When you use the website www.climefi.com, we may collect personal data about you. The purpose of this policy is to inform you about how we process your personal data in compliance with the Swiss Federal Act on Data Protection (nFADP / revDSG, in force since 1 September 2023) and, where applicable, Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

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I. Who is the data controller?

The data controller is Carbonx AG, a company registered in the Swiss Commercial Register of the Canton of Zurich, UID CHE-309.287.513, whose registered office is located at Technoparkstrasse 1, 8005 Zurich, Switzerland.

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For any data protection matters, you may contact us at: info@climefi.com

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II. What kind of personal data do we collect?

Personal data is data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name. We may collect the following personal data:

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• Identification data (e.g. full name, email address, telephone number);
• Professional data (e.g. professional role);
• Data relating to your orders (e.g. transaction number, details of your orders and subscriptions, commercial relationship follow-up);
• Login data (e.g. logs, IP address, terminal identifiers, connection and timestamp identifiers, cookies, comments and screenshots and bug tracking forms);
• Location data (including geographic data / location of parcels);
• Economic and financial data (e.g. payment data, bank details);

We will inform you when collecting your personal data, whether some of this data is mandatory or optional. Mandatory data will be indicated with an asterisk.

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III. On what legal basis, for what purposes and for how long do we keep your personal data?

Under Swiss law (nFADP), we process your personal data on the following legal grounds: (i) performance of a contract or pre-contractual steps; (ii) compliance with a legal obligation; (iii) our overriding legitimate interests; or (iv) your consent where required. Where EU individuals are concerned, the corresponding GDPR legal bases apply equivalently.

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Purposes: To provide you with our services available on our Website, To perform operations related to contracts, orders, deliveries, invoices, and customer relationship management, To create a database of customers and prospects, To send newsletters, requests and direct marketing mailings, To answer to your information request and other inquiries

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Legal basis: Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract, Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract, Performance of a contract to which you are party, Our legitimate interest in developing and promoting our business, Our legitimate interest in winning customer loyalty and informing our customers of our latest news, Our legitimate interest in responding to your inquiries, Our legitimate interest in responding to your requests and keeping records of them.

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Data retention period: To provide you with our services available on our Website, When you have created your account: personal data are retained for the duration of your account. Personal data are retained for the duration of our business relationship. In addition, the data relating to your transactions are archived for probationary purposes for a period of 5 years. For our customers: their personal data are retained for the duration of our business relationship.

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For our prospects: their personal data are retained for a period of 3 years starting from the last contact with Us. Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action). Personal data are retained during the processing of your request and is deleted once the request has been processed. Invoices are archived for a period of 10 years. The data relating to your transactions are archived for probationary purposes for a period of 5 years. If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we keep this information for 3 years.

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IV. Who are the recipients of your personal data?

The following may have access to your personal data:

(i) The staff of our company;

(ii) Our processors: hosting provider, office suite provider, collaborative work tool ;

(iii) If applicable: public and private organisations, exclusively to comply with our legal obligations.

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V. Is your personal data likely to be transferred outside Switzerland or the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company Amazon Web Services, located in the European Union (Germany, France).

As part of the tools we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside Switzerland or the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

• Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the Swiss Federal Council (under nFADP) or the European Commission (under GDPR), in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
• The personal data are transferred to a country whose level of data protection has not been recognized as adequate: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR and article 16 of the nFADP, adapted to each provider, including but not limited to the execution of Standard Contractual Clauses approved by the European Commission or the Swiss Federal Council, the application of Binding Corporate Rules or under an approved certification mechanism; or
• The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR or the nFADP.

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VI. What rights do you have regarding your personal data?

You have the following rights with regards to your personal data:

• Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR and article 19 of the nFADP.
• Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR and article 25 of the nFADP.
• Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR and article 32 of the nFADP.
• Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
• Right to erasure ("right to be forgotten"): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR and article 32 of the nFADP.
• Right to file a complaint to a competent supervisory authority: in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch; in the EU, your local supervisory authority — if you consider that the processing of your personal data constitutes a breach of applicable regulations.
• Right to define instructions related to the retention, deletion and communication of your personal data after your death, as applicable under Swiss law.
• Right to withdraw your consent at any time: for purposes based on consent, you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
• Right to data portability: under specific conditions defined in article 20 of the GDPR and article 28 of the nFADP, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
• Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

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VII Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.

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VIII. Contact information for data privacy matters

Contact email: info@climefi.com

Contact address: Carbonx AG, Technoparkstrasse 1, 8005 Zurich, Switzerland

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IX. Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

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