Privacy Policy

Last updated: 24 February 2026

Privacy Policy

This Privacy Policy describes how ZUG TRADING, operated by The Vanderbilt Portfolio AG (“we”, “us”, “our”), collects, uses, and protects personal data when you visit zugtrading.com (the “Site”).

We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (FADP, revised 2023) and, where applicable, the European Union General Data Protection Regulation (GDPR).

1. Data Controller

The data controller responsible for your personal data is:

The Vanderbilt Portfolio AG Zurich, Switzerland Contact: [email protected]

2. Data We Collect

2.1 Data Collected Automatically

When you visit the Site, we and our third-party service providers may automatically collect the following data:

• IP address (anonymised where technically feasible)
• Browser type and version
• Operating system
• Referring URL
• Pages visited and time spent on pages
• Date and time of visit
• Device type

This data is collected through cookies and similar tracking technologies. See our Cookie Policy for full details.

2.2 Data You Provide Voluntarily

If you contact us by email or through any contact form, we collect the information you provide, which may include your name, email address, organisation, and the content of your message.

2.3 Data We Do Not Collect

We do not collect payment card data, government identification numbers, or sensitive personal data as defined under the FADP and GDPR.

3. Purposes and Legal Bases for Processing

4. Google Analytics

The Site uses Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics uses cookies to collect information about how visitors use the Site. The information generated by the cookie about your use of the Site is transmitted to and stored by Google on servers in the United States.

Google will use this information to evaluate your use of the Site, compile reports on website activity, and provide other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required by law, or where such third parties process the information on Google’s behalf.

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on, available at: tools.google.com/dlpage/gaoptout.

For more information on how Google uses data when you use our Site, see: policies.google.com/technologies/partner-sites.

5. Google Ad Manager

The Site uses Google Ad Manager to serve advertisements. Google Ad Manager may use cookies and similar technologies to serve ads based on your prior visits to the Site and other websites. Google’s use of advertising cookies enables it and its partners to serve ads based on your visit to the Site and other sites on the internet.

You may opt out of personalised advertising by visiting Google’s Ads Settings at: adssettings.google.com.

6. Data Retention

• Analytics data: retained for 26 months from collection, then automatically deleted
• Email correspondence: retained for as long as necessary to respond to your enquiry, and for up to 5 years for legal compliance purposes
• Log data: retained for up to 90 days

7. Data Transfers

Some of our service providers (including Google) are based outside Switzerland and the European Economic Area. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission, or equivalent mechanisms recognised under the FADP.

8. Your Rights

Under the FADP and GDPR (where applicable), you have the following rights:

• Right of access: you may request a copy of the personal data we hold about you
• Right to rectification: you may request correction of inaccurate personal data
• Right to erasure: you may request deletion of your personal data in certain circumstances
• Right to restriction: you may request that we restrict processing of your data
• Right to object: you may object to processing based on legitimate interests
• Right to data portability: you may request your data in a structured, machine-readable format
• Right to withdraw consent: where processing is based on consent, you may withdraw consent at any time

To exercise any of these rights, contact us at [email protected].

If you are located in Switzerland, you may lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) at fdpic.ch. If you are located in the EEA, you may lodge a complaint with your local supervisory authority.

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include HTTPS encryption, access controls, and regular security reviews.

10. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The date of the most recent revision is shown at the top of this page. We encourage you to review this page periodically.

12. Contact

For privacy-related enquiries, contact:

The Vanderbilt Portfolio AG [email protected] Zurich, Switzerland