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BLUE TREE INVESTOR RELATIONS

© 2015 - 2019 by Blue Tree Advisors SARL, Geneva, Switzerland ✉️

Privacy Policy

BLUE TREE ADVISORS SARL

September 18th, 2019

Blue Tree understands that the collection of Personal Data involves a great deal of trust on your part. We take this trust very seriously and make it our highest priority to ensure the security and confidentiality of the Personal Data you provide us with.

This is why we implemented privacy by design and privacy by default standards and undertake to store your Personal Data in a secured way as well as to process your Personal Data with all appropriate care and attention in accordance with the Federal Data Protection Act (RS 235.1), the Ordinance on the Federal Data Protection Act (RS 235.11) and, where applicable, the General Data Protection Regulation (“GDPR”). Data which is deemed to be personal consists of all the information relating to a person who is either identified or identifiable (“Personal Data”).

Capitalized terms not defined in this Privacy Policy have the meanings set forth in the Terms.

Please read this Privacy Policy (the “Policy”) carefully to understand our policies and practices regarding your Personal Data and how we will treat and process them.

By using and/or registering on the Website, you accept the practices described below:

1. Acceptance of the Policy

While using the Website or the Services, Blue Tree may collect and process a certain number of Personal Data that relate to you.

The Policy shall apply to any use of the Website or use of the Services, whatever the method or medium used. It details the conditions at which, we may collect, keep, use and save information that relates to you, as well as the choices that you have in relation to the collection, utilization and disclosure of your Personal Data.

By using the Website or the Services, you acknowledge that you have read and understood this Policy and agree to be bound by it and to comply with all applicable laws and regulations. You also acknowledge that you have read and understood the Terms that apply to the Website and agree to be bound by them.

Blue Tree may modify this Policy from time to time and will post the most current version on the Website. You will be notified by email and you will be asked to Consent to these modifications before they become applicable.

2. Purpose of the collection

Blue Tree uses Personal Data mainly for the purpose of improving the user experience and the Website and targeting the Services to your needs.

We and our service providers may use your information for our legitimate business interests. Our legitimate business interests are explained below, alongside examples of how your information may be used for these purposes.

The main reason why we collect Personal Data about you is:

  • to improve the Website features and the Website Content;

  • to administer your Account;

  • to identify your needs and target the Services;

  • to fulfill your specific requests through the Website;

  • to enable you to enjoy and easily navigate the Website and benefit from the Services;

  • to accomplish our business purposes, especially to comply with a legal obligation, because we have a legitimate interest and/or with your Consent;

  • for specific purposes stated below.

The Personal Data will be freely provided by you to Blue Tree or collected automatically while using the Website, in accordance with this Policy. In addition to the information contained in this Policy, the Website may provide Users with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

We may supplement information you provide with information received from third parties.

Personal Data transmitted to Blue Tree by you are hosted by Blue Tree Advisors SARL, Rue Sautter 29, 1205 Geneva, Switzerland.

3. Type of Personal Data collected

Your Consent to this Policy followed by your submission of Personal Data represent your agreement to the collection, processing and storage of Personal Data by Blue Tree as described in this Policy.

a) Registration data

When you register through the Website or in any other way interact with us (including by email), you may be asked to communicate a number of information, including without limitation, your personal contact details:

  • email address;

  • telephone number;

  • password;

We may collect the Personal Data that you provide as part of registration and personalization of your Account.

b) Data relating to Communication

When communicating with us via the Website or via emails, we will collect the following Personal Data:

  • email address;

  • Website registration credentials, such as login and password;

  • computer information, such as IP address, operating system, type of device, browser, login dates;

  • user preferences, such as areas of interest, newsletters, community choices and other information you select in the user profile when registering on the Website or indicated by your use of the Website;

  • expressed preferences, such as communications and language settings;

  • communications, such as emails and messages with Blue Tree;

  • when you use the Website on a mobile device, we automatically collect information on the type of device you use, operating system version, and the device identifier.

  • any other information you voluntarily submit; social media account ID, and information shared with us via your social media account; information collected through cookies as disclosed below

4. Who may receive your Personal Data

A) OUR BUSINESS ENTITIES AND SERVICE PROVIDERS

We may share your Personal Data with third parties for the following purposes:

Companies within the Blue Tree group of companies. We may share your Personal Data with our affiliates, which are entities under common ownership or control of Blue Tree, to provide our services in different countries and for the purposes described in this Privacy Policy.

Our suppliers, subcontractors and business partners (“service providers”): We may share Personal Data about you with our service providers who process information to provide services to us or on our behalf. We have contracts with our service providers that prohibit them from sharing the Personal Data about you that they collect or receive with anyone else or from using such information for other purposes.

B) LEGAL & ADMINISTRATIVE OBLIGATIONS

We may use and disclose your Personal Data as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

Fraud prevention: We may use and disclose the information we collect from and about our users as we believe necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, privacy, rights, or property of us, our users, or others.

Law enforcement purposes: If requested or required by government authorities such as law enforcement authorities, courts, regulators, or otherwise to comply with the law (which may include laws outside your country of residence), we may have to disclose information we have about our users. We also may use and disclose information collected about you in order to exercise or protect legal rights or defend against legal claims.

5. Use of your Personal Data

The following paragraphs describe the various purposes for which we collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose.

Please note that not all of the uses below will be relevant to every individual.

A) INTERACTION AND COMMUNICATION

We use your Personal Data in order to provide you with the Service, to interact with you, including by means of telephone, and to respond to your requests. Your Personal Data may also be used to for fraud detection purposes. By creating an Account on the Website, you agree that we may process and use your Personal Data so that we may contact you, in particular by sending email containing general information, if you do not choose to remain anonymous.

For this purpose, your Personal Data shall also be used in order to:

  • create an Account;

  • manage your Account;

  • communicate with you including by email and by telephone;

  • send you our newsletter (provided you subscribed to it);

  • provide and improve the Website and/or the Services;

  • conduct research and compile statistics on usage patterns;

  • provide anonymous aggregate reporting for internal and external partners;

  • respond to your questions and comments;

  • prevent potentially prohibited or illegal activities;

  • enforce the Terms;

  • ensure the security of the Website;

  • access to third party services if you connect your Account with such third party services;

  • comply with legal requirements;

  • as otherwise described to you at the point of collection.

B) PERSONALIZATION

With your Consent, we use your Personal Data in order to analyze your preferences and your patterns, to personalize your experience on the Website, as well as to optimize the Website. You Consent also that we may also suggest to you Content which is best suited to your interests.

We use your Personal Data for the following personalized features:

  • to analyze your preferences and consumption habits;

  • to anticipate your needs based on our analysis of your profile;

  • to improve and personalize your experience on our Website;

  • to ensure that Content from our Website is optimized for you and for your computer or device; and

  • to allow you to participate in interactive features, when you choose to do so.

If you no longer wish to have your Personal Data used by Blue Tree to provide you with a personalized experience, please contact Blue Tree Advisors SARL, Rue Sautter 29, 1205 Geneva, Switzerland.

C) CUSTOMER SERVICE

You Consent that we use your Personal Data for customer service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. technical issue, question/complaint, general question, etc.).

D) SOCIAL NETWORKS

You Consent that we use your Personal Data when you interact with third party social networking features, such as to serve you with advertisements and engage with you on social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.

Certain features (called plugins) offered by various third-party social media Website providers (for example Facebook, LinkedIn, Twitter) are incorporated into our Website. These plugins allow you to share Content available via social networks. If a plugin appears on the Website during a browsing session, an automatic link with the servers of said Website is provided. The data relating to your Website may be sent to this third-party provider. If you are identified at the same time on the network of said third party provider, the visit to our Website may then be linked to your network account (for example Facebook). Blue Tree has no influence over this type of data transfer. Please consult the information relating to data protection by your social network regarding the purpose and the extent of the collection of your data, the subsequent management and use of your Personal Data by said provider, as well as your rights and setting options in order to protect your privacy.

When you authorize a third-party social network (such as Facebook) to share information and data with us, we may receive any data which you publicly share on said social network as well as any data which forms part of your profile. This may consist of basic data relating to your Account (e.g. your name, email address, gender, birthday, the town where you reside, your profile photograph, your user identifier, your list of friends, etc.) and all other information or activity which you have authorized the third-party network to share.

We also receive data relating to your profile when you use a function of the social network which is integrated into the Website (such as Facebook Connect) or when you interact with us via a social network. In order to find out more about how we receive data regarding yourself from third party social networks or to cease sharing your data on said social networks, we invite you to read the conditions of use of the relevant social networks. You should at all time be aware of the terms of use and privacy policy that applies to the third-party social network and are of its exclusive responsibility.

E) INTERNAL RESEARCH, ANALYTIC, SECURITY

In accordance with applicable laws, we use your Personal Data for other general business purposes, such as conducting internal marketing and demographic studies. We also use your Personal Data to ensure our security.

F) LEGAL REASONS OR MERGER/ACQUISITION

In the event that Blue Tree or its assets are acquired by, or merged with, another company including through bankruptcy, your Personal Data could be shared, with your Consent, with any of our legal successors.

We may also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the terms of the Website.

6. Your privacy choices

If you want, you can ask us for the information we have about your Account and even ask us to delete it all.

A) ACCOUNT & EMAIL SETTINGS

When you share Content via our Website, it will appear on your page.

If you no longer want to receive the newsletter from Blue Tree going forward, you may opt out of receiving these by following the instructions contained in any such email. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails and/or the newsletter from us, we may still send you important administrative messages (such as updates about your Account or service changes), from which you cannot opt out.

B) SOCIAL MEDIA

You can edit or remove the permissions you have granted to Blue Tree to use information from your social media accounts by using your application privacy settings on your social media account if you have signed in on Blue Tree through Facebook connect, you are likely to have been cookied by Facebook. You can modify or change those cookies through the settings on your Facebook account. For more details on cookies, please see our Cookies Policy.

7. Storage of your Personal Data and international Transfers

By using and/or registering on the Website, you acknowledge and agree that Personal Data you submit to Blue Tree will be hosted by Blue Tree for an indefinite period of time.

Your Personal Data will be stored in the European Union.

The storage as well as the processing of your Personal Data may require that your Personal Data are ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence. Where permitted by law, by accepting the terms of this Policy, you agree to such transferring, transmission, hosting, storing and/or processing. You also agree that such activities may take place to or in countries offering a similar level of protection than your country of residence or a lower level of protection than Switzerland, provided standard contractual clauses or binding corporate rules are implemented and you are provided with sufficient information as to the country with a lower level of protection to which your Personal Data are to be transferred.

Your submission of Personal Data and your explicit Consent to such international transfer represent your agreement to such international transfers and hosting abroad as specified above in accordance with the terms of this Policy.

8. Retention of your Personal Data

In accordance with applicable laws and the principle of proportionality, we will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected or to comply with applicable legal requirements. Personal Data used to provide you with a personalized experience will be kept for a duration permitted by applicable laws.

When you delete your Account, your Personal Data will be kept for a period of 12 (twelve) months in order to comply with legal requirements.

9. Electronic Communications Protocols

In addition to the purposes specified above, you Consent that Blue Tree may collect information about your use of the Website through electronic communications protocols. Blue Tree may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), referring Website and date and time. Collecting this automatic information helps us customize your experience as a user. It allows us to monitor and analyze use of the Website and to increase the Website's functionality and user-friendliness.

You Consent that Blue Tree may re-associate the information provided by the technologies described above with your Personal Data.

10. System Logs and Maintenance

For operation and maintenance purposes, you Consent that Blue Tree and any third party services may collect files that record interaction with the Website (system logs) or use for this purpose other Personal Data (such as IP Address).

11. Cookies and similar technologies

A Cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain websites. The Cookie uniquely identifies your browser to the server. Cookies allow Blue Tree to store information on the server (for example language preferences, technical information, click or path information, etc.) to help make the Web experience better for you and to conduct Website analysis and Website performance review. Most Web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of the Website may not work properly if you refuse cookies.

We use clear gifs in our email marketing communications which is used to track the emails that are opened by the recipients. This information allows us to have accurate reports and improve the effectiveness of our marketing and make our services and Website better for you.

12. Google Analytics

The Website (to the exclusion of cloud services available on the Website) uses Google Analytics, an Internet Website analysis service supplied by Google Inc. (“Google”). Google Analytics uses cookies which are text files placed on your computer to help to analyse the use made of the Website by its users. The data generated by the cookies concerning your use of the Website (including your IP address) will be forwarded to, and stored by, Google on servers located outside of Switzerland. Google will use this information to evaluate your use of the Website, compile reports on Website activity for its publisher and provide other services relating to the activity of the Website and the use of the internet. Google may release these data to third parties if there is a legal obligation to do so or when the third parties process these data for the account of Google including, in particular, the publisher of this Website. Google will not cross-reference your IP address with any other data held by Google.

You may deactivate the use of cookies by selecting appropriate parameters on your web browser. However, deactivation of this kind might prevent the use of certain functions of this Website. By using this Website, you specifically Consent to the processing of your Personal Data by Google under the conditions and for the purposes described above.

13. Security of your Personal Data

The security of your Personal Data is very important to us. Blue Tree processes your Personal Data in a proper manner and shall take appropriate technical and organizational measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your Personal Data.

The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Blue Tree, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of the Website (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by Blue Tree. The updated list of these parties may be requested from the Data Controller at any time.

You shall be solely responsible to keep your password and other information relating to your Account confidential and not allow any third party to access and use your Account.

In the event that your Personal Data is unduly accessed, or is reasonably believed to have been unduly accessed, by an unauthorized person and applicable law requires notification, Blue Tree shall without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the breach to the competent supervisory authority, unless said breach is unlikely to result in a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, the Company shall communicate this breach to you without undue delay.

YOU HOWEVER ACKNOWLEDGE THAT THE USE OF THE INTERNET IS NOT SAFE AND THAT THERE ARE CERTAIN INHERENT RISKS TO YOUR PERSONAL DATA. BLUE TREE SHALL MAKE REASONABLE EFFORTS TO PROTECT YOUR PERSONAL DATA BUT IT CANNOT GUARANTEE OR WARRANT THAT PERSONAL DATA YOU PROVIDE TO BLUE TREE IS SAFE AND PROTECTED FROM UNAUTHORIZED THIRD PARTY ACCESS AND THEFT AND, THEREFORE, WAIVES ALL LIABILITY IN THIS RESPECT. IN NO EVENT, SHALL BLUE TREE BE HELD LIABLE FOR CIRCUMVENTION OF ANY PRIVACY SETTINGS, VIRUSES OR SECURITY MEASURES CONTAINED ON THE WEBSITE.

14. Access to your Personal Data and information rights

You have the right to request access to or information about the Personal Data related to you which are processed by Blue Tree.

Where provided by law, you, your successors, representatives and/or proxies may (i) request deletion, correction or revision of your Personal Data; (ii) oppose the data processing; (iii) limit the use and disclosure of your Personal Data; and (iv) revoke consent to any of our data processing activities, if we are relying on your Consent and do not have another legal basis to continue processing your data.

These rights can be exercised by writing either to: Blue Tree Advisors SARL, Rue Sautter 29, 1205 Geneva, Switzerland, or by sending us an email at the following address contact@bluetreeir.com attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.

The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such Personal Data multiple times in the last twelve months). In such case, we may charge you a reasonable request fee according to applicable laws.

We may refuse, restrict or defer the provision of Personal Data where we have the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.

Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request. This may be the case even though no Personal Data about your user Account remains in our active users’ databases. Please note that Personal Data posted on third party services, such as social networks, are not located on our servers and will, therefore, not be deleted from the internet by Blue Tree.

15. Portability of your Personal Data

You also have the right to receive your Personal Data, which you have provided Blue Tree with, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Blue Tree.

This right can be exercised by writing to us at: Blue Tree Advisors SARL, Rue Sautter 29, 1205 Geneva, Switzerland, attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.

The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such Personal Data multiple times in the last twelve months). In such case, we may charge you a reasonable request fee according to applicable laws.

We may refuse, restrict or defer the provision of Personal Data where we have the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.

16. Privacy by design and by default

Blue Tree will, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of the GDPR and protect your rights.

Blue Tree will implement appropriate technical and organizational measures for ensuring that, by default, only Personal Data which are necessary for each specific purpose of the processing are processed. This obligation applies to the amount of your Personal Data we collect, the extent of their processing, the period of storage and their accessibility. These measures will ensure that by default your Personal Data are not made accessible without your intervention to an indefinite number of third parties.

17. Joint Data controllers

The data controller of the file is Blue Tree Advisors SARL, Rue Sautter 29, 1205 Geneva, Switzerland.

18. Links

If any part of the Website contains links to third party’s Websites or pages, those third party’s Websites or pages do not operate under this Policy. If you choose to visit third party Websites or pages, you will be directed to these third party's Websites or pages. We do not exercise control over third party Websites and therefore recommend you to examine the privacy statements posted on these other Websites or pages to understand their procedures for collecting, using, and disclosing Personal Data. We reject any liability relating to the privacy policy in force on said third party’s Website, the collection and use of your Personal Data by the latter and relating to the contents of said Websites (whether the links are hypertext links or deep-links).

19. Third party disclosure

Your Personal Data may be accessed and stored as necessary for the uses stated above in accordance with this Policy. While Blue Tree may share your Personal Data with agents and contractors in order to perform the functions listed above, including hosting services and Website management, we require that they treat your Personal Data, and limit their use, in accordance with the standards specified in this Policy.

When you use the Website, you submit information to Blue Tree that we store in order to offer you personalized features.

In any case where cross-border transfer is done, we ensure that an adequate protection is guaranteed for Personal Data to be transferred outside of Switzerland and the EEA. In some specific cases when this level of protection is not guaranteed, we will obtain your prior Consent or establish with the recipient of Personal Data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. You may request access to a copy of these safeguards by contacting us.

Unless otherwise stated, the third parties who receive data from Blue Tree are prohibited to use this Personal Data beyond what is necessary to provide the service to you, directly or by participating to our activities.

For compliance, please contact: contact@bluetreeir.com

20. Compliance with Laws and Law Enforcement

Blue Tree may share your Personal Data to relevant third parties, in particular if we are requested to do so to comply with a court order or law enforcement authorities request, or if we find it necessary, as determined in our sole discretion, to investigate, prevent or take action regarding illegal activities, to defend our interest, in case of violations of the Terms of Services or as otherwise required or permitted by law.

21. Business Transfers

Blue Tree may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy or insolvency event. Your Consent to this Policy followed by your submission of Personal Data represent your explicit agreement to that transfer.

22. Jurisdiction and Applicable Law

This Policy and all matters arising out of or relating to it shall be governed by the substantive laws of Switzerland, without regards to principle of conflicts of laws thereof.

Any controversy, claim or dispute between a user and Blue Tree arising out of or relating to this Policy shall be subject to the exclusive jurisdiction to the ordinary courts of the seat of Blue Tree without prejudice to an appeal to the Swiss Federal Court.

23. Contacting us and Complaints

We hope to be able to answer any questions or concerns you may have about your Personal Data. Should you have any questions about this Policy, please contact us at: contact@bluetreeir.com or Blue Tree Advisors SARL, Rue Sautter 29, 1205 Geneva, Switzerland.

You have the right to file a complaint if you feel your Personal Data has been mishandled or if we failed to meet your expectations. You are encouraged to contact us about any complaints or concerns but you are entitled to complain directly to the relevant supervisory authority.

Latest date of issue: September 18th, 2019