Privacy

1. Controller

ReLease Immobilien GmbH

Irina Schell

Switzerland

Email: info@release-immobilien.ch

2. General Information on Data Processing

This privacy policy is based on the Federal Act on Data Protection (FADP) of September 25, 2020 (in force since September 1, 2023) and – where applicable – on the European Union's General Data Protection Regulation (GDPR).

ReLease Immobilien processes personal data in accordance with the principles of purpose limitation, proportionality, data security, and transparency, and while observing the duties of care as per Art. 398 et seq. of the Swiss Code of Obligations (OR).

3. Types of Data Processed

• Master data (last name, first name, company, position, address)
• Contact data (phone number, email address)
• Contract and project data (location details, property interest, appointment status)
• Usage data (pages visited, access times, IP address)
• Communication data (email content, inquiries, CRM notes)
• Content data (e.g., photographs, text entries in forms)

4. Purposes of Data Processing

Your data will be processed for the following purposes:

• Commercial real estate brokerage (tenant/landlord)
• Processing inquiries and contract preparation
• Ongoing customer support and project communication
• Administration (e.g., appointment scheduling, document management)
• Operation of the online offering and analysis of access data
• Reach measurement and marketing (e.g., newsletters, ad optimization)

5. Definitions

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

6. Security Measures

We kindly ask you to regularly review our privacy policy. We will update the privacy policy as soon as changes in our data processing activities make it necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or any other individual notification.

ReLease Immobilien takes appropriate technical and organizational measures to protect personal data from unauthorized access, loss, misuse, or alteration.

Access to electronic systems (e.g., HubSpot, cloud storage, email accounts) is password-protected and restricted to authorized personnel.

7. Use of CRM System (HubSpot)

For efficient management of contacts and projects, ReLease Immobilien uses the CRM system HubSpot (HubSpot Inc., Cambridge, MA, USA).

• Server locations: EU & USA
• A data processing agreement exists with HubSpot in accordance with Art. 28 GDPR
• All data processing is carried out in accordance with DSG & GDPR
• Purpose: Customer support, communication, appointment and project management

8. External Service Providers and Processors

If, in the course of our processing, we disclose data to other individuals and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g., if the transmission of data to third parties, such as payment service providers, is necessary for the fulfillment of a contract in accordance with Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation requires it, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).

Virtual Assistance

ReLease Immobilien works with an external virtual assistant based in Germany. This assistant is:

• contractually to the Confidentiality and Purpose limitation obliged
• has only limited access to data (e.g., contact management, appointment scheduling)
• may use data not independently use or disclose

Other recipients (depending on the project):

• Owners, landlords, or prospective tenants
• Authorities or service providers (e.g., notaries, web hosts, trustees)

9. Hosting and Access Data

Our online offering is hosted on servers within the EU. Our hosting provider processes data under a data processing agreement.

Collected log files include:

• IP address
• Date/Time of access
• requested pages and files
• Browser type, operating system
• Referrer URL

Log files are stored for a maximum of 7 days, unless required for tracking a security-relevant incident.

10. Cookies and Analytics Tools

Cookies are small files that are stored on users' computers. Various information can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, also known as "session cookies" or "transient cookies," are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can, for example, store the content of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent." For example, the login status can be saved if users visit it again after several days. Similarly, user interests can be stored in such a cookie, which are used for audience measurement or marketing purposes. Cookies offered by providers other than the controller operating the online offering are referred to as "third-party cookies" (otherwise, if they are only the controller's cookies, they are called "first-party cookies").

We may use temporary and permanent cookies and will inform you about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Disabling cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies employed for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by disabling them in the browser settings. Please note that in this case, not all functions of this online offering may be available.

Our website uses cookies for user-friendly design and analysis.

Contact

When contacting us (e.g., via contact form, email, telephone, or social media), user information is processed for handling the contact request and its processing in accordance with Art. 6 para. 1 lit. b) GDPR. User information may be stored in a Customer Relationship Management system ("CRM System") or similar inquiry management system.

We delete inquiries when they are no longer required. We review the necessity every two years; statutory archiving obligations also apply.

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis,

optimization and economic operation of our online offering in accordance with Art. 6 para. 1 lit. f GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the users' use of the online offering is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement, thereby offering a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on activities within this online offering, and to provide us with other services related to the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with IP anonymization activated. This means that the IP address of users is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software settings; users can also prevent Google from collecting the data generated by the cookie and related to their use of the online offering, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on data use by Google, settings, and objection options can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated).

Users' personal data will be deleted or anonymized after 14 months.

You can block cookies through browser settings or deactivate them using the following link:

http://tools.google.com/dlpage/gaoptout?hl=de

11. Integration of Third-Party Services

Third-party content may be embedded within our website (e.g., Google Maps, fonts, videos). In this process, the IP address is transmitted to the respective provider.

Provider: Google LLC, Privacy Policy: https://www.google.com/policies/privacy/

12. Data Transfer to Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transferring data to third parties, this only happens if it is necessary for the fulfillment of our (pre-)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we only process or have data processed in a third country if the special conditions of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level equivalent to that of the EU (e.g., for the USA through the "Privacy Shield") or compliance with officially recognized specific contractual obligations (so-called "Standard Contractual Clauses").

13. Retention Period

Data is only stored for as long as necessary for the respective purpose.

• By default: Deletion after 5 years after project completion
• Statutory retention periods remain unaffected (e.g., OR, HGB, AO).

14. Rights of Data Subjects

Data subjects have the right, in accordance with Art. 25 et seq. revDSG:

• to information on whether and which personal data concerning them is being processed;
• to the disclosure or transfer of their personal data in a common electronic format (data portability);
• to the rectification of inaccurate or incomplete personal data;
• to the deletion of data, provided that no statutory retention obligations or overriding interests prevent it;
• to restrict processing in certain cases;
• to object to unlawful data processing;
• to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).

Inquiries should be sent in writing or by email to:

info@release-immobilien.ch

15. Deletion of Data

Unless expressly stated otherwise in this privacy policy, data stored by us will be deleted as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent its deletion. If data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, data is retained for 6 years in accordance with Section 257 (1) HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, booking vouchers, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, booking vouchers, commercial and business letters, documents relevant for taxation, etc.).

According to legal requirements in Austria, data is retained for 7 years in accordance with Section 132 (1) BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statements of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents related to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU member states for which the Mini One Stop Shop (MOSS) is used.

16. Right to Revoke Consent

You can revoke any given consent at any time with future effect.

17. Updates

ReLease Immobilien reserves the right to amend this privacy policy to comply with new legal requirements or implement technical changes.

The version published on the website at any given time is valid.

‍