Privacy Policy

Last updated: 24 February 2026

1. Controller

This website, zugbusiness.com, is operated by The Vanderbilt Portfolio AG, Zurich, Switzerland (“we”, “us”, “our”). We are the data controller responsible for personal data collected through this site.

For data protection enquiries, contact: [email protected]

2. Applicable Law

This Privacy Policy is governed by the Swiss Federal Act on Data Protection (FADP / Datenschutzgesetz, DSG) in its revised form in force from 1 September 2023, and, to the extent applicable to users in the European Economic Area, by the EU General Data Protection Regulation (GDPR). Where GDPR applies, the legal bases referenced below are those provided by the GDPR; equivalent Swiss law provisions govern Swiss-only processing.

3. What Data We Collect

3.1 Data Collected Automatically

When you visit zugbusiness.com, our servers and third-party analytics services may collect:

• IP address (anonymised prior to storage where technically feasible)
• Browser type and version
• Operating system
• Referring URL
• Pages visited and time on page
• Date and time of visit

This data is collected for the purpose of operating and improving the site, and for analytics. It is not used to identify individual users except where required by law.

3.2 Data You Provide

If you contact us via email ([email protected] or [email protected]), we collect and process the personal data contained in your email solely for the purpose of responding to your enquiry. We do not add email correspondents to marketing lists without explicit consent.

3.3 Cookies and Tracking Technologies

Please see our separate Cookie Policy for full details of the cookies and tracking technologies used on this site.

4. Google Analytics

We use Google Analytics (provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to understand how visitors use this site. Google Analytics sets cookies that collect anonymised information about your visit (pages viewed, time on site, general geographic region, device type). This data is processed by Google in accordance with Google’s Privacy Policy.

Legal basis (GDPR): Legitimate interests (Art. 6(1)(f) GDPR) — understanding site usage to improve content and operations. Where applicable under national law, your consent (Art. 6(1)(a) GDPR) via our cookie consent mechanism.

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on or by declining analytics cookies via our cookie banner.

Data collected via Google Analytics may be transferred to Google LLC servers in the United States. Google participates in the EU-U.S. Data Privacy Framework. Switzerland has recognised the EU adequacy decision framework for data transfers to the United States under applicable conditions.

5. Google Ad Manager

We use Google Ad Manager (provided by Google Ireland Limited) to serve advertising on this site. Google Ad Manager may set cookies and use similar tracking technologies to serve targeted or contextual advertisements. Advertising data may be shared with Google’s advertising partners as described in Google’s Privacy Policy.

Legal basis (GDPR): Consent (Art. 6(1)(a) GDPR) where required; legitimate interests for contextual advertising that does not involve cross-site tracking.

You may manage your Google advertising preferences at adssettings.google.com.

6. Legal Bases for Processing (GDPR)

7. Data Retention

• Analytics data: retained by Google in accordance with Google’s data retention settings (default: 14 months)
• Email enquiries: retained for as long as the subject matter of the enquiry may require, and in any event no longer than 3 years after last correspondence unless a legal obligation requires longer retention

8. Your Rights

Under the FADP and, where applicable, the GDPR, you have the right to:

• Access personal data we hold about you
• Rectify inaccurate personal data
• Erase personal data we hold about you (subject to legal retention requirements)
• Restrict processing of your personal data
• Object to processing based on legitimate interests
• Data portability (where processing is based on consent or contract)
• Withdraw consent at any time (without affecting the lawfulness of prior processing)

To exercise these rights, contact: [email protected]

Swiss data subjects may also lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC): www.edoeb.admin.ch.

EEA data subjects may lodge a complaint with their national data protection supervisory authority.

9. International Transfers

Data processed by Google (Analytics, Ad Manager) may be transferred outside Switzerland and the EEA. Google participates in international data transfer frameworks recognised under Swiss and EU law. We rely on Standard Contractual Clauses (SCCs) and applicable adequacy decisions for such transfers.

10. Children

This site is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, contact [email protected].

11. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page indicates the most recent revision. Material changes will be noted on the site.

12. Contact

The Vanderbilt Portfolio AG, Zurich, Switzerland [email protected]