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: info@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

No personal data is sold or commercially distributed.

4. Legal Basis
Processing is based on:

• Legitimate business interest

• Pre-contractual measures

• Contractual necessity

• Compliance with Swiss legal obligations

Where applicable, processing of individuals located in the European Union may also rely on Article 6 GDPR.

5. Data Sharing
Personal data may be shared strictly where required for mandate execution, including with:

• Legal advisors

• Escrow providers

• Independent laboratories (for gemological certification)

• Regulatory authorities where legally required

All sharing is limited to professional necessity.

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.

9. Rights of Data Subjects
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: info@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.