Legal Notice & Privacy

 

Disclaimer

A) No representations

We, fronttrail Equity Partners GmbH (“fronttrail”), have diligently prepared this website and its contents. We make no representation and offer no warranty with respect to the truth, the accuracy or the up-to-date status of the information contained on this website. The provision of information on this website is not intended as, and should not be construed as, an invitation or inducement to engage in investment activities, nor does it constitute an offer, or an invitation to offer, for the issue, sale or purchase of securities or any other asset. Consequently no legal or contractual relationship between fronttrail and the user arises from the latter’s use of the website, which is at the user’s risk. Content on this website that is attributed to a specific author represents the opinion of that named author and not that of fronttrail.

B) External links

Where this website contains links to websites operated by third parties, fronttrail is not responsible for their content or for the truth, accuracy or up-to-date status thereof. Any opinion expressed on such a third party website is the opinion of the operator of that website and not of fronttrail. When setting up a link to a third-party site, fronttrail has investigated whether that site is in breach of any applicable laws, but we are unable to review, and do not systematically review, those links on an ongoing basis to determine whether any such laws have been breached subsequently. Our policy is, however, to delete any such link if we become aware of a breach of law by a website to which we have linked.

C) Copyrights

All content on this website is subject to Swiss copyright law. The prior written consent of fronttrail or, where fronttrail is not the copyright holder, of the owner of the copyright is required for any use of that content beyond what is permitted under Swiss copyright law, including without limitation copying, storing, editing, modifying or reproducing such content, in the original language or in translation, in any media, systems or data bases. Any such use without consent may be subject to criminal prosecution. A user may, however, prepare copies or download material from this website for his or her personal use, but not for commercial use.

The presentation of this website in frames by third parties is only allowed with the prior written consent of fronttrail.

D) Data protection

With fronttrail’s privacy policy outlined under Privacy Statement below, we inform you about the processing of your personal data on our website www.fronttrail.com (the “website”) and about your privacy rights.

Your personal data will be processed under the rules of the data protection law of the European Union (hereinafter “EU”), in particular the General Data Protection Regulation (hereinafter „GDPR“) and further applicable regulations.

You should be aware that the transfer of data on the internet (e.g. communication by email) may be subject to deficiencies and failures in terms of data security, and it is impossible to rule out completely that third parties may get access to such data.

Any use of our contact details as referred to in the following privacy statement and in our contact section for the purpose of commercial promotion and/or advertising is prohibited, unless fronttrail grants written approval or there is already an ongoing business relationship. fronttrail and all persons referred to on this website herewith forbid any commercial use and/or dissemination of their data.

Privacy Statement

1) Name and contact details of the person in charge of data processing

This privacy statement applies to data processed by:

fronttrail Equity Partners GmbH
Samstagernstrasse 55
8832 Wollerau
SWITZERLAND

Email requests@fronttrail.com

The data protection officer can be reached under the above address.

2) Subject matter of data protection

The subject matter of data protection is personal data. This means any information relating to an identified or identifiable individual or natural person (‘data subject’). This includes, among others, any such person’s name, address, email or phone number.

More detailed information on the personal data processed by us can be found in s. 3 below of this privacy statement.

3) Collection and storage of personal data as well as the nature and purpose of their processing

a) Visiting our website

When calling our website, the browser used on your end device will automatically send information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected and stored until it is automatically deleted, without any action required on your part:

  • internet protocol address of the requesting computer
  • date and time of the access
  • name and uniform resource locator (URL) of the file retrieved
  • website from which the access takes place (referrer URL)
  • website that is called via our website
  • browser used and, if applicable, the operating system of your computer and the name of your access provider

We process this for the following purposes:

  • ensuring a smooth establishment of the connection to the website,
  • ensuring comfortable use of our website,
  • evaluation of system safety and stability, and
  • other administrative purposes.

The legal basis for data processing is Art. 6, para. 1, lit. f) of the General Data Protection Regulation (GDPR). Our legitimate interest entitles us to collect data for the above-listed purposes. Under no circumstances do we use collected data to draw conclusions about you.

We also use analytics services when visitors use our website. More information about this is provided in s. 5 and 6 below of this privacy statement.

b) Signing up to our newsletter

If you have expressly provided consent in accordance with Art. 6, para. 1, lit. a) GDPR, we will use your email address to send you our newsletter on a regular basis. To sign up to the newsletter, you will need to enter your email address and first and last names. We record your first and last names in order to send you personalized messages and other communications.

You can unsubscribe at any time by clicking the link at the end of the newsletter. Alternatively, you can contact us at requests@fronttrail.com to unsubscribe at any time. The only costs resulting from this are the transfer costs according to the basic rates of your telecommunications provider.

The personal data required for sending out the newsletter will be erased as soon as they are no longer required for achieving the purpose of their collection and as far as no other legal authorization basis applies for further processing. Your email address will only therefore be stored for sending out the newsletter until you revoke your consent.

c) Email contact

If there are any questions, we offer the option to contact us via the provided email address. In such a case, your personal data transmitted in the email will be stored.

Data processing activities for the purpose of contacting s according to Art. 6, para. 1, lit. f) GDPR. If the aim of the contact is the conclusion of a contract, Art. 6, para. 1, lit. b) GDPR shall be an additional legal basis for processing.

The personal data collected by us will be erased after completion of the request submitted by you.

d) Job applications

We accept applications via email. Your details will only be processed and used for the candidate selection process for fronttrail and/or our portfolio companies. By sending your application, you consent to being contacted in writing and/or by phone as part of the application process.

Please note that your details are not stored anonymously, i.e. staff responsible for the HR selection process will have access to them.

Data is processed for the purpose of making contact in line with Art. 6, para. 1, lit. a) GDPR, subject to your freely given consent.

You can revoke future consent at any time via email, fax or in writing.

e) Investment opportunities

You can send us information about investment opportunities via email. The data received will only be processed and used to assess the investment opportunity.

Please note that your details are not stored anonymously, i.e. staff responsible for the evaluation process will have access to them.

Data are processed in accordance with Art. 6, para. 1, lit. a) GDPR, subject to your freely given consent.

You can revoke future consent at any time via email, fax or in writing. We point out, however, that we are subject to statutory data retention requirements with regard to this data. Therefore, even after a transaction has been terminated, further processing of your data must take place.

4) Passing on data

We shall only pass on your personal data to third parties (recipients) if we are entitled to do so under the provisions of data protection law. Below we inform you about the circumstances in which this may be the case: We can pass on your personal data to third parties (recipients), if:

  • you have explicitly given consent to this for one or more specific purposes (Art. 6, para. 1, lit. a) GDPR);
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (Art. 6, para. 1, lit. b) GDPR);
  • processing is necessary for compliance with a legal obligation to which the we are subject (Art. 6, para. 1, lit. c) GDPR);
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (Art. 6, para. 1, lit. f) GDPR).

Furthermore, we work together with service providers, so-called processors, to whom we transfer your personal data and who process your data for us on our behalf and in accordance with our instructions in compliance with Art. 28 GDPR. These service providers have been carefully selected and commissioned by us, are bound by our instructions and are regularly inspected. Specifically, please find below a list of our service providers:

5) Cookies

We use cookies on our website. These are small files that your browser will create automatically and that are stored on your end device (laptop, tablet, Smartphone or similar) when you visit our website. Cookies do not cause any damage to your end device; they contain no viruses, Trojans or other malicious software (malware).

The cookie is used to store information that results from the respective context of the specifically used end device. However, this does not mean that we gain direct knowledge of your identity this way.

Use of cookies serves to make the use of our offering more agreeable for you. We use session cookies in order to recognize that you have visited individual pages of our website before. They will be deleted automatically after you leave our website.

Furthermore, we also use temporary cookies to optimize user friendliness, which are stored on your end device for a certain specified period. When you visit our website again in order to use our services, it will be automatically recognized that you have visited us before and which input and settings you have made so that you will not have to enter them again.

On the other hand, we use cookies in order to statistically record use of our website and to evaluate it for the purpose of optimizing our offer to you (see s. 6 below of this privacy statement). These cookies enable us to recognize that you have visited us before if you visit our website again. These cookies are deleted automatically after 365 days in each case.

The data processed by cookies are required for the purpose of maintaining our legitimate interests and those of third parties according to Art. 6, para. 1, lit. f) GDPR.

Most browsers accept cookies automatically. You may, however, configure your browser so that no cookies will be stored on your computer or that you will always be informed before a new cookie is set up. Complete deactivation of cookies may, however, render you unable to use all functions of our website.

6) Analysis tools

The tracking measures listed below and used by us are performed in accordance with Art. 6, para. 1, lit. f) GDPR. With the tracking measures used, we want to ensure demand-oriented design and continual optimization of our website. On the other hand, we use tracking measures in order to statistically record use of our website and to evaluate it for the purpose of optimizing our offer to you. These interests are to be viewed as justified within the meaning of the above rule.

The respective purposes of the data processing activities and data categories can be taken from the corresponding tracking tool in this section.

a) Google Analytics

For the purpose of demand-oriented design and continuous optimization of our websites, we use Google Analytics, a web analysis service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter: “Google”). In this context, pseudonymized user profiles are compiled and cookies are used (see s. 5 above of this privacy statement). The information generated by the cookie regarding your use of this website, such as

  • browser type/version,
  • operating system used,
  • referrer URL (the website visited before),
  • host name of the accessing computer (internet protocol address),
  • time of the server query,

is transferred to servers of Google in the USA and stored there within the context of the agreement on contract data processing that we have entered into with Google. The information is used in order to evaluate use of the website in order to compile reports on the website activities and in order to provide further services connected to use of the website and use of the internet for the purpose of market research and demand-oriented design of these internet websites. This information may also be transferred to third parties if this is required by law or as far as third parties process these personal data based on a contract. In no case will your internet protocol address be combined with any other data of Google. The internet protocol addresses are rendered anonymous so that they cannot be assigned (IP masking). Sessions and campaigns shall be ended after the end of a specific period of time. By default, sessions shall be ended after 30 minutes without any activity, and campaigns after six months. The time limit for campaigns may be up to two years.

You may prevent installation of the cookies by making the corresponding settings in your browser software; however, note that you may be unable to fully use all functions of the website in such a case.

You may furthermore prevent recording of the data generated by the cookie and referring to your use of the website (incl. your internet protocol address) and processing of these personal data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, in particular for browsers on mobile end devices, you can prevent recording by Google Analytics by clicking this link . An opt-out cookie is set that will prevent the future recording of your personal data when visiting this website. The opt-out cookie will only be valid for this browser and only for our website; it is stored on your device. If you delete the cookies in this browser, you need to set the opt-out cookie again.

For more information on data protection related to Google Analytics, see the Google Analytics Help (https://support.google.com/analytics/answer/6004245?hl=en).

b) Google AdWords conversion tracking

To compile statistics on the use of our website and evaluate it for optimization purposes, we also use Google conversion tracking. Google AdWords places a cookie (see s. 5 above of this privacy statement) on your computer, provided that you have arrived at our website via a Google ad.

These cookies are valid for 30 days and do not contain personally identifiable information. If the user visits specific pages on the website of the AdWords client and the cookie has not yet expired, Google and the client can recognize that the user has clicked on the ad and been forwarded to our site.

Every AdWords client has a different cookie. Cookies can therefore not be tracked via AdWords clients’ websites. Information collected via conversion cookies serve to create conversion statistics for AdWords clients who have set up conversion tracking. AdWords clients are provided with the total number of users who have clicked on their ad and been forwarded to a webpage with a conversion tracking tag. However, they do not receive any information which can identify you personally.

If you do not wish to be included in the tracking process, you can decline to set the required cookie via the setting in your browser that deactivates the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting up your browser to block cookies from Google AdWords (instructions to turn cookies on or off see here). Google’s data protection notice regarding conversion tracking is available here (https://services.google.com/sitestats/en.html).

c) MailChimp

We use MailChimp as our marketing automation platform. We send our newsletter via MailChimp, a service provided by The Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

The email addresses of our newsletter subscribers and other data outlined here are stored on MailChimp servers in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf, and can also use these data to optimize and improve its own services, e.g. to optimize sending from a technical perspective or how the newsletter is displayed, or for commercial purposes, such as determining which countries the subscribers are in. However, MailChimp does not use the details of our newsletter subscribers to contact them itself or pass the data on to third parties.

We trust the reliability, IT and data security of MailChimp. MailChimp is certified under the EU-US privacy shield framework and therefore adheres to EU data protection guidelines. We have also concluded a data processing agreement with MailChimp, under which MailChimp pledges to protect our users’ data, to process data on our behalf in accordance with data protection regulations and explicitly not to pass on details to third parties. MailChimp’s privacy policy is available here.

7) Plug-ins

We currently don’t use GDPR-relevant plug-ins on our website.

8) Rights of the data subject

You have the right:

  • to demand information in accordance with Art. 15 GDPR regarding the processing of your personal data by us. In particular, you may request information on the purposes of the processing, the categories of personal data, the categories of recipient to whom your data has been or as disclosed, the envisaged storage period, the existence of the right to rectification, erasure, restriction of processing or objection, the right to lodge a complaint, the source of your data to the extent that it was not collected at our site, and the existence of automated decision-making, including profiling and any meaningful information on its details;
  • in accordance with Art. 16 GDPR, obtain the rectification of any inaccurate personal data stored by us or completion of such data without undue delay;
  • in accordance with Art. 17 GDPR, obtain the erasure of your personal data stored by us, to the extent that processing is not required for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims;
  • in accordance with Art. 18 GDPR, obtain the restriction of processing of your personal data, to the extent that the accuracy of the data is contested by you, processing is unlawful, but you oppose erasure and we no longer need the personal data, but you still require them for the establishment, exercise or defense of legal claims or you have objected to processing pursuant to Art. 21 GDPR;
  • in accordance with Art. 20 GDPR, demand to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to demand transmission to another controller;
  • in accordance with Art. 7, para. 3 GDPR, to withdraw your consent once given to us towards us at any time. This has the consequence that we may no longer continue the data processing activities that were based on this consent in future and
  • in accordance with Art. 77 GDPR, lodge a complaint with a supervisory authority. Usually, you may contact the supervisory authority at your habitual residence or place of work or our registered office for this. A list of the EU data protection authorities is available by clicking this link: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

9) Right to object

As far as your personal data is processed based on legitimate interests in accordance with Art. 6, para. 1, lit. f) GDPR, you have the right to object to processing of your personal data in accordance with Art. 21 GDPR, to the extent that there are grounds relating to your particular situation or the objection is targeted against direct marketing. In the latter case, you have a general right to object that will be implemented by us without any indication of a particular situation.

If you want to exercise your withdrawal right or right to object, simply send us an email to requests@fronttrail.com.

10) Further information

In accordance with Art. 13, para. 2, lit. e) GDPR we would like to inform you about the following:

The provision of personal data is neither a statutory nor contractual requirement, nor a requirement necessary to enter into a contract. You are not obliged to provide the personal data. There are no consequences resulting from failure to provide such data.

In accordance with Art. 13, para. 2, lit. f) GDPR we would like to inform you about the following:

We do not process your personal data for the purpose of automated decision-making.

11) Data security

Within the website visit, we use the common secure socket layer (SSL) in conjunction with the respective highest encryption level your browser supports. This usually is 256-bit encryption. If your browser does not support 256-bit encryption, we will use 128-bit v3 technology instead. Whether an individual website of our internet offer is transmitted encrypted or not is evident by the closed display of the key or lock symbol in the lower status bar of your browser.

Apart from this, we use appropriate technical and organizational security measures in order to protect your data from accidental or willful manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures will be improved continually according to the technological developments.

12) Topicality and changes of this privacy statement

This privacy statement is currently valid as of February 2019.

Further development of our website and offers through it or changed statutory or authority specifications may require changes to this privacy statement. You may call and print the respective current privacy statement at any time on our website.