Privacy Policy

1What this policy covers

This privacy policy explains which personal data we process, what we use it for, to whom we disclose it and what rights you have. It applies to our website www.zimmerbergrealestate.ch and to our activities outside the website: to clients, prospective clients, owners, landlords, partners and introducers as well as other persons with whom we are in contact.

We comply with the Swiss Federal Act on Data Protection (FADP). Where it applies, we also comply with the EU General Data Protection Regulation (GDPR).

2Controller

The controller responsible for processing is:

The branch belongs to LOUMPROMOTION (SWITZERLAND) LTD, a company incorporated in England and Wales (Companies House no. 10291605). Please send questions about data protection and requests regarding your rights to private@zimmerbergrealestate.ch or to the postal address above.

We plan to transfer our business to a Swiss company (planned name: Zimmerberg Real Estate GmbH). From the transfer onward, that company will be the controller; we will then update this privacy policy.

3What data we process

Depending on the contact and the service, we process in particular:

• Contact and personal details: name, address, email, phone, language, date of birth, nationality and information on family members, for example for the school search.
• Mandate and contract data: search profile, budget, timeline, preferred regions, information on properties, correspondence, contracts, invoices and payments.
• Due diligence data: copies of identity documents, information on beneficial owners, proof of financing and funds, residence and permit status, information on the eligibility to purchase (Lex Koller) and the results of screening against sanctions lists and lists of politically exposed persons (PEP).
• Property and owner data: information on owners, sellers, landlords and operators and on their properties.
• Data on partners and business contacts: name, position, employer, contact details and information on introductions and remuneration.
• Communication data: content and metadata of emails, messenger messages, phone calls and letters.
• Website data: technical data collected when you visit our website and, with your consent, usage data from Google Analytics (section 8).

We generally do not ask for sensitive personal data, such as health data. If you provide such information on your own initiative, for example on special requirements for a home or a school, we use it only for that purpose. Our due diligence may reveal information on sanctions or on administrative or criminal proceedings; we process such data only to the extent necessary.

Sources: We receive most data from you directly. We receive further data from persons who introduce you to us with your consent or act on your behalf (such as advisors, employers, family offices, banks, law and tax firms), from owners, landlords, property managers and other brokers, from public sources such as the commercial register, the media and the internet, and from sanctions and PEP lists.

4What we use data for

• answering inquiries and holding first meetings
• preparing, concluding and performing mandates: search, viewings, applications, negotiations and the brokerage of purchase agreements, leases and business apartments (Arrival Residences)
• providing relocation services, such as the school search, registration with the municipality, insurance, banking, mobility and household matters
• handling sale and rental mandates of owners
• verifying identity, source of funds, eligibility to purchase, sanctions and PEP status and preventing money laundering, fraud and other violations of law
• working with partners and introducers and settling their remuneration
• invoicing, bookkeeping and enforcing claims
• complying with legal obligations, such as retention and tax obligations
• operating, securing and improving the website
• maintaining business relationships and informing you about our services, for example with invitations or market information, if you have consented or, in an existing business relationship, have not objected
• protecting our rights and defending against claims

5Legal bases

We process personal data in accordance with the principles of the FADP. Where the GDPR applies, we rely on the following legal bases:

• contract or pre-contractual measures (Art. 6(1)(b) GDPR), for example for inquiries and mandates
• legal obligations (Art. 6(1)(c) GDPR), for example retention obligations
• legitimate interests (Art. 6(1)(f) GDPR), for example the security and consistent presentation of the website, due diligence to prevent violations of law, cooperation with partners, the maintenance of business relationships and the enforcement of claims
• your consent (Art. 6(1)(a) GDPR), for example for web analytics with Google Analytics (section 8), for status reports to partners who introduced you to us, for introductions to partners or for market information by email. You may withdraw your consent at any time with effect for the future.

6To whom we disclose data

We disclose personal data only to the extent necessary for the purposes described, if you have consented or if we are obliged or entitled to do so. We do not sell personal data.

• Owners, sellers, landlords, property managers, operators of business apartments and other brokers: to the extent necessary for viewings, applications, negotiations and the conclusion of contracts, for example with an application dossier.
• Notaries, land registries, authorities, banks, insurers, schools and moving and relocation service providers: to the extent necessary for your mandate or at your request.
• Partners and introducers who introduced you to us: status reports only with your consent; information for settling remuneration only to the extent we have disclosed it in the mandate.
• Partners to whom we introduce you: for example advisors on residence and citizenship planning, only with your consent.
• Authorities and courts: if we are legally obliged or entitled to do so or if it is necessary to protect our rights.
• Service providers processing data on our behalf: providers of IT, cloud, email and hosting services (for example Microsoft for office software and document storage and the hosting provider of our website), fiduciary and accounting service providers and, where applicable, providers of sanctions and PEP screening services. They may process the data only in accordance with our instructions.
• Successor company: upon the transfer of our business to the planned Zimmerberg Real Estate GmbH or another successor company, the data passes to that company.

7Disclosure abroad

We process personal data mainly in Switzerland. However, recipients may also be located abroad, in particular in the EU and EEA, in the United Kingdom, in the United States or in the country from which you are relocating.

For countries that, according to the Swiss Federal Council, provide adequate data protection, such as the member states of the EU and EEA and the United Kingdom, no further safeguards are required. We disclose data to the United States if the recipient is certified under the Swiss-U.S. Data Privacy Framework or if appropriate safeguards are in place. For other countries without adequate data protection, we use recognized standard contractual clauses or rely on a statutory exception, for example if the disclosure is necessary to perform your contract, if you have expressly consented or if it concerns the enforcement of legal claims. You may request a copy of the safeguards used from us.

8Our website

Server logs: When you visit our website, the hosting provider records technically necessary data, such as your IP address, the date and time, the page accessed, your browser and operating system and the previously visited page. This data is used to deliver the website, for security and for error analysis. We do not analyze it to identify you personally.

Web analytics with Google Analytics: Only if you select “Accept” in the cookie notice do we use Google Analytics 4 to measure how our website is used, for example which pages are visited, for how long and through which source visitors find us. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Data may also reach Google LLC in the USA (section 7); according to Google, Google LLC is certified under the Swiss-U.S. Data Privacy Framework. For this purpose, Google Analytics sets cookies (_ga and _ga_ with our measurement ID) that expire no later than twelve months after your last visit. We use the reports only in aggregated form to improve the website; advertising features and Google Signals are turned off. According to Google, Google Analytics does not log or store the IP addresses of users in Switzerland, the EU or the United Kingdom. Google retains event-level data for no more than 14 months.

Your choice: Without your consent, we do not load Google Analytics and do not set any analytics cookies. We store your decision in your browser’s local storage (key “loum-consent”) for twelve months. You can change your choice at any time with effect for the future: Open cookie settings (this link is also in the footer of the website).

No advertising, no plugins: We do not use advertising services or social media plugins.

Language setting: The website stores the language in use, either the one you select or the one derived from your browser’s language settings, in your browser’s local storage (key “zre-lang”) so that it appears in that language on your next visit. This setting remains on your device and is not transmitted to us. You can delete it in your browser settings.

Fonts from Google: Our website loads fonts via the Google Fonts service. Your browser connects to Google servers and transmits your IP address. These servers may also be located in the United States. More information: policies.google.com/privacy.

Contact form: When you submit the form, your browser transmits your information to our server in encrypted form. We use it only to respond to your inquiry; section 9 applies to any further communication.

Links: Our website contains links to LinkedIn. If you click on such a link, the privacy terms of the respective provider apply.

9Communication by email and messenger

If you contact us by email, phone or messenger, or if we communicate with you through these channels, we process your information to handle your request. Unencrypted emails and messages may be viewed by third parties. For messenger services such as WhatsApp, Signal or Threema, the terms of the respective provider, which may also process data abroad, apply in addition. On request, we use secure channels.

10Retention

We retain personal data for as long as necessary for the purpose, as long as statutory retention obligations apply or as long as we have a legitimate interest, for example to preserve evidence during limitation periods.

• business records, accounting vouchers and invoices: ten years (Art. 958f of the Swiss Code of Obligations)
• mandate, contract and due diligence data: as a rule, ten years after the end of the business relationship
• inquiries without a mandate: as a rule, up to 24 months after the last contact
• server logs: only as long as necessary for security and operation

11Data security

We protect personal data with appropriate technical and organizational measures, such as access restrictions, password protection and encrypted transmission of our website (HTTPS). However, no one can guarantee absolute security.

12Your rights

Within the framework of applicable law, you have in particular the following rights:

• access to your personal data
• correction of inaccurate data
• erasure, unless a retention obligation or an overriding interest prevents it
• objection to certain processing, in particular for marketing purposes
• receipt or transfer of your data in a common electronic format
• withdrawal of consent with effect for the future
• under the GDPR, also restriction of processing

Please send your request to private@zimmerbergrealestate.ch. We may ask for proof of identity. You may also lodge a complaint with a supervisory authority: in Switzerland with the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch), in the EU and EEA with the supervisory authority of your country.

13Automated decisions

We do not make decisions based solely on automated processing. We do not carry out high-risk profiling.

14Obligation to provide data

You are not obliged to provide us with personal data. Without the information required for a mandate and our due diligence, however, we cannot act for you.

15Changes and language

We may amend this privacy policy at any time. The version published on www.zimmerbergrealestate.ch applies.

This privacy policy is available in German and English. In case of discrepancies, the German version prevails.

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