iolite Capital Management AG ("iolite Capital", "we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data we collect when you visit www.iolitecapital.com (the "Website"), how and why we use it, the legal bases on which we rely, with whom we share it, how long we keep it, and the rights available to you. We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
1. Who we are
The controller responsible for the processing of personal data on this Website is:
iolite Capital Management AG
Gwattstrasse 15, 8808 Pfäffikon SZ, Switzerland
Email: privacy@iolitecapital.com · info@iolitecapital.com
For any privacy-related enquiry, or to exercise any of the rights described in Section 10, please contact us using the details above.
2. Personal data we collect
We collect personal data that you provide directly and data collected automatically when you use the Website:
- Information you provide: name, email address, telephone number, company or organisation, and the content of any message you send through our contact form or by email.
- Member account data: if you are granted access to the Inner Circle, the account information necessary to authenticate you and to provide access to investor materials, together with records of the materials you access.
- Usage and technical data: IP address, approximate location derived from it, browser type and version, device and operating-system information, pages viewed, dates and times of access, time spent on pages, and referring URLs.
- Cookies and similar technologies: identifiers used to operate the Website, remember preferences, maintain security, and measure usage (see Section 6).
We do not knowingly collect special categories of personal data (such as data revealing health, religious or political views, or biometric data) through the Website, and we ask that you do not submit such data to us.
3. How we use personal data
We use personal data for the following purposes:
- To operate, maintain, and secure the Website;
- To respond to enquiries and communicate with you;
- To provide and administer access to members-only investor materials;
- To analyse and improve Website performance and content;
- To detect, prevent, and address technical issues, fraud, or misuse;
- To comply with legal, regulatory, and supervisory obligations, including those applicable to a Swiss financial institution; and
- To establish, exercise, or defend legal claims.
We do not sell or rent personal data, and we do not use it for automated decision-making, including profiling, that produces legal or similarly significant effects concerning you.
4. Legal bases for processing
Where the GDPR applies, we rely on the following legal bases:
- Consent (Art. 6(1)(a) GDPR) — e.g. for optional analytics cookies; you may withdraw consent at any time;
- Performance of a contract or pre-contractual steps (Art. 6(1)(b) GDPR) — e.g. responding to your enquiry or providing member access;
- Legitimate interests (Art. 6(1)(f) GDPR) — operating and securing the Website, understanding how it is used, and communicating with prospective and existing contacts, balanced against your rights and freedoms; and
- Legal obligation (Art. 6(1)(c) GDPR) — compliance with applicable laws and regulatory requirements.
Under the Swiss FADP, processing is carried out lawfully, in good faith, proportionately, and for the purposes set out in this Policy.
5. Disclosure to third parties
We may share personal data with carefully selected third parties who process it on our behalf and under our instructions ("processors"), including:
- our website host and platform provider (Wix.com Ltd and its affiliates), which hosts the Website and provides built-in analytics and contact-form functionality;
- providers of member-authentication, email, and communication services; and
- providers of website analytics (see Section 6).
All processors are bound by appropriate confidentiality and data-processing terms. We may also disclose personal data where required by law, regulation, court order, or a competent authority, or where necessary to establish, exercise, or defend legal claims, or to protect the rights, property, or safety of iolite Capital, our clients, or others. We do not otherwise disclose your personal data to third parties for their own independent purposes.
6. Cookies and analytics
We use cookies and similar technologies that fall into the following categories:
- Strictly necessary cookies — required to operate the Website, maintain security, and provide member access. These cannot be switched off in our systems.
- Functional cookies — remember your preferences and choices.
- Analytics cookies — help us understand how the Website is used, on an aggregated basis. Where required, these are set only with your consent.
The Website is hosted on the Wix platform, which sets certain strictly necessary cookies for security and functionality. We may also use analytics tools such as Wix Analytics and/or Google Analytics (provided by Google LLC / Google Ireland Ltd) to measure aggregated traffic; these providers process the data under their own terms. You can control or disable cookies through your browser settings and, where presented, through the cookie banner on the Website. You can opt out of Google Analytics using the browser add-on Google provides. Disabling certain cookies may affect how the Website functions.
7. International data transfers
iolite Capital is based in Switzerland. Some of our service providers (including our website platform and analytics providers) may process personal data in the European Economic Area (EEA), the United States, or other countries whose data-protection laws may differ from those of Switzerland or the EEA.
Where personal data is transferred to a country that does not, in the view of the Swiss Federal Council or the European Commission, ensure an adequate level of protection, we rely on appropriate safeguards — typically the European Commission's Standard Contractual Clauses (with the Swiss addendum recognised by the Federal Data Protection and Information Commissioner), or another lawful transfer mechanism — to protect your data. You may request a copy of the relevant safeguards using the contact details in Section 14.
8. Data retention
We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements, and to establish, exercise, or defend legal claims. Enquiry and contact-form correspondence is generally retained for the duration of our relationship and for a reasonable period thereafter; member-access records are retained for as long as the account is active and as required by law. Server logs and analytics data are retained for a limited period and then deleted or anonymised. When personal data is no longer required, we delete or irreversibly anonymise it.
9. Data security
We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These include encryption in transit (HTTPS), access controls, and the selection of reputable service providers. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
10. Your rights
Subject to and in accordance with applicable law (the Swiss FADP and, where applicable, the GDPR), you have the following rights in respect of your personal data:
- Access — to be informed whether we process your personal data and to obtain a copy of it;
- Rectification — to have inaccurate or incomplete data corrected;
- Erasure — to have your data deleted in certain circumstances;
- Restriction — to restrict our processing in certain circumstances;
- Data portability — to receive certain data in a structured, commonly used, machine-readable format;
- Objection — to object to processing based on our legitimate interests;
- Withdrawal of consent — to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
To exercise any of these rights, please contact us at privacy@iolitecapital.com. We may need to verify your identity before responding. We will respond within the timeframe required by applicable law.
If you believe our processing of your personal data infringes applicable law, you have the right to lodge a complaint with a supervisory authority — in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch); in the EEA, the data-protection authority of your country of residence, place of work, or the place of the alleged infringement.
11. Children's privacy
The Website is intended for financially sophisticated, professional, and qualified investors and is not directed at children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take appropriate steps to delete it.
12. Third-party links
The Website may contain links to third-party websites, platforms, and resources (for example, news outlets, conference organisers, social-media profiles, and document downloads). We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party site you visit.
13. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Effective date" at the top of this page indicates when it was last revised. Material changes will be made prominent on this page. Your continued use of the Website after any change constitutes acceptance of the updated Policy.
14. How to contact us
For any question about this Privacy Policy or our handling of personal data, or to exercise your rights, please contact:
iolite Capital Management AG
Gwattstrasse 15, 8808 Pfäffikon SZ, Switzerland
Email: privacy@iolitecapital.com