PRIVACY POLICY

Previous version: July 15th, 2019

Last Revised: November 19th, 2019

PLEASE READ ALL OF THE FOLLOWING PRIVACY POLICY AND TERMS AND CONDITIONS OF SERVICE ("TOS") FOR THIS WEB SITE BEFORE USING THIS SITE.

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InvestGlass SA ("IG") respects the privacy rights of our users and is strongly committed to protecting your privacy. This Privacy Policy applies to Web sites, any newsletters subscribed to via this Web site. We are not in the business of selling information about you to advertisers or other third parties.

The GDPR includes the following rights for individuals:

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • the right not to be subject to automated decision-making including profiling.

By using this Site or the Services, you represent and warrant that you are (i) at least eighteen (18) years of age, (ii) otherwise recognized as being able to form legally binding contracts under applicable law, and (iii) are not a person barred from purchasing or receiving the Services found under the laws of Switzerland and the Canton of Geneva or other applicable jurisdiction.

Definitions :
“Client” means a customer of InvestGlass
“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“Client facing portal” means the area of the Site that can be accessed only by users who have been granted access by another user, usually a Company and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.

1. Collection and Use of Personal Information

IG or a designated service provider collects personal information that you voluntarily provide on this Web sites (including the client facing portal), on third-party websites and applications, and when subscribing to the digital edition of InvestGlass SA Newsletter, which may include your username, name, address, telephone, e-mail address, billing information, etc. For example, IG or a designated service provider collects personal information when you register on this Web site, request certain InvestGlass SA services or products. This information is used to provide you your requested service or product and to communicate with you. This information is also used to send Services notifications. We use any credit card or payment information we acquire from you to fulfil your order. Credit Card or payment information can be transmitted to Paypal and Xero for payment automation if you decide to use this payment method. You can also pay through traditional IBAN payment. Please contact us at contact@investglass.com to be informed about alternative payment methods. Consistent with the choice you make when providing personal information, InvestGlass SA may use your personal information to provide you with information, special offers, and promotions via various means including e-mail. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you.

“PII” , “Personally Identifiable Information” and “personal data” are all used in this Privacy Policy interchangeably to refer to any data, information, or combination of data and information that is provided by you to InvestGlass SA or through your use of the InvestGlass Services, and which relates to an identifiable individual.

InvestGlass collects the following information:

  • Account Information. To use the InvestGlass Services, you will need to create an account or a company will create an account for you. When an account is created we will collect certain PII that can be used to identify you, such as your name, title, job description, company name, location, email alias, email address and, in certain cases, profile photo. We will only use such PII for the purposes of providing the Services to you, your company and third party company if they opened a client facing portal account. Client facing portal does not require PII to function. Client facing portal access can be granted through a Pseudonym and InvestGlassID token. Users - as Advisors can connect another user - Investor account, if this user has agreed that the Investor contact hasn't been or isn't solicited illegally and that he has the rights to contact Investor contact and manage his assets. To enforce that process we use a token InvestGlassID. Each user has one unique InvestGlassID.
  • Support Information you give us. If you provide user feedback or contact us for user support, we will collect your name and email address as well as any other content included in the support request or feedback, in order to send you a reply or in order to improve the Services. Support information is stored on Intercom customer service solution or by email;
  • Usage data. Our servers automatically record certain information about how our Services are used. Usage Data could include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the pages or features of our Services to which a User browsed and the time spent on those pages or features, frequency with which our Services are used by a User, search terms, and other statistics. We use Usage Data to administer the Services and we analyze (and could engage third parties, who are under an obligation of confidentiality, to analyze) Usage Data to improve, customize, and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences;
  • Posted Data. When you use the InvestGlass Services to record, post, send, or receive messages, files or any other information or text, audio, or video communication exchange posted to the InvestGlass Services, we will transmit and store the content of such exchange as necessary to provide the InvestGlass Services. Posted data can be found and shared into the client facing portal. Please make sure that you are legally authorized to share content through this means.

Please note that if you decide not to provide us with the PII that we request, you will not be able to access or use all of the features of InvestGlass Services and third party data or applications vendors. We are not responsible for the content or privacy and security practices and policies of third-party sites, services, data or applications vendors to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

2. Use of Cookies and Other Electronic Tools

InvestGlass services use automatically collected information and other information collected on the Service through cookies and similar technologies to: (1) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (2) provide customized advertisements, content, and information; (3) monitor and analyze the effectiveness of Service and third-party marketing activities; (4) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (5) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device.

3. Third party tracking application

Service providers: INTERCOM Expiration 30 days, Content Helps to identify the visitor and traffic

4. Disclosure of Personal Information and Other Information

IG may share your personal and other information with our designated service providers you will use with InvestGlass Services (data vendors, third party solutions). Consistent with the choice you make when providing personal information, IG may also store your personal information with a sponsor or other third party ("Third-Party Provider") that provides internet hosting, cloud services, software, billing service providers, customer support services and software, business analytics. To receive special offers, marketing news, education tutorials or promotions that may be of interest to you please make sure that you opt-in.

Such third parties will be required to maintain the confidentiality of all PII that they process on our behalf and to implement and maintain reasonable security controls to protect the confidentiality, integrity and availability of such PII.

The collection, further use, and/or disclosure of your information by Third-Party Providers or by other third parties is not the responsibility of InvestGlass SA. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies. InvestGlass will obligate any such third-party service provider to notify IG if such provider becomes unable to satisfy such data protection obligations, and IG will take reasonable steps to stop and remediate unauthorized or noncompliant processing by such third-party services provider, upon becoming aware of such processing.

5. Information disclosed.

Information that we collect from our users, including PII, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, will be disclosed or transferred to a third-party acquirer in connection with the transaction. The disclosure and transfer of any of your PII to such third-party acquirer will be done in compliance with applicable law and regulation, as the case may be, and only as necessary in order to enable IG or the relevant acquirer to continue to perform services to you or your organization.

6. Information Shared with Other Users.

For any users, InvestGlass lets you connect through the InvestGlassID token system to third party users. Information you recorded can be shared to third party user you authorized. Please do not share your InvestGlassID with unknown third party. InvestGlass SA is not responsible if you fail protecting your InvestGlassID. The content of your personal data and third party publication can be shared to fully benefit from InvestGlass Services. You can use the UNLINK function to cease seeing this content. In most cases content is providing from your advisor – user. Please contact this user if you wish to modify, delete this content.

7. Use of marketing tools.

If you are using mailing, mass mailing with Bulk button provided inside IG services, make sure that you comply with GDPR and make sure to include unsubscribe links or notices within any emails which are required by law. For example, Create a mailto: link. You can even use a mailto: link generator like this one. Your mailto: link will look something like this: mailto:your_email@company.com?subject=Unsubscribe&body=Unsubscribe

8. Right to be Forgotten.

If you have received a Right to be Forgotten request, or if you wish to received the right to be forgotten, please send us an email at contact@investglass.com. If you “delete” a lead, this action will not erase the lead information from the database. If you wish to delete permanently a user/account/lead, please contact us at contact@investglass.com. We will respond to this request within thirty (30) days. We will delete, amend or block access to any personal data that we are storing only if we also receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation.

If you or your company wish to have their data completely removed from our systems please email contact@investglass.com.

9. Opting out from Commercial Communications

If you received commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to following email contact@investglass.com. Please be aware that if you opt-out of receiving commercial email from us it may take up to ten (10) business days to process your request. Additionally, EVEN after you opt-out from receiving commercial messages from us, you will continue to reiceve administrative message from us regarding the service.

10. Data Retention

We only retain the personal data collected from a user for as long as the user’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

  • the contents of closed accounts are deleted within 3 months of the date of closure;
  • billing information is retained for a period of 10 years as of their provision to InvestGlass in accordance with the Swiss accounting and taxation laws;
  • information on legal transactions between Client and InvestGlass is retained for a period of 10 years.

11. Accuracy and Security of Personal Information

Any personal information you provide to IG is kept on secure servers in Switzerland managed by SAFE HOST SA and Exoscale SA. IG uses reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the Username and password.

12. Accessing and Updating Your Personal Information

To access, review, rectify, or delete your personal information covered by this Privacy Policy, please contact us at contact@investglass.com. We will respond to this request within thirty (30) days.

If you have questions regarding our compliance please reach out to contact@investglass.com and our Chief Cybersecurity Officer, Data Protection Office will gladly answer any questions you may have. You also have the right to lodge a complaint to protection authorities. This provision does not apply to personal data that is part of client data. Then, the management of the client data is subject to the client’s own privacy polity and any request for access, correction or deletion should be made to the client responsible for the uploading and storage of such data into the service.

While IG will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.

13. Transfer of Personal Information to Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries around the world that may have different levels of privacy protection than your country. The service is hosted in Plan les Ouates servers in Switzerland and we are using service providers that can be located in the U.S. The U.S. may not have the same data protection framepowkr as the country from which you may by using the services. By submitting your personal information, you consent to such transfers and processing.

14. Links to Third-Party Websites

IG may provide links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

15. Revisions to this Privacy Policy

Any PII that is collected via our InvestGlass Services is processed in accordance with the Privacy Policy in effect at the time such information is collected. We could revise this Privacy Policy from time to time. We’ll update the “Last Updated” date above to indicate when the Privacy Policy was last materially changed.

If we make any material changes to this Privacy Policy that adversely impact or decrease the privacy and security of PII we’ll notify you as follows. We will post them here https://portal.ubpias.com/privacy_policy.

16. How to contact us

Please contact us with any questions or comments about this polity by email at contact@investglass.com.