Naretra Investment AG (Switzerland) and Naretra GmbH (Germany) (collectively referred to as “we”, “us”, or “our”) are dedicated to protecting your personal data and ensuring that it is processed in compliance with applicable data protection laws, including the Federal Act on Data Protection (FADP) in Switzerland and the General Data Protection Regulation (GDPR) in the European Union, including Germany. This Data Protection Policy provides an overview of how we collect, use, protect, and share your personal data when you visit our [website],  www.naretra.com or interact with us.

1. Data Controllers

The data controllers responsible for processing your personal data are:

Naretra Investment AG

General-Guisan-Strasse 6, 6300 Zug, Switzerland

Phone: +41 (41) 229 40 31

Email: [email protected]

Commercial Register Number: CHE-211.674.735

VAT Number: CHE-211.674.735

2. Personal Data We Collect

We may collect the following categories of personal data:

• Identification Data: Name, email address, phone number, postal address, company details (if applicable).
• Communication Data: Any information you provide through contact forms, emails, or customer service inquiries.
• Technical Data: IP address, browser type, operating system, and other technical information automatically collected when you interact with our website.
• Usage Data: Data on your interactions with our website, such as pages visited, links clicked, and time spent on our site.
• Contractual Data: Any data required to fulfill contractual agreements, including billing information or financial data.

3. Purpose and Legal Basis of Data Processing

We collect and process personal data for the following purposes:

• Providing Services: To deliver our services, respond to your inquiries, and manage our contractual relationship with you. (Legal Basis: Performance of a Contract – Art. 6(1)(b) GDPR)
• Website Performance: To ensure the technical functionality and performance of our website. For more detailed information please review our [Privacy Policy] , naretra.com/privacypolicy.
• Marketing and Communication: To send you marketing materials, newsletters, or promotional content if you have provided your consent. (Legal Basis: Consent – Art. 6(1)(a) GDPR)
• Compliance with Legal Obligations: To comply with Swiss and German legal requirements, such as tax or regulatory obligations. (Legal Basis: Compliance with Legal Obligations – Art. 6(1)(c) GDPR)
• Analytics and Improvements: To analyze website traffic and improve the user experience. (Legal Basis: Legitimate Interests – Art. 6(1)(f) GDPR) For more detailed information please review our [Privacy Policy] , naretra.com/privacypolicy.

4. Sharing of Personal Data

We may share your personal data with:

• Service Providers: Third-party providers that help us operate our website and deliver our services, such as IT support, hosting services, or payment processors. These providers are bound by data protection agreements.
• Affiliated Companies: Personal data may be shared between Naretra Investment AG and Naretra GmbH for internal administrative purposes.
• Authorities: When required by law, we may disclose your personal data to public authorities, regulators, or courts.

We do not sell or rent your personal data to third parties.

5. International Data Transfers

If we transfer your personal data outside of Switzerland or the European Economic Area (EEA), we will ensure that adequate safeguards are in place, such as:

• Adequacy Decisions: Transfers to countries recognized by the European Commission or Swiss authorities as providing an adequate level of data protection.
• Standard Contractual Clauses: Data transfer agreements that incorporate the European Commission’s standard contractual clauses for cross-border data transfers.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. When your data is no longer needed, it will be securely deleted or anonymized.

7. Your Rights Under Swiss and German Law

In accordance with Swiss and European data protection laws, particularly the FADP and the GDPR, you have the following rights regarding your personal data:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You can request the correction of inaccurate or incomplete personal data.
• Right to Erasure: Under certain circumstances, you have the right to request that we delete your personal data (“right to be forgotten”).
• Right to Restriction of Processing: You can request that we restrict the processing of your personal data under certain conditions.
• Right to Data Portability: You have the right to receive your personal data in a structured, machine-readable format and transmit it to another controller.
• Right to Object: You can object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: If you have provided consent for the processing of your personal data, you have the right to withdraw this consent at any time.

To exercise any of these rights, please contact us using the details provided below.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include encryption, firewalls, secure access controls, and regular monitoring of our systems.

9. Use of Cookies and Similar Technologies

We use cookies and similar technologies to collect information about your browsing activities. Cookies allow us to enhance the functionality of our website and improve your user experience. For more detailed information about how we use cookies and how you can manage your preferences, please review our [Cookie Policy], www.naretra.com/cookiepolicy.

10. Changes to This Data Protection Policy

We may update this Data Protection Policy periodically to reflect changes in our practices or legal requirements. We encourage you to review this policy regularly to stay informed about how we protect your personal data.

11. Contact Us

If you have any questions or concerns regarding this Data Protection Policy or wish to exercise your data protection rights, please contact us at:

Naretra Investment AG

General-Guisan-Strasse 6, 6300 Zug, Switzerland

Phone: +41 (41) 229 40 31

Email: [email protected]

Naretra Germany Office

Am Thyssenhaus 1 – 3, 45128 Essen, Germany

Email: [email protected]

12. Information Right to Lodge a Complaint with a Supervisory Authority

Additionally, if you believe that we are not handling your personal data in accordance with the law, you have the right to lodge a complaint with the relevant data protection supervisory authority in Switzerland or Germany in particular of your place of residence, your place of work or the place of the alleged infringement.