Privacy Policy

1. Data Controller
The data controller responsible for processing personal data is:
ITC-Invest
Frank Steinberger
Via Maistra 10, 6914 Carona
Switzerland
Email: office@itc-invest.ch

2. Scope and Purpose of Processing
Personal data is processed solely for legitimate business purposes, including:

• Responding to inquiries

• Evaluating potential mandates

• Conducting transaction-related communication

• Meeting legal and regulatory obligations

The processing is limited to what is necessary for these purposes.

3. Categories of Data
Depending on the interaction, we may process:

• Name

• Professional affiliation

• Contact details

• Transaction-related information

• Identification data where legally required

• ​Documents and information exchanged through the private vault, which may contain personal data.

No personal data is sold or commercially distributed.

4. Applicable Data Protection Law
Personal data is processed in accordance with the Swiss Federal Act on Data Protection. Where the EU General Data Protection Regulation applies, processing is based, as appropriate, on pre-contractual measures or contractual necessity, compliance with applicable legal obligations, legitimate interests, or consent.

5. Data Sharing
Personal data may be disclosed where necessary for the purposes described in this policy to:

• sellers, buyers and their authorised representatives

• independent professional advisers, laboratories and transaction service providers

• website hosting, IT and communication service providers, including Wix and Infomaniak

• competent authorities where legally required

• Brian Widyaratne, our source-coordination partner in Sri Lanka, who uses an ITC-Invest email account hosted by Infomaniak, where necessary for seller introductions and transaction coordination;

Disclosure is limited to the information necessary for the relevant purpose.

6. International Transfers
Given the cross-border nature of advisory services, data may be processed internationally where required for transaction execution.
Appropriate safeguards are implemented where legally necessary.

7. Data Retention
Personal data is retained only for as long as necessary to fulfill contractual purposes or comply with legal obligations.

8. Data Security
Reasonable technical and organizational measures are implemented to safeguard personal data against unauthorized access, loss, or misuse.
Private Vault
Access to the private vault requires an access code and an additional security key. Vault content is encrypted locally before transmission and decrypted locally by the authorised recipient.

9. Rights of Data Subjects
Subject to applicable law, individuals may request:

• Access to their personal data

• Correction of inaccurate data

• Deletion where legally permissible

• Restriction of processing

• Information about data handling

Requests may be directed to: office@itc-invest.ch

10. Website Usage Data
The website may collect limited technical data (e.g., server logs) necessary for security and operational integrity.
If analytics or tracking tools are used, appropriate transparency and consent mechanisms will be implemented where required by law.