Housecat’s Privacy Policy

Last updated: March 7, 2022

Housecat AG, a corporation organized and existing under the laws of Switzerland with registered offices at Baarerstrasse 10, 6300 Zug, Switzerland (hereinafter "Housecat" or "we" or “us”) as the operator of this website (hereinafter the “Website”) and the operator of the Housecat online platform (hereinafter the “Platform”) and the respective app (hereinafter the “App”) takes the protection of your personal data very seriously. The purpose of this privacy policy (hereinafter the “Privacy Policy”) is to inform you (hereinafter “you” or “User”) about how we collect, process and use your Personal Data.

This Privacy Policy is applicable between you as User of our Website/Platform/App and Housecat, owner and publisher of the Website and owner and operator of the Platform/App. This Privacy Policy applies to the use of any personal data we collect or that you provide to us in connection with your use of our Website/Platform/App. In this context we process Personal Data of various Users. Housecat obtains Personal Data about you from various sources. You may be a visitor to one of our Websites or a User of one or more of our Services (as defined below) This Privacy Policy applies to all use of the Website/Platform/App and any other dealings between Housecat and its Users and any services provided by Housecat (all of these: use, dealings and services are defined hereinafter as the “Services”).

In case you provide us with Personal Data of third persons, You should make sure that these persons are familiar with this Privacy Policy and you should only share their Personal Data if you have permission to do so and have ensured that this Personal Data is correct.

We can assure you that we comply with the Swiss Federal Act on Data Protection, the Swiss Ordinance to the Federal Act on Data Protection, and the European General Data Protection Regulation (hereinafter the “GDPR”) and that we process your Data lawfully, fairly and transparently.

If you are younger than 18 years old, you are not allowed to use our Website/Platform/App without the permission of your parents or legal guardian.

We take confidentiality and privacy issues very seriously. We therefore ensure that your personal information is secure; we communicate our privacy and security guidelines and practices to all our employees and service providers and strictly enforce privacy safeguards within our company.

1. Definitions and Interpretation

In this Privacy Policy, the following definitions are used

Data: all information that you submit to us via our Website/Platform/App.

Personal Data: all information making you directly or indirectly identifiable (e.g. your name, first name, address, phone number or email address but also the IP address of your computer, for example, or the information relating to your browsing of our Website).

Cookies: A small text file placed on your computer by our Website when you visit certain parts of our Website and/or when you use certain features of the Website. Please refer to the Cookie Policy for more information.

Data Controller: The processing of any Personal Data provided or collected on the Website/Platform/App is carried out under the supervision of Housecat AG, Baarerstrasse 10, 6300 Zug, E-Mail: hello@housecat.com

GDPR: The "General Data Protection Regulation" (EU Regulation 2016/679), as well as any national legislation adopted in accordance therewith.

Website: The Website: www.housecat.com and all subdomains of this Website, unless they are expressly excluded from the scope of this Privacy Policy by their own terms and conditions.

In this Privacy Policy, unless the context requires a different interpretation

2. Scope of This Privacy Policy

This Privacy Policy applies only to the actions of Housecat and of Users with respect to our Website and our Platform/App. It does not extend to websites that can be accessed from our Website and/or Platform/App, including, but not limited to, any links we may provide to social media websites.

3. Responsible Person / Contact Details

Responsible for the Personal Data collected is our data protection officer with business address at Baarerstrasse 10, 6300 Zug, Switzerland (hereinafter the “Responsible Person”). For any matters relating to data protection you may contact hello@housecat.com by e-mail or by letter to the following address:

Housecat AG
Baarestrasse 10
6300 Zug
Switzerland

Representative in the EU according to article 27 GDPR is: Ville Vesterinen, with business address in Baarerstrasse 10, 6300 Zug. For any matters relating to data protection you may contact by e-mail hello@housecat.com, or by letter to the following address:

Housecat AG
Baarestrasse 10
6300 Zug
Switzerland

4. Data Processing in Connection With Our Website and Platform/App

General data and Information resulting from your activity on our Website

We receive and store certain types of information every time you visit our Website. For example, like many websites, we use Cookies and we obtain certain types of information when your Web browser accesses our Website and other content provided by or on behalf of Housecat on other websites. We may, therefore, also collect the following technical Data from you:

The collection and processing of this technical data is for the purpose of

This is our legitimate interest in the processing of Data in the sense of Art. 6 Par. 1 lit. f. GDPR.

General data and Information resulting from your activity on our Platform/App

In the context of our relationship, you may need to provide certain Personal Data that is required for accepting and carrying out a business relationship, fulfilling contractual obligations or that we are legally obliged to collect. Without this data, we may not be in a position to enter into a legal agreement, provide services, or initiate or maintain a business relationship.

Data we collect of all Users that register on the Platform/App and/or use the Platform/App:

(Personal) DataPurposes of processing
The types of Personal Data we process may include:
  • personal details relating to you (name, date and place of birth, nationality, gender, domicile)
  • contact details, including private and / or business phone numbers, postal and email addresses
  • identification data such as passports, National Insurance or Social Security numbers, driving licence, ID cards, social network user names, customer identifiers (CIF, IBAN / BIC), relationship identifiers (e.g. client segment and account currency), photographs
  • marital status, name of spouse, number of children (if applicable)
  • tax status (e.g. tax ID)
  • order data (e.g. payment data and account information)
  • data from the fulfilment of our contractual obligations
  • information about your financial situation (e.g. source of wealth, incomes, benefits, mortgage information, shareholdings)
  • video and telephone / audio recordings
  • data relating to criminal convictions and offences (including excerpts of criminal register)
  • data related to designation of your status as a politically exposed person (PEP) and related information
  • marketing and sales data (e.g. customer relationship documentation)
  • data relating to your habits and preferences
  • data from your interactions with us, our internet websites, our apps, our social media pages, meetings, calls, chats, emails, interviews and phone conversations
  • documentation data (e.g. file notes or meeting minutes from a consultation, client needs and product usage)
  • data relating to your current and past professional roles and employment, and education (e.g. corporate title, membership of professional associations or bodies, career histories or biographies, job function, knowledge and experience in investment matters, qualifications and skills)
  • other data similar to the broad categories mentioned above.
Due to legal obligations:
  • identity checks, fraud and financial crime and market abuse prevention or detection. If a potential fraud is detected, any person connected to it or you could be refused certain or all services.
  • fulfilling control and reporting obligations under applicable financial regulations including, without limitation, securities and financial crime regulations
  • fulfilling requirements related to our licences and regulatory permissions
  • complying with regulatory record keeping obligations
  • complying with regulatory obligations in relation to measuring and managing relevant risks

For purposes of legitimate business and other interests pursued by us or a third party (including sharing of data) in:

  • carrying on business relationships with clients and other parties
  • providing services to clients
  • validating the authority of signatories (e.g. when concluding agreements and transactions)
  • performing obligations and exercising rights under and otherwise carrying out contracts, or taking pre-contractual measures (If you are our client, the level and nature of processing of your personal data that we may carry out pursuant to this paragraph will likely depend on the specific product or service to be provided to you and can include needs assessments and other assessments to provide advice and support to you, as well as to carry out transactions contemplated in, or necessary to fulfil, such legal agreement).
  • consulting with credit rating agencies to investigate creditworthiness and credit risks where we may have an exposure to you
  • developing, deploying and supporting our products and services
  • developing and furthering our business and business relationships, and keeping our clients and other stakeholders satisfied
  • reviewing and optimizing procedures for needs assessment for the purpose of direct client discussions
  • marketing or market and opinion research
  • protecting our businesses and the integrity of the relevant markets
  • obtaining Personal Data from publicly available sources for client acquisition purposes
  • compliance with licencing, permission and / or licencing exemption requirements and regulatory requests or guidance related to such licences, permissions or exemptions
  • due diligence
  • facilitation of and responding to, regulatory requests and supervisory visits, and otherwise acting in open and collaborative manner with competent regulatory authorities
  • prevention of and investigations related to financial crime, including fraud, financing of terrorism and money laundering, and compliance with sanctions, including know your customer (KYC) and regular politically exposed persons (PEP) screening
  • asserting legal claims and defences in legal disputes
  • carrying out conflict checks
  • handling client complaints
  • managing risk and securing our systems, assets, infrastructure and premises
  • asserting legal claims and defences in legal disputes
Social media data
Information you make public, when you leave a comment or otherwise post something on our social media channels.
We use this data to:
  • verify the authenticity of the data, which you provided to us, its compliance with our Terms & Conditions and with all applicable regulatory and legal requirements in any relevant jurisdiction.
  • contact you via our social media channels;
  • process your feedback left on our social media channels.

Please note: Our social media channels are also controlled by the social medium itself. Please check their own privacy policies, to see how each social medium processes Personal Data. We use these data because we have a legitimate interest to process these data in order to provide a good functioning Platform.

This is our legitimate interest in the processing of Data in the sense of Art. 6 Par. 1 lit. f. GDPR.

Contact Possibility via the Website and/or the Platform/App

The Website/Platform/App may contain a contact form that enables a quick electronic contact to Housecat, as well as direct communication with us, which also includes a general address of the e-mail address. If you contact us by e-mail or via contact form, the Personal Data transmitted by you is automatically stored.

Such Personal Data, transmitted on a voluntary basis by you to us, is stored for the purpose of processing or contacting you and to handle your request and provide you the service or support you requested. The legal basis for the data processing for these purposes lies in the fulfilment of an agreement in accordance with Art. 6 Par. 1 lit. b GDPR and you have provided consent in accordance with Art. 6 Par. 1 lit. a GDPR.

Use of Website Cookies

The Website uses cookies. Cookies are text files that are stored in a computer system via an Internet browser. For further information, visit https://www.allaboutcookies.org/.

When you visit our Website, we may collect information from you automatically through cookies. Through the use of cookies, Housecat can provide the users of the Website with more user-friendly services that would not be possible without the cookie setting.

You may prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, previously set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you deactivate the setting of cookies in the Internet Browser used, it may not be possible to use all the functions of our Website.

If you do not agree to our use of cookies, you should set your browser settings accordingly as described above or not use our Website. By continuing to use our Website without changing your settings, you are agreeing to our use of cookies and the terms with regard to cookies of this Privacy Policy.

Two types of cookies may be used on the Website - "session cookies" and "persistent cookies". Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie and your browser settings).

The table below summarizes the different types of cookies we use on the Website, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).

Cookies used on the Website:

Type of CookieWhat do they do?Do these cookies collect my personal data / identify me?
Necessary CookiesCookies that are essential to making the Website work correctly. They enable visitors to move around our Website and use our features. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session.These cookies do not identify you as an individual. If you do not accept these cookies, it may affect the performance of our Site.
Performance CookiesCookies that help us understand how visitors interact with our web properties by providing information about the areas visited, the time spent on the Site and any issues encountered, such as error messages. They help us improve the performance of our Website, alert of any concerns and more.These cookies don’t identify you as an individual. All data is collected and aggregated anonymously.
Functionality CookiesCookies that allow our web properties to remember the choices you make (such as your user name, language or the region you are in) to provide a more personalized online experience.The information these cookies collect may include personally identifiable information that you have disclosed, such as a username, for example. We shall always be transparent with you about what information we collect, what we do with it and with whom we share it. If you do not accept these cookies, it may affect site performance and functionality and may restrict access to web content.
Targeting/Advertising CookiesCookies that are used to deliver content, which is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They also help us measure the effectiveness of advertising campaigns on the Site. Among other others the following services are used: Facebook Pixel; Facebook SDK; Google Analytics These services also use cookies. Information about the use of the website generated by cookies (such as web browser and version used, IP address) is transmitted to servers in the United States and stored there. In general, the IP-address is anonymized when transferred to servers in the United States. Exceptionally however the full IP-address may be transferred to servers in the United States.Most types of these cookies track consumers via their IP address so will collect some personal data. Your dates, sessions and interactions can be allocated across several devices to one pseudonymous user ID and therefore analyse the activities of a user on several devices by the correspondent web analysis services and the companies who provide these services. The information sent to the companies through this analysis service permits the anonymous evaluation of the use of our Website as well as the establishment of reports on the Website activities.

5. Retention of Personal Data

The retention period of Personal Data processed by Housecat may vary depending on common practice, and considered in accordance with the legal obligations and the applicable limitation rules. In any case, Housecat will process and store the Personal Data only for the period necessary to achieve the purpose of storage or as far as this is granted by the applicable laws or regulations.

If the storage purpose is not applicable any more, or if the storage period prescribed by the applicable laws and regulations expires, the Personal Data is routinely erased in accordance with legal hold requirements.

6. Personal Data Security

Personal Data security is of great importance to Housecat. In order to protect your Personal Data, we have implemented appropriate physical, electronic and organizational procedures to safeguard and secure the Personal Data collected via our Website/Platform/App in order to ensure its integrity and confidentiality. Our security measures are continuously being improved in line with technical developments. All Personal Data is securely stored in accordance with industry standards and the Swiss Federal Act on Data Protection, the Swiss Ordinance to the Federal Act on Data Protection and the GDPR.

If a password is required to access certain sections of our Website/Platform/App, you are responsible for keeping this password confidential.

We endeavor to do all we can to protect your Personal Data. However, the transmission of information on the Internet is not fully secure and remains your sole responsibility. We cannot ensure the security and accept no liability of the transmission of your Data to our Website/Platform/App.

7. Other Parties Who Have Access to Information We Collect

With the exceptions described in this section, we do not make your Personal Data available to third parties unless you have expressly consented to it, if we are legally obligated to, or if this is necessary to enforce our rights concerning a contractual relationship.

We may grant access to Personal Data about you:

In principle, we process your Data in Switzerland. In case it is necessary to transfer your Data to third parties outside Switzerland and the EU, the Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the Swiss and European standards.

If the level of data protection in a country where a service provider is located does not correspond to the Swiss and European data protection level, we contractually ensure that the protection of your Personal Data corresponds to that in Switzerland and the EU at all times, by concluding agreements using the standard contractual clauses complying with the GDPR. You understand that the data protection legislation in such other countries may not give you as much protection as the data protection legislation in the country where you are located.

All Personal Data used by these third parties is solely used for the purposes of the services provided at your request. Any use for other purposes is strictly prohibited. In addition, any Personal Data processed by third parties will be in accordance with the terms of this Privacy Policy and in compliance with the Swiss Federal Act on Data Protection and the GDPR. The third party providers we use will only collect and use your information to the extent necessary to enable them to perform the services they provide to us.

8. Links to Other Websites

Our Website/Platform/App may, from time to time, provide links to other websites. When you activate them (by clicking on them), the operators of the respective website may record that you are on our Website and may use this information. We have no control over such websites and we are not responsible for their content. The processing of your Personal Data then lies in the responsibility of the individuals of these websites and occurs according to their privacy policy. This Privacy Policy does not extend to the use of such websites. We advise you to read the privacy policy applicable to such other websites before using them.

9. Your Rights Regarding Your Personal Data

Please note that some of the rights mentioned below are subject to limitations in some situations, and that the exercise of these rights may affect, restrain or render impossible our ability to continue a business relationship with you.

Right to confirmation

You have the right to obtain confirmation from Housecat as to whether or not Personal Data concerning you is being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact the Responsible Person as stated in section 3 of this Privacy Policy.

Right to access

You have the right to obtain free information from Housecat about your Personal Data stored at any time, and a copy of this information. Furthermore, you will have access to the following information:

If you wish to avail yourself of this right of access, you may at any time contact the Responsible Person as stated in section 3 of this Privacy Policy.

Right to rectification

You have the right to obtain from Housecat, without undue delay, the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

If you wish to exercise this right to rectification, you may, at any time, contact the Responsible Person as stated in section 3 of this Privacy Policy.

Right to erasure (right to be forgotten)

You have the right to request from Housecat the erasure of Personal Data concerning you as soon as possible, and Housecat shall have the obligation to erase Personal Data without undue delay where one of the following grounds applies:

Right to restriction of processing

You have the right to obtain the restriction of processing from Housecat where one of the following applies:

If any one of the aforementioned conditions is met, and you wish to request the restriction of the processing of Personal Data stored by Housecat, you may at any time contact Housecat’s Responsible Person. The Responsible Person will arrange the restriction of the processing.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time, to the processing of Personal Data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Housecat shall no longer process the Personal Data in the event of the objection, unless Housecat can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defense of legal claims. In order to exercise the right to object, you may directly contact the Responsible Person.

Right to data portability

You have the right to receive the Personal Data concerning you, which was provided to Housecat, in a structured, commonly used and machine-readable format. You shall have the right to transmit those data to another controller without hindrance from Housecat to which the Personal Data has been provided, as long as the processing is based on consent, pursuant to article 6 (1) GDPR or point (a) of article 9 (2) GDPR, or on a contract pursuant to point (b) of article 6 (1) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest.

Furthermore, in exercising your right to data portability pursuant to article 20 (1) GDPR, you shall have the right to have Personal Data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, you may at any time contact the Responsible Person according to section 3.

Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between you and Housecat, or (2) is not authorized by the applicable law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.

Due to legal and regulatory requirements, we are required to combat money laundering, terrorism financing, fraud and assess risks and offences that pose a danger to assets. Automatized Data assessments (including on payment transactions) are also carried out for this purpose. At the same time, these measures also serve to protect you.

Furthermore, we use assessment tools in order to be able to specifically notify you and advise you about our products. These allow communications and marketing to be tailored as needed, including market and opinion research.

If the decision (1) is necessary for entering into, or the performance of, a contract between you and Housecat, or (2) it is based on your explicit consent, Housecat shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.

If you wish to exercise the rights concerning automated individual decision-making, you may, at any time, contact the Responsible Person.

Right to withdraw data protection consent

You have the right to withdraw your consent to processing of your Personal Data at any time.

If you wish to exercise the right to withdraw the consent, you may at any time directly contact the Responsible Person as stated in section 3.

Manifestly unfounded or excessive use of rights

While the exercise of any individual rights mentioned above will be free of charge, a reasonable fee may be exceptionally charged if such requests are manifestly unfounded or excessive. Housecat may refuse to comply with the request under such circumstances.

10. Miscellaneous

If a court or competent authority considers that any provision of this Privacy Policy (or any part thereof) is invalid, illegal or unenforceable, that provision or relevant part of the provision will, to the extent required, be deemed to be deleted. The validity and enforceability of the other provisions of this Privacy Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising a right or remedy will be deemed a waiver of such right, or of another right or remedy.

This Privacy Policy will be governed by and interpreted according to Swiss law. Any dispute arising out of this Privacy Policy will be subject to the exclusive jurisdiction of the ordinary courts in Zug, Switzerland.

Changes to This Privacy Policy

We reserve the right to make changes to this Privacy Policy as we deem necessary from time to time or as may be required by law. All changes will be posted immediately on our Website/Platform/App and you are deemed to have accepted the new terms of the Privacy Policy when you first use the Website/Platform/App after such changes. Always the current version of the Privacy Policy, as published on our Website/Platform/App, is applicable.

If our company is the subject of a corporate transaction such as an acquisition or merger with another company, your information may be transferred to the new owners so that we can continue to sell our products to you.

More Information About Privacy Regulations

Please do not hesitate to contact us if you have any questions regarding this Privacy Policy by contacting us at hello@housecat.com