Naretra Investment AG (Switzerland) and Naretra GmbH (Germany) (collectively referred to as “we”, “us”, or “our”) are committed to protecting your personal data and ensuring your privacy when using our website,  www.naretra.com. This Privacy Policy explains how we collect, process, and protect your personal data in compliance with Swiss data protection law, including the Federal Act on Data Protection (FADP), and the General Data Protection Regulation (GDPR) applicable in the European Union, including Germany.

1. Controller of Your Personal Data

The data controllers responsible for processing your personal data on this website 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 and process the following types of personal data:

• Contact Information: Name, email address, phone number, postal address.
• 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.
• Cookies and Tracking Technologies: Cookies and similar technologies may be used to collect information about your preferences and online activities (for more information, please see our [Cookie Policy] naretra.com/cookiepolicy.
• Contractual Data: Information necessary to perform contractual obligations, such as financial details and billing information.
• Communication Data: Any data you provide through contact forms, emails, or customer service inquiries.

3. Purpose of Data Processing

We process your personal data for the following purposes:

• To Provide Our Services: We use your data to provide and manage our services, including fulfilling contracts, handling inquiries, and offering customer support.
• Website Functionality: To ensure the proper functioning of our website and enhance your user experience.
• Legal Obligations: To comply with our legal obligations under Swiss and German law, such as tax and accounting requirements.
• Marketing and Communication: With your consent, we may use your data to send you newsletters, marketing information, or personalized offers.
• Analytics and Improvement: To analyze the use of our website and services, improve user experience, and conduct market research.

4. Legal Basis for Processing

We rely on the following legal grounds to process your personal data:

• Performance of a Contract (Art. 6(1)(b) GDPR): When the processing is necessary to fulfill a contract with you, such as delivering services or products.
• Consent (Art. 6(1)(a) GDPR): Where you have given explicit consent for certain processing activities (e.g., marketing communications).
• Legitimate Interests (Art. 6(1)(f) GDPR): For activities like improving our website, ensuring security, and marketing, unless your rights override our interests.
• Legal Obligations (Art. 6(1)(c) GDPR): When processing is required to comply with legal obligations (e.g., accounting, tax compliance).

5. Sharing of Personal Data

We may share your personal data with:

• Service Providers: Third-party service providers that assist us with website hosting, IT support, analytics, payment processing, or marketing services. These providers are bound by confidentiality agreements and data protection laws.
• Authorities: When required by law, we may share your personal data with public authorities (e.g., tax authorities, courts).
• Affiliated Companies: If necessary, your data may be shared between Naretra Investment AG and Naretra GmbH for internal purposes.

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

6. International Data Transfers

If we transfer your personal data outside Switzerland or the European Economic Area (EEA), such transfers will only occur under adequate safeguards, such as:

• Adequacy Decisions: Transfers to countries deemed to have adequate data protection by the European Commission or Swiss Federal Data Protection and Information Commissioner.
• Standard Contractual Clauses: Agreements based on the European Commission’s approved standard contractual clauses to ensure adequate protection.

7. Data Retention

We retain your personal data only 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.

8. Your Rights

Under Swiss and European law, including the GDPR, you have the following rights concerning your personal data:

• Right of Access: You have the right to request access to your personal data that we hold.
• Right to Rectification: You can request the correction of inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”): You may request that your personal data be deleted, provided we have no legal obligation to retain it.
• Right to Restriction: You can ask us to limit the processing of your personal data under certain circumstances.
• Right to Data Portability: You have the right to request a copy of your personal data in a structured, machine-readable format.
• Right to Object: You can object to the processing of your data for direct marketing or based on legitimate interests.
• Right to Withdraw Consent: You can withdraw any consent you’ve provided for data processing at any time.

To exercise these rights, please contact us using the contact details provided in this policy.

9. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, or alteration. These measures include encryption, access controls, and regular security audits.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our website to collect information about your browsing behavior and preferences. Please refer to our [Cookie Policy] www.naretra.com/cookiepolicy for more details on the cookies we use, their purposes, and how to manage your cookie preferences.

11. Data Processing when contacting us

• Contacting us by e-mail

You can contact us by e-mail using the e-mail addresses published on our website.

If you use this method of contact, the data you provide (e.g. surname, first name, address), but at least the e-mail address and the information contained in the e-mail and the personal data you provide will be stored for the purpose of contacting you and processing your request. In addition, the following data is collected by our system

• IP address of the accessing computer;
• Date and time of the e-mail.

• Contacting us via the website contact form

If you use the contact form provided on our website for communication, it is necessary to provide your surname and first name as well as your e-mail address. Without this data, we will not be able to process your request sent via the contact form. Providing your address is optional and enables us to process your request by post if you wish.

The following data is also collected by our system:

• IP address of the accessing computer;
• Date and time of registration.
• Contacting us by letter

If you send us a letter or fax, the data transmitted by you (e.g. surname, first name, address) and the information contained in the letter, together with the personal data transmitted by you, will be stored for the purpose of contacting you and processing your request

The legal basis for the processing of personal data in the context of contact forms, e-mails and letter transmitted to us is Art. 6(1)(f) GDPR.

12. Online Presence in Social Media

We maintain online presences in the social networks (LinkedIn , X and Instagram) in order to inform you about our services and to communicate via the platforms if you are interested. Our social media channels can only be accessed via an external link. As soon as you access our social media profile in the respective network, the terms and conditions and data processing guidelines of the respective operators apply.

We have no influence on the collection of data and its further use by the social networks. We have no knowledge of the extent to which, where and for how long the data is stored, the extent to which the networks comply with existing deletion obligations, which analyses and links are made with the data and to whom the data is passed on. We therefore expressly draw your attention to the fact that your data (e.g. personal information, IP address) will be stored by the operators of the networks in accordance with their data usage guidelines and used for business purposes.

We process data with regard to social media presences insofar as, for example, comments or direct messages are sent to us via these. The legal basis for the processing of data with your consent is Art. 6(1)(a) GDPR.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our data processing practices or legal requirements. Please review this policy regularly to stay informed of any updates.

14. Contact Information

If you have any questions or concerns about this Privacy Policy or your personal data, 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]

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

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