Privacy Policy

1 Introduction

This Privacy Policy provides information about the processing of your personal data (hereinafter also referred to as "DATA") by Picus Investments GmbH (hereinafter also referred to as "Picus Investments", "CONTROLLER", "us" or "we").

The protection of your DATA is of the utmost importance to us, which is why the processing of DATA is carried out in accordance with applicable data protection laws such as the EU General Data Protection Regulation (hereinafter referred to as "GDPR") and the revised Federal Act on Data Protection of June 19, 1992 (hereinafter referred to as "FADP"). This Privacy Policy is based on the terminology used in the GDPR and the FADP (hereinafter also referred to as "APPLICABLE DATA PROTECTION LAW") and is guided by their provisions.

Picus Investments is also responsible for requirements and concerns from individuals residing outside of Switzerland regarding the processing of your DATA.

2 Who is the data controller and who can you contact?

The CONTROLLER (DATA CONTROLLER) for the processing of personal data is:
Picus Investments GmbH.

3 For what purposes do we use your data?

3.1. Use when visiting the website

When accessing our website, your internet browser automatically transmits DATA for technical reasons, even during purely informational use or viewing of the website, to ensure correct display as well as stability and security.

The following DATA is stored separately from other data that you may transmit to us:

• IP address
• Date and time of access
• Access status/HTTP status code
• Browser type/version/language
• Operating system used
• URL of the previously visited website
• Amount of data transferred in each case
• Website from which the request originates
• Browser
• Operating system and its interface
• Language and version of browser software

This DATA is stored in particular for technically necessary reasons. In addition, we store this DATA for a limited time in order to initiate a derivation to personal DATA in the event of unauthorized access or access attempts to our cloud solution. The processing of your DATA described in this section takes place in compliance with the principle of legality, the principle of correctness, the principle of proportionality, the principle of transparency, the principle of purpose limitation and the consent of the data subject, taking into account APPLICABLE DATA PROTECTION LAW.

3.2. Use for email inquiries

You can contact us via the email addresses provided on our website: info@picusinvest.com

If you send us an email, we collect, store and use, if provided, your:

• Name
• Complete address details
• Landline and/or mobile phone number
• Email address
• Content of your message

Processing only takes place to the extent necessary to process your inquiry and for correspondence with you. The DATA collected serves solely the purpose of being able to process your request. The processing of your DATA described in this section takes place in compliance with the principle of legality, the principle of correctness, the principle of proportionality, the principle of transparency, the principle of purpose limitation and the consent of the data subject, taking into account APPLICABLE DATA PROTECTION LAW.

3.3. Use based on legal requirements

We process your DATA to fulfill legal obligations such as regulatory requirements and/or commercial and tax retention obligations. APPLICABLE DATA PROTECTION LAW is taken into account as the basis for this processing.

Should we wish to process your DATA for a purpose not mentioned above, we will inform you in advance within the framework of legal provisions and/or obtain your consent.

4 Cookies

The following lists the tools we use for product optimization or to optimize customer interaction on our website.

The listed tools store so-called cookies. Cookies are files that are stored on your device and that make it possible to recognize the user and serve to make the digital offer more user-friendly and effective.

You can also access our website without cookies. You can also decide via the settings in our cookie banner which categories of cookies you wish to accept.

To completely prevent the use of cookies by your internet browser, you can deactivate the use of cookies via the settings of your internet browser. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. You can find out how to deactivate and/or delete cookies via the help functions of your internet browser. Please note that deactivating/deleting cookies may result in individual functions of our website no longer functioning to their full extent. Cookies that may be required for certain functions of our website are shown below. In addition, the deactivation/deletion of cookies only affects the internet browser used here. If you use other internet browsers, the deactivation/deletion of cookies must therefore be repeated accordingly.

The DATA stored by a cookie is stored until the end of the lifetime of the respective cookie or until you delete the cookie.

Further information can be found in the respective privacy policy of the respective providers.

We use your information in the context of website analyses to make our website more user-friendly and to conduct market research. For this purpose, we use web analysis tools. These tools use your IP addresses either in shortened form or not at all. The placement of such analysis cookies is carried out in accordance with APPLICABLE DATA PROTECTION LAW. As the operator of the website, we have a legitimate interest in analyzing user behavior in order to optimize our web offering.

5 Who receives your data?

Depending on the type of DATA processed by us as DATA controller, only certain and relevant organizational units have access to your DATA. These are the specialist departments involved in providing our services. Through a role and authorization concept, access within our company is limited to those functions and to the extent required for the respective purpose of processing.

To fulfill the aforementioned purposes, we also transmit your DATA to third parties (e.g. IT service providers as "data processors") with your written consent in accordance with APPLICABLE DATA PROTECTION LAW. The categories of these recipients are divided as follows:

1. External service providers in the EU and/or Switzerland

To fulfill our contractual and legal obligations, we partly use external service providers in the EU and/or Switzerland. These service providers can therefore also receive DATA for these purposes if they maintain confidentiality and our data protection instructions.

Picus Investments uses the services of the following external service providers:
Alphahosting GmbH, 06112 Halle, Germany

This list may be changed and supplemented at our sole discretion.

2. Other recipients

In addition, we may transfer your personal DATA to other recipients, such as authorities to fulfill legal reporting obligations (e.g. law enforcement authorities or social welfare authorities).

6 Where and for how long is your data stored?

Insofar as the DATA is no longer required for the aforementioned purposes, it will be deleted after expiry of the statutory retention period and blocked for further processing for the remaining duration of the statutory retention period in accordance with APPLICABLE DATA PROTECTION LAW.

Your DATA is generally processed for as long as our processing purposes, the statutory retention periods and our legitimate interests for documentation and evidence purposes require.

7 The security of your personal data according to the Privacy by Default and by Design principle

Picus Investments will take appropriate technical and organizational measures (in particular pseudonymization of DATA, data minimization and restriction of access to the relevant DATA to persons who process this DATA for the purposes of data processing) both at the time of determining the means for processing and at the time of processing itself, which serve to effectively implement data protection principles and to integrate the necessary guarantees into the processing in order to meet the requirements of APPLICABLE DATA PROTECTION LAW and to protect your rights.

This obligation relates to the type and amount of your PERSONAL DATA that we collect, the scope of its processing and the duration of its storage and accessibility. These measures ensure that your DATA is not made accessible to an indefinite number of third parties by default without your intervention.

In the event of a breach of the protection of personal data, Picus Investments notifies the competent supervisory authority (Federal Data Protection and Information Commissioner (FDPIC)) without delay in accordance with APPLICABLE DATA PROTECTION LAW after becoming aware of the breach, unless it is unlikely that this breach poses a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, Picus Investments will, if possible, notify you of this breach without delay in accordance with APPLICABLE DATA PROTECTION LAW.

8 What rights do you have?

In order to show you all possibilities within the framework of the collection and use of your information or your DATA, we would like to draw your attention to the rights that you are entitled to in this context and this on the basis of APPLICABLE DATA PROTECTION LAW.

8.1 Right to information

You can request information about how, by whom, for what purposes and under what conditions your DATA is collected and used.

8.2 Right to rectification

Of course, when using your personal information, we do not want to pass on false or outdated information in order to prevent misunderstandings or possible damage. Therefore, you have the opportunity at any time to update or correct the information we have collected about you.

8.3 Right to restriction of processing

You can also request that we only use your DATA in a restricted manner. This means that your DATA will still be stored, but may only be used under limited conditions (e.g. to assert legal claims).

8.4 Right to object

Insofar as we collect and use your information and DATA on the basis of legitimate interests, you naturally have the right to object to the use of your information.

8.5 Right to erasure

Last but not least, we also delete your DATA insofar as it is no longer required for the purposes named here and insofar as there are no retention obligations for us. However, if you are of the opinion that there is no legal basis for further storage, you can assert your right to erasure of your DATA. There is a statutory period of 30 days for us to carry out the deletion of the DATA.

8.6 Right to data portability

You also have the right to data portability with regard to all DATA that you have provided to us. This means that we will make this DATA available to you in a structured, common and machine-readable format.

9 Consent and withdrawal of consent

If you have given us consent for the processing of your personal DATA, you can revoke this at any time and without giving reasons. The revocation of consent takes effect for the future. The lawfulness of the processing of your DATA up to the time of revocation remains unaffected.

10 Changes and adjustments to the Privacy Policy

We reserve the right to change this Privacy Policy. The current version of the Privacy Policy is always available at www.picusinvest.com. If this Privacy Policy is changed in the future, we will inform you of the changes.

February 2026