PRIVACY POLICY

Last Updated: October 23, 2023

This privacy policy has been designed to help you understand what information we collect, why we collect it, and to explain how you can update, manage, export, and delete your information.

Data Protection

1. General

EDWULSTRAD RMIC SA places great importance on the protection of your data. We only collect personal data that is absolutely necessary for the fulfilment of our tasks (data economy). The recorded data is managed diligently and protected against any form of misuse. Article 13 of the Federal Constitution, as well as data protection law, guarantee everyone the respect of privacy and protection against the abusive use of personal data. The website complies with these provisions.

2. Scope of Application

This privacy policy applies to EDWULSTRAD RMIC SA’s website at the domain “eduard-wulfson.com” and to personal data collected through this site. It may be modified at any time without notice. Third-party sites linked to EDWULSTRAD RMIC SA’s site are subject to their own privacy policies.

3. Processing of Personal Data

a) Retention and Deletion

On EDWULSTRAD RMIC SA’s website, only data that is essential for its proper functioning and usefulness is processed. Furthermore, your personal data is managed in accordance with retention and deletion rules, including those you choose to share, if any. This personal data is only retained for the period necessary to achieve its initial collection goal, although legal requirements or other obligations may sometimes result in extended retention periods.

b) Form Data Recording

When you complete a form (e.g., contact form), only data necessary to fulfil the intended purpose is processed. Generally, all fields are optional. A field is mandatory only if it concerns data that EDWULSTRAD RMIC SA needs to respond to your request. The data is deleted at the latest upon the expiration of the legal retention period.

c) Registration for Newsletters

When registering for a newsletter, the following data is requested: email address (mandatory); title, first name, and last name (optional). Personal data provided by you to subscribe to a newsletter is immediately deleted when you unsubscribe.

d) Recording for statistical purposes

This site uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users interact with the site.

The information generated by the cookies about your use of the site (including your IP address, which is anonymized for users in the European Union or other European Economic Area countries) will be transmitted to and stored by Google on servers in the United States. This information is used to evaluate your use of the site, compile reports on website activity for website operators, and provide other services related to website activity and internet usage.

The collection and processing of data through Google Analytics are based on your explicit consent. You can accept or decline the use of these cookies when you access the site, using our cookie management banner.

You can prevent the collection of data generated by cookies related to your use of the site (including your IP address) and the processing of this data by Google by downloading and installing the browser add-on for disabling Google Analytics, available here: https://tools.google.com/dlpage/gaoptout.

Google may transfer this information to third parties when required by law or when such third parties process the information on Google’s behalf. Google will not combine your IP address with other data held by Google.

Data collected by Google Analytics is retained for a maximum period of 14 months, in accordance with applicable regulations.

e) Cookies

EDWULSTRAD RMIC SA’s website uses cookies to enhance navigation and provide certain functions, such as language selection and security reinforcement to prevent Cross-Site Request Forgery (CSRF) attacks. These are small text files stored on your computer. Most cookies are deleted from your hard drive when you close your browser (session cookies). Others remain on

your computer and can recognize you if you return to the same site (persistent cookies). You can block the use of cookies in your browser by limiting or disabling their storage and retrieval. However, without cookies, you may not be able to use all the functions offered on the site.

f) Social Media and Other Third-Party Services

EDWULSTRAD RMIC SA’s website has various accounts and profiles on social media platforms (e.g., Instagram). These sites and services are offered and managed by third parties, each of which has its own privacy policy.

When using EDWULSTRAD RMIC SA’s site, users can transmit data to these providers. These situations are expressly subject to the data protection rules of the respective providers. Users should be aware that data may be collected and transmitted to third parties. If a user is simultaneously logged into an account of another service, the transmitted information may be directly associated with that account. EDWULSTRAD RMIC SA has no influence on the collection and use of this data. It does not know the extent of the data stored, where it is stored, how long it is stored, whether any deletion rules are observed, what evaluations and associations are made with this data, or to whom it is transmitted. Key third-party services used on EDWULSTRAD RMIC SA’s website:

– Instagram: Instagram, Inc. is owned by Facebook. Information about data processing can be found in the following document: Instagram Privacy Policy.

4. Your Rights

You have the right to request information about the processing of your personal data by EDWULSTRAD RMIC SA at any time, free of charge. Contact information can be found in the footer. The law provides for other data rights, including deletion, correction, processing restriction, and data transmission. EDWULSTRAD RMIC SA‘s website uses data and stores it in log files to function, so users do not have the right to object to this.

5. Data Security

Websites: For the website you are visiting, EDWULSTRAD RMIC SA uses encrypted data communication based on the SSL protocol. Thanks to the SSL certificate, our domain is authenticated, and exchanges between Infomaniak’s servers and you are encrypted. You can recognize encrypted pages by the key or padlock symbol in your browser’s address bar.

General Data Processing: EDWULSTRAD RMIC SA applies technical and organizational security measures to protect processed data against accidental or intentional manipulation, partial or complete loss, destruction, and unauthorized access. These measures correspond to the current state of the art.

6. Operation

The servers used to operate the site are maintained by Infomaniak, which is committed to the security of its infrastructure, including a security policy that meets the requirements of various standards, certifications, and the Swiss Federal Data Protection Act (nLPD). Information on data processing managed by Infomaniak can be found in the following document: Infomaniak Privacy Policy.

7. Contact Person

If you have any questions about data processing or believe that your rights are not being respected, please contact the Data Protection Officer, Mrs. Stéphanie Wulfson.

If necessary, please write to the address stephanie@eduard-wulfson.com.