in our legitimate interest (article 6(1)(f) GDPR).
III Do we engage in profiling or automated decisions?
Currently, we do not engage in profiling for the purposes described in this privacy policy and we do not use automated decision-making to decide about ways to handle your data. If we should decide to start using a computer program to evaluate any of your data and make automated decisions that have a legal or similar effect on you, we will inform you of this in full transparency.
IV How and why do we share your personal data?
Where necessary or useful for the provision of our services or for other purposes defined in this privacy policy, we may disclose your personal data to third parties.
1 Disclosure to third parties
1.1 Purposes of disclosure
Please note that we may disclose personal data to third parties for the following purposes:
- To review and assess investment opportunities and carry out due diligence and regular reporting;
- For networking purposes:
- To meet our contractual obligations and if it is in our legitimate interest;
- If you have consented to us doing so (where necessary);
- If we are under a legal, regulatory, or professional obligation to do so;
- If it is necessary in connection with legal proceedings or to exercise or defend legal rights;
- If we have another legitimate interest in involving service providers, contractors and other third parties;
- If it is necessary in connection to a merger, consolidation, asset sale, or in the unlikely event of an insolvency or bankruptcy; or
- To fulfill other purposes defined in this privacy policy.
All third parties are required to implement appropriate technical and organizational security measures to protect your personal data in accordance with applicable data protection law.
1.2 Third parties
Specifically, we share your personal data with the following third parties:
- External service providers: We may share your personal data with service providers to assist us in fulfilling our contractual or legal obligations. Among others, we engage external service providers in the areas of IT support, software-as-a-service, accounting, suppliers, vendors and distributors.
- Business partners: We may share your personal data with our business partners (businesses that we have invested in or other investors) as well as banks, advisors, auditors, lawyers, insurance companies, marketing experts or pension scheme providers, possible acquirers of (a part of) our business and trusted advisors to assist us in fulfilling our contractual or legal obligations.
- Courts or public authorities: We may disclose your personal data to courts or other public authorities, e.g., tax authorities, social security authorities, compensation funds, etc., in order to comply with our legal, contractual or other obligations.
2 Transfer of personal data to third parties in foreign countries
During our business activities and for the purposes described in this privacy policy, we may share personal data with third parties located outside of Switzerland.
We only share your personal data abroad to the extent permitted and required by law. Personal data is only transferred to third parties abroad if the relevant legal requirements are met. Third parties located outside of Switzerland are required to maintain the same level of data protection as we do.
If the recipients are located outside of Switzerland, we implement appropriate safeguards to ensure that the level of protection of personal data is equivalent to that in Switzerland, unless the level of data protection in a country is adequate under applicable law.
Currently, we mainly transfer personal data to third parties located in member states of the EU/EEA or third parties located in the UK. No additional safeguards are required for such transfers as these countries provide an adequate level of data protection.
In exceptional cases, we may rely on your consent to disclose your personal data if this is necessary for the performance of a contract, for the establishment, assertion, or enforcement of legal claims or for the protection of overriding interests.
V How do we protect your personal data?
We have put in place technical and organizational security measures to hold your personal data securely in electronic and physical form, to protect it from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss.
Our premises are access controlled and our systems and electronic databases require multi-factor authentication.
Our employees and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations and to the extent required by law, have signed so-called data processing agreements.
Please bear in mind that the transmission of information via the internet (including via email) is not completely secure, and whilst we do our best to protect your personal data, we cannot guarantee the security of data transmitted via our website, or by email, and any such transmission is at your own risk.
VI How long do we store your personal data?
We will retain your personal data for as long as it is necessary for the purpose for which it was collected.
Therefore:
- Personal data that is collected for the purpose of fulfilling a contract agreed between us and you will be stored until this contract has been fulfilled.
- Personal data that is collected for the purpose of maintaining our legitimate interests, including data security, will be stored until this purpose has been fulfilled.
In general, we keep your personal data for 10-15 years. In addition, we may also store your personal data for a longer period (i) if you have consented to this and you have not revoked your consent, (ii) if we have a legitimate interest to do so, (iii) if this is required to fulfil legal or regulatory requirements (for example accounting regulations or tax law) or (iv) for as long as claims could be brought against us.
Personal data of applicants to whom we cannot offer a job will be deleted three months after rejection at the latest. With the consent of applicants, we may store the collected personal data for a longer period in order to offer the applicant other positions in the future.
VII What are your rights?
In connection with the processing of your personal data, you may have the following rights:
- The right to request information about the personal data we process about you and certain information in relation to its processing;
- The right to request rectification of your personal data;
- The right to request deletion of your personal data;
- The right to request limitation of the processing of your personal data;
- The right to receive your personal data in a standard electronic format for your own purposes or the purpose of transferring it to another company in certain cases; and
- The right to object to the processing of your personal data.
In case you have provided your consent to the collection, processing, or transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing activity at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
Please note, that we may sometimes refuse to grant or restrict some of your rights for legal reasons or based on applicable data protection law. We will inform you of the grounds for our decision to the extent permitted or required by law.
In general, you will not have to pay a fee to exercise any of your individual rights. However, we may charge a fee for access to your personal data if applicable data protection law allows us to do so, in which case we will inform you as required by law.
If you feel that we have not handled your query or concern to your satisfaction or if you feel we do not process your personal data in accordance with applicable data protection law, you can file a complaint with the competent data protection authority, which is the Swiss Federal Data Protection and Information Commissioner ("FDPIC") (http://www.edoeb.admin.ch) for Switzerland.
If you would like to exercise these rights, please contact us in writing by email or letter in accordance with section VIII of this privacy policy.
VIII Our contact information
Matterbase AG
Oberneuhofstrasse 6
6340 Baar
Switzerland
Email address
kristina@matterbase.ch
IX Updates and changes to this privacy policy
We reserve the right to update and change this privacy policy from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our privacy policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our privacy policy.
7 March 2024
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