This data protection declaration applies to the use of the Incrementum AG websites. We attach great importance to the protection of your personal data and collect, process and use your personal data exclusively in accordance with the principles described below and in compliance with the applicable data protection laws.

I. Contact details of the data responsible and the data protection coordinator

The website ingoldwetrust.report (hereinafter “Website”) is operated by Incrementum AG, Im alten Riet 102, 9494 Schaan, Liechtenstein, as the data responsible within the meaning of the General Data Protection Regulation (GDPR) (hereinafter “Incrementum AG” or “we”). The operational data protection coordinator of Incrementum AG is Mrs Claudia Fasciati. She can be reached at the above address as well as by telephone: +423 237 26 65 or e-mail: cf@incrementum.li.

II. Description and scope of data processing

1.     Scope of the processing of personal data

Our processing of personal data of our users is limited to those data which are necessary for the provision of a functional website as well as our contents and services. The processing of personal data of our users is only carried out for the purposes agreed with them or if there is another legal basis (in the sense of the DSGVO). We only collect personal data that is actually required for the performance and processing of our tasks and services or that you have voluntarily provided to us.

2.     Visitor and usage data

When our website is accessed, our system also automatically collects data and information from the computer system of the accessing computer. The following personal data and information are collected:

• Information about the type of browser and the version used
• The user’s operating system
• The user’s internet service provider
• The IP address of the user
• Date and time of access
• Websites from which the user’s system accesses our website.

This data and information is stored for data security reasons in order to ensure the stability and operational security of our system. We store them for a maximum period of 1 month. The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f GDPR. In addition, this data and information are also used to analyse the use of our website (see point 3).

3.     Web analysis and targeting tools

a.     Matomo Analytics

We analyse the use of our website using the open-source software tool Matomo (formerly Piwik; privacy policy declaration can be found at https://matomo.org/privacy-policy/). When individual pages of our website are accessed, the following data is stored:

• Two bytes of the IP address of the user’s accessed system
• The accessed website
• The website from which the user accessed the accessed website (referrer)
• The sub-pages accessed from the accessed website
• The time spent on the website
• The frequency with which the website is accessed

However, the automatically collected IP addresses are anonymised before analysis. All analyses are therefore based on anonymised data records and no personal analysis are carried out. This data is not merged with other personal data sources or passed on to third parties. By evaluating the data obtained, we are able to compile information on the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. These purposes are also our legitimate interest in processing the data in accordance with Art. 6 Para. 1 lit. f GDPR. By anonymising the IP address, the interest of users in the protection of their personal data is adequately considered. You are not being tracked since your browser is reporting that you do not want to. This is a setting of your browser so you won’t be able to opt-in until you disable the ‘Do Not Track’ feature. If you have already activated the “Do Not Track” setting in the browser settings, no actions performed will be analysed and linked. This can be deactivated again in the browser settings. The collected data are automatically deleted after 730 days.

a.     Facebook Pixel

With your consent, this website uses the Facebook Pixel of the social network “Facebook” (Facebook Inc., 1601 S. California Ave, Palo Alto, California 94304, USA). This serves the purpose of presenting visitors to our website with interest-based advertisements during their visit to the social network Facebook. A direct connection to the Facebook servers is established via the Face-book pixel when visiting our website. In the process, it is transmitted to the Facebook server that you have visited our website and Facebook assigns this information to your personal Facebook user account. We would like to point out that we, as the provider of the website, have no knowledge of the content of the transmitted data or its use by Facebook. For more information on the collection and use of data by Facebook, as well as your rights in this regard and options for protecting your privacy, please refer to Facebook’s data protection information at https://www.facebook.com/about/privacy/. We ourselves do not pass on any customer data to Facebook. Further information about your corresponding data protection rights and setting options for protecting your privacy can be found at: https://www.facebook.com/policy.php, https://www.facebook.com/help/186325668085084.

c. Google Tag Manager, Google Analytics and Google Ads Conversion Tracking

This website uses Google Tag Manager provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).

Google Tag Manager is a tag management system that allows us to centrally manage website tags. Google Tag Manager itself does not process any personal data, but merely ensures the triggering of other tags.

In particular, the following services may be integrated via Google Tag Manager:

Google Analytics

Subject to your consent, we use Google Analytics, a web analytics service provided by Google Ireland Limited.

Google Analytics uses cookies that enable an analysis of your use of the website. In particular, the following data may be processed:

• IP address (in anonymized/shortened form)
• visited pages
• time spent on pages
• interactions
• technical information (browser, device, etc.)

The information generated by the cookie may be transferred to and stored on Google servers, including in the United States.

We use Google Analytics exclusively with IP anonymization enabled. This means that your IP address is shortened by Google within the EU or EEA before transmission.

Processing is based on your consent pursuant to Art. 6(1)(a) GDPR.

Google Ads Conversion Tracking

This website also uses Google Ads Conversion Tracking, subject to your consent.

If you reach our website via a Google advertisement, a cookie is set on your device by Google Ads. This cookie is used to analyze the effectiveness of our advertisements.

In particular, the following information may be processed:

• visits to specific pages (conversions)
• interactions after clicking on ads
• technical information about the device

This information is used exclusively for statistical evaluation and optimization of our advertising measures.

Data may also be transferred to Google servers in the United States.

Legal Basis and Control

All Google services are integrated and executed only after your explicit consent in accordance with Art. 6(1)(a) GDPR via our cookie consent tool.

You can withdraw or modify your consent at any time with effect for the future.

Further Information

Further information on data processing by Google can be found at:
https://policies.google.com/privacy

4.     Cookies

Incrementum uses so-called cookies on the website. Cookies are small text files that are stored in the cache of your browser to enable recognition of your browser and to make your visit to our website even more attractive. Currently, only so-called session cookies are stored. Session cookies automatically lose their validity when you leave the website. Persistent cookies remain on your terminal device for a longer period until you delete them. They enable us, for example, to use the tools described above for web analysis and individualised targeting. Of course, you can also visit our website without cookies being stored on your browser. You can restrict or deactivate the storage of cookies in your browser settings at any time, but this may lead to restrictions in the functions and user-friendliness of our website.

5.     Data processing via contact form and when contacting us

You can contact Incrementum directly by email contact@incrementum.li, telephone +423 237 26 66 or fax +423 237 26 67. Incrementum collects, processes and uses the personal data and information you provide via these channels and via the contact form on the website (title, first and last name, e-mail address, subject and content of your message) exclusively for the purpose of processing your request. If they are no longer required to fulfil the above-mentioned purpose or on the basis of other justifiable grounds pursuant to Art. 6 Para. 1 GDPR (e.g. contract initiation and fulfilment, statutory retention periods, legitimate interests), they will be deleted.

6.     Newsletter

On our website you can register for our electronic newsletter. Insofar as you have given your consent to receive the newsletter (Art. 6 para. 1 let. a GDPR), we will use your e-mail address you have provided, your title, your first name and surname exclusively to send you current information from Incrementum AG. We record your investor type and your domicile in order to comply with the regulatory requirements of product governance under MiFID II. We ask for your language in partial so that we can send you targeted information in your desired language. Since only professional investors are admitted to some funds, we sometimes also ask for the company name. After successful registration for the newsletter, you will automatically receive an e-mail asking you to confirm your e-mail address. As soon as you have confirmed your e-mail address by clicking on the link contained in the confirmation e-mail, you will regularly receive the newsletter you have selected. In the newsletter email you can unsubscribe from the newsletter at any time and revoke your consent. Your email address, salutation, first and last name, investor type, domicile, language and company name will then be deleted from the system immediately. Technically, the newsletter is processed via Mailchimp. MailChimp is a newsletter delivery platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The e-mail addresses of Incrementum newsletter recipients, as well as their other data described in the notes, are stored on MailChimp servers in the USA. However, no sensitive data such as credit card details, etc. are transmitted to Mailchimp. MailChimp uses this information to send and evaluate the newsletters on behalf of Incrementum. Furthermore, according to its own information, the dispatch service provider may use this data in pseudonymous form, i.e. without assigning it to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and display of the newsletters or for statistical purposes to determine which countries the recipients come from. However, the mailing service provider does not use the data of Incrementum newsletter recipients to write to them itself or to pass it on to third parties. Incrementum trusts in the reliability and IT and data security of MailChimp. MailChimp is certified under the Privacy Shield agreement and thus offers a guarantee of compliance with the European data protection level. In addition, Incrementum has concluded a “Data Processing Agreement” with MailChimp. This is a contract in which MailChimp undertakes to protect the data of Incrementum newsletter subscribers, to process it in accordance with their data protection provisions on behalf of Incrementum and, in particular, not to pass it on to third parties. Please visit www.mailchimp.com for more information about Mailchimp, its privacy policy and terms of use. Currently, an alternative evaluation process is underway regarding the above-mentioned program.

7.     File downloads

We do not require you to provide any personal information in order to download files from our website.

8. Store

We collect information about you during the ordering process in our store. What we collect and store While you are visiting our website, we track: Products you have viewed: We use this information to show you, for example, products you have recently viewed. Shipping Address: We ask you to enter this so we can, for example, estimate shipping costs before you place an order and send it to you! We also use cookies to track the contents of your shopping cart as you browse our site. When you shop with us, we ask you for information such as your name, billing address, shipping address, email address, phone number, credit card/payment information, and optional account information such as your username and password. We use this information for the following purposes, among others:

• To send you information about your account and your order
• Respond to your inquiries, including refunds and complaints
• Process payments and prevent fraud
• Set up your account for our store
• To comply with legal obligations, such as calculating taxes
• Improve our store offerings
• Send you marketing messages if you would like to receive them

When you create an account, we store your name, address, email address, and phone number, which we will use for future checkout orders. In general, we will retain your information for as long as we need it for the purposes for which we collect and use it, and we are not required by law to retain it. For example, we store order information for tax and accounting purposes for 7 years. This includes your name, email address, and billing and shipping address.   Who on our team has access Members of our team have access to the information you provide to us. For example, both administrators and store managers can access: Order information, such as what was purchased, when it was purchased, and where it should be sent; and Customer information such as your name, email address, and billing and shipping information. Our team members have access to this information to fulfill orders, process refunds, and assist you.   What we share with others We only share information with third parties that help us provide you with our orders and store services, such as Stripe for payment processing.  

III. Data security

We use the widespread SSL procedure in connection with the highest encryption level supported by your browser when visiting our website. You can see whether an individual page of our website is transmitted in encrypted form by the closed display of the key or lock symbol in the address bar of your browser. In addition, we apply further appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

IV. Your rights (affected rights)

Regarding the personal data concerning you, you are entitled to the following data protection rights under the GDPR:

• Right to information: You can request information from Incrementum about whether and to what extent personal data about you are being processed (e.g. categories, origin, recipients and storage period of the personal data processed, purpose of processing, the existence of automated decision-making including profiling, your rights as a person concerned, etc.). 

• Right to correction, deletion and restriction of processing: You have the right to request the correction of inaccurate or incomplete personal data concerning you. Furthermore, your personal data must be deleted if this data are no longer necessary for the purposes for which they were collected or processed, if you have withdrawn your consent or if this data are processed unlawfully. Furthermore, you have the right to request the restriction of processing.

• Right of revocation: You have the right to revoke your consent to the processing of your personal data for one or more specific purposes at any time, if the processing is based on your explicit consent. This also applies to the revocation of declarations of consent given prior to the application of the GDPR, that means as well prior to 25 May 2018. Please note that the revocation only takes effect for the future. Processing that took place before the revocation are not affected. The revocation also has no influence on data processing on any other legal basis.

• Right to data portability: You have the right to obtain the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format and to have this data transferred to another controller.

• Right of objection: You have the right to object informally to the processing of data in individual cases for reasons arising from your particular situation, provided that the processing is in the public interest or is carried out to protect the legitimate interests of the asset management company or a third party. Furthermore, you have the right to object informally to the use of personal data for advertising purposes. If you object to the processing of your personal data for direct advertising, we will no longer process your personal data for this purpose.

• Right of appeal: You have the right to lodge a complaint with the competent Liechtenstein supervisory authority. You may also contact another supervisory authority in an EU or EEA member state, for example in your place of residence or place of work or in the place of the suspected violation.

The contact details of the competent data protection authority in Liechtenstein are as follows: Liechtenstein Data Protection Authority, Städtle 38, P.O. Box, 9490 Vaduz, Liechtenstein, telephone: +423 236 60 90, e-mail: info.dss@llv.li. Requests for information or objections should preferably be submitted by writing to the data protection coordinator mentioned above. The data protection coordinator is also available to you as a contact person for all other data protection matters. Status: August 2022