Privacy Policy

Effective date: 24 February 2026 Publisher: The Vanderbilt Portfolio AG, Zurich, Switzerland

1. Introduction

This Privacy Policy explains how ZUG WEB3, operated by The Vanderbilt Portfolio AG (“we,” “us,” or “our”), collects, uses, and protects personal data when you visit zugweb3.com (the “Site”).

We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (FADP, revised version in force from 1 September 2023) and, where applicable, the European Union General Data Protection Regulation (GDPR).

2. Data Controller

The data controller responsible for personal data processed through this Site is:

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

3. Data We Collect

3.1 Data Collected Automatically

When you visit the Site, we and our third-party service providers may automatically collect:

• Log data: IP address (anonymised), browser type, operating system, referring URL, pages visited, time and date of visit, and time spent on pages.
• Device data: Device type, screen resolution, and browser language settings.
• Analytics data: Aggregated behavioural data collected through Google Analytics (see Section 5).
• Advertising data: Data collected through Google Ad Manager for the purpose of serving and measuring advertisements (see Section 6).

3.2 Data You Provide Voluntarily

We collect personal data you voluntarily provide, for example when you contact us by email. This may include your name, email address, and the contents of your communication.

3.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies. Please see our Cookie Policy for full details.

4. Legal Basis for Processing

We process personal data on the following legal bases:

• Legitimate interests (FADP Art. 31; GDPR Art. 6(1)(f)): Analytics, fraud prevention, and improving the Site.
• Consent (FADP Art. 31; GDPR Art. 6(1)(a)): Where you have consented to cookies or marketing communications, which you may withdraw at any time.
• Legal obligation (FADP Art. 31; GDPR Art. 6(1)(c)): Where processing is required by applicable law.

5. Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics uses cookies to help us analyse how users interact with the Site. The information generated by cookies about your use of the Site (including your IP address) is transmitted to and stored by Google on servers which may be located in the United States or other countries.

We have enabled IP anonymisation, which means Google truncates your IP address within EU/EEA member states before transmission.

Google will use this information to evaluate your use of the Site, compile reports on website activity for us, and provide other services relating to website activity and internet usage.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.

Google’s privacy policy is available at policies.google.com/privacy.

6. Google Ad Manager

We use Google Ad Manager to serve advertisements on the Site. Google Ad Manager may use cookies and similar technologies to serve ads based on your prior visits to this Site or other websites. Google’s use of advertising cookies enables it and its partners to serve ads based on your visit to this Site and/or other sites on the internet.

You may opt out of personalised advertising by visiting Google’s Ad Settings at adssettings.google.com, or by visiting the Network Advertising Initiative opt-out page at optout.networkadvertising.org.

7. Data Retention

We retain personal data only for as long as necessary for the purposes set out in this Policy or as required by law. Analytics data is retained for 14 months (Google Analytics default). Email correspondence is retained for up to 3 years.

8. Data Transfers

Your data may be transferred to and processed in countries outside Switzerland and the European Economic Area, including the United States (Google services). Such transfers are made on the basis of adequacy decisions, standard contractual clauses, or other appropriate safeguards as required by applicable law.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate data.
• Right to erasure: Request deletion of your personal data in certain circumstances.
• Right to restriction: Request restriction of processing in certain circumstances.
• Right to data portability: Receive your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise your rights, contact us at [email protected]. We will respond within the timeframe required by applicable law (generally 30 days).

Swiss residents may also lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch. EU residents may lodge a complaint with their national supervisory authority.

10. Children’s Privacy

The Site is not directed at children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately.

11. Links to Third-Party Sites

The Site may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page will reflect the date of the most recent update. Continued use of the Site after changes constitute acceptance of the updated Policy.

13. Contact

For privacy-related inquiries, contact: [email protected]

The Vanderbilt Portfolio AG, Zurich, Switzerland.