Privacy policy of the Wealth Investment Network - WENET AG

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 personal data that we receive in the course of our business relationships with customers, prospective customers, business partners and other involved persons, or that we collect when operating our website, our digital applications and when using our services.

Personal data is any information relating to an identified or identifiable natural person. A data subject is a person whose personal data is processed. Processing includes any handling of personal data, in particular the collection, storage, retention, use, alteration, disclosure, archiving, erasure, or destruction of personal data.

To the extent permitted in individual cases and necessary or appropriate for the respective purposes, we also obtain personal data from publicly accessible sources, e.g. from land registers, commercial registers, debt enforcement registers, media or the Internet, or receive such data from authorities, courts, business partners, consultants, legal representatives, banks, insurance companies, credit agencies or other third parties.

In addition to the personal data that you provide to us directly, we may receive the following categories of personal data about you: information from public registers, information relating to official or judicial proceedings, information about your professional functions and activities, creditworthiness and financial information, references, address and contact details, powers of attorney, information relating to contracts, and information from media and the internet, insofar as this is appropriate in the specific case.

In connection with the use of our website, we may also process technical data and usage data, in particular IP address, date and time of access, pages accessed, browser used, operating system, device information and referrer URL.

We process personal data in accordance with applicable Swiss data protection law. Where the EU General Data Protection Regulation («GDPR») is applicable, we base the processing of personal data in particular on the following legal grounds pursuant to Art. 6 para. 1 GDPR:

• the consent of the data subject;
• the performance of a contract with the data subject or the implementation of pre-contractual measures;
• fulfilling a legal obligation to which we are subject;
• the protection of vital interests of the data subject or another natural person;
• the protection of our legitimate interests or the legitimate interests of third parties, unless the interests or fundamental rights and freedoms of the data subject prevail.

Our legitimate interests include, in particular, the proper management of our business, the provision and further development of our website and services, communication with customers, prospective customers and business partners, information security, the prevention of misuse, the assertion, exercise or defense of legal claims and compliance with Swiss legal regulations.

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, particularly in the context of providing financial and real estate services such as management, brokerage, valuation and consulting, construction projects, and trading in goods of all kinds (see also our company purpose) for our customers, as well as purchasing products and services from our suppliers and subcontractors, and to comply with our legal obligations both domestically and internationally. If you work for such a customer or business partner, your personal data may also be affected in this capacity.

In addition, we also process personal data of you and other persons for the following purposes, where permitted and where we deem it appropriate, 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);
• Maintaining our operations, in particular our IT, 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 subscribe to our newsletter or undergo a background check), we will process your personal data within the scope of and based on this consent, unless we have and require other legal grounds. You can withdraw your consent at any time, but this will not affect any 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 Germany and abroad who (i) process data on our behalf (e.g., IT providers, banks, insurance companies, notaries, land registries, authorities, external consultants, other brokers, buyers/tenants/sellers/landlords, marketing, valuation, real estate portals), (ii) jointly with us, or (iii) on their own responsibility, data that they have received from us or collected for us.

Other persons: This refers to other cases where the inclusion 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 legal 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. As a matter of principle, we 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 as described below. This website can generally be visited without registration. Data such as pages viewed or the names of files accessed, as well as the date and time, are stored on the server for statistical purposes, without this data being directly linked to you personally. Personal data, in particular name, address, or email address, is collected on a voluntary basis whenever possible. We reserve the right to use new or different technologies, services, applications, etc., than those listed below and to amend this privacy policy accordingly.

Cookies

We use cookies and similar technologies on our website to store or read information on your device. Cookies are small files that are placed on your device and store certain information, such as language settings, session information, technical data, or information about your use of our website.

We use cookies and similar technologies, in particular to technically provide our website, to make it secure and user-friendly, to analyze the use of our website, and to improve our services. Depending on the technology used, this may involve processing technical data such as IP address, date and time of access, pages visited, browser used, operating system, device information, referrer URL, and usage data.

Some cookies are only required for the duration of a browser session and are deleted after the browser is closed. Other cookies can remain stored beyond the browser session and be retrieved again on a subsequent visit to our website.

Where cookies or similar technologies are technically necessary for the operation of our website, we use them based on our legitimate interest in the secure and functional operation of our website. We only use other cookies and similar technologies, in particular for analysis, marketing, or tracking purposes, to the extent permitted by applicable law and, where necessary, after obtaining your consent.

You can configure your browser to block, delete, or allow cookies only in specific cases. Furthermore, where our website provides corresponding settings, you can adjust your cookie preferences at any time or revoke your consent for the future. Blocking cookies may limit the functionality of our website.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential information, such as inquiries you send us, our website uses SSL/TLS encryption. You can usually recognize an encrypted connection by the fact that the address bar of your browser begins with "https://" and a padlock icon is displayed.

When SSL/TLS encryption is enabled, the data you transmit to us cannot be easily read by third parties according to the current state of technology.

Third party services

We may use Google services on our website, in particular Google Maps for displaying maps, Google reCAPTCHA for protection against bots and spam, and YouTube for embedding videos. The provider of these services is Google LLC, USA; for individuals in the European Economic Area and Switzerland, Google Ireland Limited, Ireland, may also be responsible.

When you access pages that integrate such services, information about your use of our website, as well as technical data, in particular IP address, device and browser information, date and time of access, and usage data, may be transmitted to and processed by Google. Cookies or similar technologies may also be used in this process.

We use Google reCAPTCHA to check whether entries on our website are made by humans or abusively by automated programs. For this purpose, Google may analyze various pieces of information, in particular technical data and user behavior on our website.

To the extent that personal data is transferred to the USA or other countries without an adequate level of data protection through the use of these services, we base the transfer on appropriate safeguards or legal exceptions. For data transfers to certified US companies, the Swiss-US Data Privacy Framework or, if the GDPR applies, the EU-US Data Privacy Framework may be relevant.

Further information on how Google processes personal data can be found in Google's privacy policy. Where necessary, we will only use such services with your consent or provide corresponding settings options.

Google Analytics or other statistics services

We may use Google Analytics or similar statistics and analysis services on our website to measure and evaluate website usage and improve our services. The provider of Google Analytics is Google Ireland Limited, Ireland. Google Ireland Limited may engage Google LLC, USA, and other Google group companies as sub-processors.

When using such services, cookies and similar technologies may be used. In particular, technical and usage data may be processed, e.g., IP address, truncated IP address, cookie or device identifiers, information about the browser and operating system used, referrer URL, pages visited, time and duration of the visit, and interactions on our website.

We only use such statistics and analytics services to the extent permitted by applicable law and, where necessary, after you have given your consent. You can withdraw your consent at any time with effect for the future or adjust your cookie settings.

Providers of such services may process personal data on their own responsibility or on our behalf. Where personal data is disclosed to countries without an adequate level of data protection, we base the disclosure on appropriate safeguards or legal exceptions. For data transfers to certified US companies, the Swiss-US Data Privacy Framework or, if the GDPR applies, the EU-US Data Privacy Framework may be relevant.

Further information on how Google processes personal data can be found in Google's privacy policy and in the information on Google Analytics.

Social Media Plug-ins

We may use plugins, buttons, or embedded content from social networks and third-party platforms on our website, such as Twitter, YouTube, LinkedIn, or Instagram. These elements are usually identifiable by corresponding icons, logos, or notices.

Where possible, we integrate these elements in such a way that no personal data is transmitted to the respective providers simply by visiting our website. Only when you activate such an element, e.g., by clicking on it, can a connection to the servers of the respective provider be established. In this case, your IP address, information about your device and browser, the date and time of access, and details of the page visited may be transmitted to the provider.

If you are registered with the respective provider, they can associate your visit to our website with your user account and process the data for their own purposes. Further processing is the responsibility of the respective provider and is governed by their privacy policy.

We generally do not receive any personal information about you from the providers, but at most aggregated or statistical data on the use of our content.

Contact form

When you send us inquiries via a contact form, we process the data you provide in the form, including your contact details, to process your request, to contact you and for any follow-up questions.

The processing takes place within the framework of our communication with you and, where applicable, for the implementation of pre-contractual measures, for the fulfillment of a contract or based on our legitimate interest in processing and documenting inquiries.

We store this data for as long as is necessary to process your request, for any follow-up questions, to document the communication, or due to legal or contractual retention obligations.

Newsletters and marketing emails

When you subscribe to our newsletter or other marketing emails, we process your contact details, in particular your email address, in order to send you the relevant communications. You can unsubscribe from the newsletter or marketing emails at any time, in particular via the unsubscribe link in the respective email or by notifying us.

In our newsletters and marketing emails, we may use tracking pixels or similar technologies, to the extent permitted by law. These are small, visible or invisible image elements that are retrieved from our servers or the servers of our service providers when the email is opened. This allows us to determine, in particular, whether and when an email was opened, which links were clicked, and how our communications are used.

We use this information to measure the use of our newsletters and marketing emails, to improve our content, and to better tailor our offers to the interests of our recipients. This may involve processing technical data such as IP address, time of access, device used, email program, and usage data.

Where consent is required for the use of such technologies, we will only use them if you have given your consent. You can revoke your consent at any time with effect for the future. You can also block the loading of external images in your email program; however, this may affect the display of our emails.

6. data transfer and data transmission abroad

We may disclose personal data to third parties within the scope of our business activities and for the purposes described in this privacy policy, insofar as this is permissible and appears necessary or appropriate for the respective purposes. This applies in particular if third parties process personal data on our behalf, if they process personal data under their own responsibility, or if disclosure is necessary to fulfill contractual, legal, or legitimate interests.

The categories of recipients include, in particular:

• 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»).

These recipients are partly located within Switzerland, but may also be located outside of Switzerland and the EEA. In particular, you must expect your data to be transferred to all countries where Wealth Investment Network – WENET AG is represented by branches or other offices, as well as to other countries where our service providers are located (e.g., IT, cloud, or communication service providers).

If a recipient is located in a country without adequate legal data protection, we contractually obligate the recipient to comply with applicable data protection regulations (for this purpose, we use the revised standard contractual clauses of the European Commission), unless the recipient is already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exception. An exception may apply, in particular, in legal proceedings abroad, but also in cases of overriding public interest, or if contract processing requires such disclosure, if you have given your consent, or if the data in question is publicly available data against which you have not objected.

7. duration of storage of personal data

We process and store your personal data for as long as it is necessary to fulfill our contractual and legal obligations or otherwise for the purposes for which it was processed, i.e., for example, for the duration of the entire business relationship (from initiation and execution to termination of a contract) and beyond, in accordance with statutory retention and documentation requirements. It is possible that personal data may be retained for the period during which claims can be asserted against our company and to the extent that we are otherwise legally obligated to do so or legitimate business interests require it (e.g., for evidentiary and documentation purposes). As soon as your personal data is no longer required for the aforementioned purposes, it will generally be deleted or anonymized to the extent possible. Shorter retention periods of twelve months or less generally apply to technical operational data (e.g., system logs).

8. data security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access, loss, misuse, alteration, disclosure or destruction.

Depending on the type and scope of data processing, these measures include in particular training and instructions for employees, access controls and restrictions, IT and network security solutions, encryption, logging, data backups and other organizational and technical controls.

We adapt our security measures appropriately, taking into account the state of the art, the type and scope of the personal data processed, and the existing risks.

9. obligation to provide personal data

As part of our business relationship, you must provide the personal data necessary for establishing, conducting, and terminating the business relationship, as well as for fulfilling the associated contractual obligations. There is generally no legal obligation to provide us with personal data.

Without this personal data, we are generally unable to conclude or execute a contract with you or with the entity or person you represent, or to provide the requested services.

Our website may also be unusable or only partially usable if certain technical data required to ensure data traffic, such as the IP address, cannot be processed.

10 Rights of the data subject

Under applicable data protection law, and to the extent provided therein, you have the right to request information about the personal data we process. You can also request the correction of inaccurate personal data, the deletion of personal data, the restriction of processing, and the release or transfer of certain personal data. Furthermore, you can object to the processing of your personal data, in particular if we process personal data for direct marketing or related profiling.

To the extent that we process personal data based on your consent, you can revoke this consent at any time with effect for the future. The revocation does not affect the lawfulness of the processing prior to the revocation.

Please note that these rights are subject to legal requirements and limitations. In particular, we may be obligated or entitled to continue processing or storing certain personal data, for example, due to legal retention obligations, overriding legitimate interests, for the establishment, exercise, or defense of legal claims, or for the protection of the rights of third parties.

Exercising your rights may, in individual cases, affect existing contracts or the provision of our services. If this is the case and not already contractually regulated, we will inform you accordingly.

To exercise your rights, you can contact us using the contact details provided in this privacy policy. To prevent misuse, we may need to verify your identity appropriately. We will only request a copy of your ID if your identity cannot be reliably established by other means.

You also have the right to enforce your rights in court or to lodge a complaint with the competent data protection authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC). Where the GDPR applies, you can also contact the competent data protection supervisory authority in the EU or EEA member state of your residence, your place of work, or the location of the alleged data protection breach.

11. changes

We may amend this privacy policy at any time. The current version published on our website applies.

If the privacy policy is part of an agreement with you or we are legally obliged to inform you about changes, we will inform you of the update in an appropriate manner, e.g. by email or by posting a notice on our website.

As of June 2026