Privacy Policy

Last updated: 24 February 2026

This Privacy Policy describes how The Vanderbilt Portfolio AG (“we”, “us”, or “our”) collects, uses, and protects personal data when you visit zugeconomy.com (the “Site”). We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (FADP / nDSG, as revised effective 1 September 2023) and, where applicable, the European Union General Data Protection Regulation (GDPR).

1. Controller Identity

The Vanderbilt Portfolio AG Zurich, Switzerland

For data protection enquiries: [email protected]

2. Data We Collect

2.1 Data You Provide Voluntarily We do not operate registration or account systems. If you contact us by email, we receive your email address and any personal data included in your message. We use this data solely to respond to your enquiry.

2.2 Data Collected Automatically

When you visit the Site, the following data may be collected automatically:

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

This data is collected primarily through Google Analytics (see Section 4 below).

2.3 Advertising Data The Site uses Google Ad Manager to serve advertisements. Google Ad Manager may collect identifiers, cookie data, and behavioural data for the purposes of serving targeted advertising. See Section 5 below.

3. Legal Basis for Processing

Under the FADP and GDPR, we process personal data on the following legal bases:

Legitimate interests: website analytics and site improvement (Art. 6(1)(f) GDPR; Art. 31 FADP)
Consent: where we rely on consent (e.g. non-essential cookies), you may withdraw consent at any time via our cookie preference centre
Contract: if you contact us, processing your data is necessary to respond to your enquiry

4. Google Analytics

This Site uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Analytics uses cookies to collect information about how visitors use the Site. We use this information to compile statistical reports and to improve the Site. The information generated by the cookie (including an anonymised version of your IP address) is transmitted to and stored by Google on servers which may be located in the United States.

Google may transfer this data to third parties where required by law or where third parties process data on Google’s behalf.

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

Google’s privacy policy is available at: https://policies.google.com/privacy

IP Anonymisation: We have enabled IP anonymisation in Google Analytics, which means Google truncates IP addresses before storage.

5. Google Ad Manager

This Site uses Google Ad Manager (formerly DoubleClick for Publishers) to manage and serve advertising. Google Ad Manager is operated by Google Ireland Limited.

Google Ad Manager uses cookies and other tracking technologies to deliver advertisements relevant to your interests. Advertisers and Google may use data from your visit to this Site to serve ads on other websites you visit.

You can control personalised advertising settings through Google’s Ad Settings: https://adssettings.google.com

For more information, see Google’s privacy and terms: https://policies.google.com/technologies/ads

6. Cookies

We use cookies and similar tracking technologies. Please see our separate Cookie Policy for full details of the cookies we use and how to manage your preferences.

7. Data Retention

Analytics data: retained in Google Analytics for 26 months by default
Email correspondence: retained for as long as necessary to manage the correspondence, and no longer than 5 years thereafter
Server logs: retained for up to 90 days

8. Data Transfers Outside Switzerland / EEA

Some of our service providers (including Google) may process data outside Switzerland and the EEA, including in the United States. Where data is transferred internationally, we rely on appropriate safeguards including:

Standard Contractual Clauses approved by the European Commission
Swiss Federal Council adequacy decisions
Google’s adherence to the EU-US Data Privacy Framework

9. Your Rights

Under the Swiss FADP and GDPR (where applicable), you have the right to:

Access: request a copy of personal data we hold about you
Rectification: request correction of inaccurate data
Erasure: request deletion of your data in certain circumstances
Restriction: request restriction of processing in certain circumstances
Objection: object to processing based on legitimate interests
Portability: receive your data in a structured, machine-readable format
Withdraw consent: at any time where processing is based on consent

To exercise any of these rights, contact: [email protected]

You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at: https://www.edoeb.admin.ch

10. Third-Party Links

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

11. Children’s Privacy

The Site is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last updated. We encourage you to review this page periodically.

13. Contact

For privacy-related enquiries: [email protected]

The Vanderbilt Portfolio AG, Zurich, Switzerland