Privacy Policy of SquaredData AG
Version effective as of 1 January 2026
With this Privacy Policy we, SquaredData AG, Weissenrainstrasse 28, 8707 Uetikon am See, Switzerland (hereinafter SquaredData, we or us), describe how we collect and further process personal data.
The term "personal data" in this Privacy Policy shall mean any information that identifies or could reasonably be used to identify any person.
If you provide us with personal data of other persons (such as employees, end clients, family members, work colleagues), please make sure the respective persons are aware of this Privacy Policy and only provide us with their data if you are allowed to do so and such personal data is correct.
This Privacy Policy is aligned with the EU General Data Protection Regulation ("GDPR") and the Swiss Data Protection Act ("DPA"). However, the application of these laws depends on each individual case.
1. Controller / Data Protection Officer / Representative
The "controller" of data processing as described in this Privacy Policy (i.e. the responsible person) is SquaredData. You can notify us of any data protection related matters using the following contact details: Weissenrainstrasse 28, 8707 Uetikon am See, Switzerland or info@etfbook.com.
2. Collection and Processing of Personal Data
We primarily process the following personal data that we obtain from our clients/users and other business partners as well as other individuals in the context of our business relationships with them or that we collect from clients/users when operating our platform, websites (in particular www.etfbook.com) and applications in the field of ETF data analytics ("Platform"):
Full name (first name, middle name, last name and gender);
Address;
E-mail address;
Telephone and/or mobile number;
Further personal data you may provide or upload in your discretion.
Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data (also see cookies Section 4 below).
3. Purpose of Data Processing and Legal Grounds
We primarily use collected personal data in order to conclude, process and fulfill contracts with our clients/users and business partners, in particular in connection with providing consulting and online Platform solutions in the field of data analytics (in particular flow and performance analytics of ETFs and respective screening and reporting) and related software, products or services, as well as in order to comply with our domestic and foreign legal and regulatory obligations. You may also be affected by our data processing in your capacity as an employee of such a client/user or business partner.
In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:
offer, provide, develop and improve our Platform services;
review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
market and opinion research;
asserting legal claims and defense in legal disputes and official proceedings;
prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
ensuring the functionality of our operation, including our IT, our websites, software (including the Platform) and other appliances;
acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of SquaredData.
If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.
4. Cookies / Tracking and Other Techniques Regarding the Use of the Platform
We typically use "cookies" and similar techniques on our websites or software (including the Platform), which allow for an identification of your browser or device. A cookie is a file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website or install our software (including our Platform). If you revisit our website or use our software (including the Platform), we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the Platform ("session cookies"), we may use cookies in order to save user configurations and other information for a certain time period (e.g. two years) ("permanent cookies"). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies for the purpose of saving user configuration (e.g. language, automated log in), in order to understand how you use our services and content, and to enable to show you customized offers and advertisement (which may also happen on websites of other companies; should your identity be known to us, such companies will not learn your identity from us; they will only know that the same user is visiting their website has previously visited a certain website). Certain cookies are sent to you from us, others from business partners with which we collaborate. If you block cookies, it is possible that certain functions (such as, e.g. language settings, shopping basket, ordering processes) are no longer available to you.
In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing e-mails. If such image files are retrieved from our servers, we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting.
By using our websites, software (including the Platform) and consenting to the receipt of newsletters and other marketing e-mails you agree to our use of such techniques. If you object, you must configure your browser or e-mail program accordingly or uninstall the software (including the Platform), should the respective setting not be available.
We may use Google Analytics or similar services on our Platform. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google Ireland Ltd. (located in Ireland), Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both "Google"), www.google.com and which allow us to measure and evaluate the use of our Platform (on an anonymized basis). For this purpose, permanent cookies are used, which are set by the service provider. Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not any personal information of you).
5. Datatransfer and Transfer of Data Abroad
In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:
our service providers and subcontractors, including processors (e.g. IT providers, cloud storage providers, third-party payment providers, third-party analytics services providers);
domestic and foreign authorities or courts;
acquirers or parties interested in the acquisition of SquaredData or business divisions or other parts of SquaredData;
other parties in possible or pending legal proceedings;
affiliates of SquaredData;
together Recipients.
Certain Recipients may be within Switzerland, but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to countries of the EU, EFTA and/or EEA, the UK and the USA where some of our service providers are located (such as cloud computing/storage providers).
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with appropriate data protection standards (for this purpose, we use the revised European Commission's standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules (like the Swiss-U.S. Data Privacy Framework or the EU-U.S. Data Privacy Framework) to ensure data protection, unless we can rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.
6. Retention Periods for your Personal Data
We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g. for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g. system logs).
7. Data Security
We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, inspections.
8. Obligation to Provide Personal Data To Us
In the context of our business relationship you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the Platform cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).
9. Profiling and Automated Individual Decision-Making
We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products, applications, features or tools suitable or relevant to you. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise to you as required.
In establishing and carrying out a business relationship, we generally do not use any fully automated individual decision-making (such as pursuant to article 22 GDPR). Should we use such procedures in certain cases, we will inform you separately of this and advise you of your relevant rights if required by law.
10. Your Rights
In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above. Please further note that the exercise of these rights may be in conflict with your contractual obligations, and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.
In general, exercising these rights requires that you are able to prove your identity (e.g. by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.
In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
11. Amendments of this Privacy Policy
We may amend this Privacy Policy at any time without prior notice. The current version published on our Platform shall apply.