Privacy policy of the Wealth Investment Network - WENET AG

1. general privacy policy

Wealth Investment Network - WENET AG (hereinafter also referred to as «we», «us») is a property broker based in Zug. As part of our business activities, we obtain and process personal data about our clients, associated persons, interested parties, authorities, real estate agents, professional and other associations, visitors to our website, participants in events and other bodies or their respective contact persons and employees (hereinafter also referred to as «you»). The above is not an exhaustive list. If you provide us with data about other persons (e.g. family members, representatives, interested parties or other associated persons), we assume that you are authorised to do so, that this data is correct and that you have ensured that these persons have been informed of this disclosure, insofar as a legal obligation to provide information applies (e.g. by bringing this data protection declaration to their attention in advance). This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation («GDPR») and the Swiss Data Protection Act («DPA»). However, whether and to what extent these laws are applicable depends on the individual case.

2. responsibility for the processing of data

The data controller is responsible for the processing described in this privacy policy: For requests or information in connection with the protection of your personal data, you can contact the above-mentioned office in writing or by e-mail.

3. processing of personal data

We primarily process the «personal data» (hereinafter referred to as «personal data») that we receive from our customers and other business partners as part of our business relationship with them and other persons involved and that we collect from their users when operating our website «www.we-net.ch», apps and other applications. Personal data is all information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular storing, disclosing, obtaining, deleting, saving, modifying, destroying and using. Insofar as this is permitted in individual cases, we also obtain certain data from publicly accessible sources (e.g. land registers, commercial registers, the Internet, debt collection registers) or receive such data from other companies, authorities or other third parties. In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official or legal proceedings, information in connection with your professional functions and activities, creditworthiness information, information about you that other persons (such as consultants, legal representatives, etc.) provide to us so that we can fulfil contracts with you.This includes, for example, references, your address, powers of attorney, information from banks, insurance companies, information about you from the media and the Internet (if this is appropriate in the specific case), data in connection with the use of the website (e.g. IP address). We process personal data in accordance with Swiss data protection law. In addition, we process personal data - insofar and insofar as the EU GDPR is applicable - in accordance with the following legal bases in connection with Art. 6 para. 1 GDPR: a) Processing of personal data with the consent of the data subject; b) Processing of personal data for the fulfilment of a contract with the data subject and for the implementation of corresponding pre-contractual measures; c) Processing of personal data for the fulfilment of a legal obligation to which we are subject under any applicable EU law or under any applicable law of a country in which the GDPR is applicable in whole or in part; d) processing of personal data to protect the vital interests of the data subject or another natural person; f) processing of personal data to protect the legitimate interests of us or third parties, except where such interests are overridden by the fundamental freedoms and rights and interests of the data subject. Legitimate interests are, in particular, our commercial interest in being able to provide our website, information security, the enforcement of our own legal claims and compliance with Swiss law.

4. purposes of data processing and legal bases

We primarily use the personal data we collect to conclude and process our contracts with our customers and business partners, in particular in the context of providing financial and property services such as management, brokerage, valuation and advice, construction of buildings and trading in goods of all kinds (see also the purpose of the company) for our customers and the purchase of products and services from our suppliers and subcontractors, as well as to fulfil our legal obligations in Switzerland and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this function. In addition, we also process personal data of you and other persons, where permitted and where we deem it appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• Offering and further developing our products, services and websites, apps and other platforms on which we are present;
• Communication with third parties and processing their enquiries (e.g. applications, media enquiries);
• Examination and optimisation of procedures for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for the purpose of customer acquisition;
• Advertising and marketing (including the organisation of events), unless you have objected to the use of your data (if we send you advertising from us as an existing customer, you can object to this at any time);
• Market and opinion research, media monitoring;
• Assertion of legal claims and defence in connection with legal disputes and official proceedings;
• Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analyses to combat fraud);
• Guarantees of our operations, in particular IT, our websites, apps and other platforms;
• Video surveillance to safeguard domiciliary rights and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to or entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone recordings);
• Purchase and sale of business divisions, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and compliance with legal and regulatory obligations;
• With regard to the conclusion of a contract, in particular a contract with you or your client or employer, we may in particular obtain and otherwise process your name, contact details, authorisations, declarations of consent, information about third parties (e.g. contact persons, authorities), contract contents, date of conclusion, creditworthiness data and all other data which you provide to us or which we collect from public sources or from third parties (e.g. commercial register, media or from the Internet).

If you have given us your consent to process your personal data for specific purposes (e.g. when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, provided we have no other legal basis and require one. Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place. In connection with the aforementioned purposes, we transfer your personal data in particular to the categories of recipients listed below. If necessary, we will obtain your consent for this: Service providers: We work with service providers in Switzerland and abroad who (i) process data on our behalf (e.g. IT providers), (ii) on our joint responsibility or (iii) on their own responsibility, which they have received from us or collected for us. Other persons: This refers to other cases where the involvement of third parties arises from the above purposes. This concerns, for example, delivery addressees or payment recipients specified by you, third parties in the context of agency relationships (e.g. your lawyer or your bank) or persons involved in official or court proceedings. As part of our corporate development, we may sell or acquire businesses, parts of businesses, assets or companies or enter into partnerships, which may also result in the disclosure of data (including from you, e.g. as a customer or supplier or as their representative) to the persons involved in these transactions. In the course of communication with our competitors, industry organisations, associations and other bodies, data relating to you may also be exchanged. All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.). We process and store personal data mainly in Switzerland and the European Economic Area (EEA), but potentially in any country in the world, depending on the case - for example via subcontractors of our service providers or in proceedings before foreign contractual partners or authorities. Your personal data may also be transferred to any country in the world as part of our activities for customers. Please note that we generally process your data for as long as required by our processing purposes, the statutory retention periods and our legitimate interests, in particular for documentation and evidence purposes, or for as long as storage is technically necessary (e.g. in the case of backups or document management systems). If there are no legal or contractual obligations or technical reasons to the contrary, we generally delete or anonymise your data after the storage or processing period has expired as part of our normal processes and in accordance with our retention policy. If you do not provide certain personal data, this may mean that it is not possible to provide the associated services or conclude a contract. We always indicate where personal data requested by us is mandatory.

5. cookies / tracking and other technologies in connection with the use of our website

By using our website, you consent to the collection, processing and use of data in accordance with the following description. This website can generally be visited without registration. Data such as pages called up or the name of the file called up, date and time are stored on the server for statistical purposes without this data being directly related to your person. Personal data, in particular name, address or e-mail address, is collected on a voluntary basis as far as possible. We reserve the right to use new or different technologies, services, applications, etc. than those listed below and to adapt the data protection declaration accordingly.

Privacy policy for cookies

Our website uses cookies. These are small text files that make it possible to store specific user-related information on the user's end device while they are using the website. Cookies make it possible, in particular, to determine the frequency of use and number of users of the pages, to analyse the behaviour of page use, but also to make our offer more customer-friendly. Cookies remain stored at the end of a browser session and can be called up again when you visit the site again. If you do not wish this to happen, you should set your Internet browser to refuse to accept cookies.

Privacy policy for SSL encryption

This website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as the enquiries you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. If SSL encryption is activated, the data you send to us cannot be read by third parties.

Third party services

This website may use Google Maps for embedding maps, Google Invisible reCAPTCHA for protection against bots and spam and YouTube for embedding videos. These services of the American Google LLC use cookies, among other things, and as a result, data is transferred to Google in the USA, whereby we assume that no personal tracking takes place in this context solely through the use of our website. Google has undertaken to guarantee appropriate data protection in accordance with the US-European and US-Swiss Privacy Shield. Further information can be found in Google's privacy policy or in the respective privacy policy of the third party.

Google Analytics or other statistics services

We sometimes use Google Analytics or similar services on our websites. This is a third-party service that may be located in any other country (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as a processor (both «Google», www.google.com), with which we can measure and evaluate the use of the website (not personalised). Permanent cookies set by the service provider are also used for this purpose. If you have registered with the service provider yourself, the service provider also recognises you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

Privacy policy for social media plug-ins

We use so-called plug-ins from social networks such as Twitter, YouTube, LinkedIn, Instagram etc. on our website. This is visible to you in each case (typically via corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and can use this information for their own purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

Privacy policy for contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions.

Newsletters and marketing emails

In some of our newsletters and other marketing emails, we also include visible and invisible image elements, where permitted, which enable us to determine whether and when you have opened the email so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email programme. By using our website and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques.

6. data transfer and data transmission abroad

As part of our business activities and for the purposes set out in Section 4, we also disclose data to third parties to the extent permitted and deemed appropriate, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following bodies:

• Service providers of ours (within the Wealth Investment Network - WENET AG as well as externally, e.g. banks, insurance companies), including contract processors (e.g. IT providers);
• Dealers, suppliers, subcontractors and other business partners;
• Customers;
• domestic and foreign authorities, official bodies or courts;
• Media;
• The public, including visitors to websites and social media;
• Competitors, industry organisations, associations, organisations and other bodies;
• Acquirers or parties interested in acquiring business units, companies or other parts of Wealth Investment Network - WENET AG;
• other parties in potential or actual legal proceedings;
• Other companies of the Wealth Investment Network - WENET AG;

(all together the «recipients»). Some of these recipients are in Germany, but they can be anywhere in the world. In particular, you must expect your data to be transferred to all countries in which Wealth Investment Network - WENET AG is represented by branches or other offices, as well as to other countries where the service providers we use are located (e.g. Microsoft). If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection (we use the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption clause. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the fulfilment of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

7. duration of storage of personal data

We process and store your personal data for as long as is necessary for the fulfilment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as far as possible. Shorter retention periods of twelve months or less generally apply to operational data (e.g. system logs).

8. data security

We take appropriate technical and organisational security precautions to protect your personal data from unauthorised access and misuse, such as training, issuing instructions to employees, IT and network security solutions, access controls and restrictions, checks, etc.

9. obligation to provide personal data

As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfilment of the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or fulfil a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

10 Rights of the data subject

You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing, as well as to the disclosure of certain personal data for the purpose of transfer to another organisation (so-called data portability) within the scope of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so or need it to assert claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 4. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature cancellation of the contract or costs. We will inform you in advance if this is not already contractually regulated. The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 2. Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. changes

We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update. Status January 2026