1 March 2026
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ZUG DLT
The Vanderbilt Terminal for Distributed Ledger Technology
INDEPENDENT INTELLIGENCE FOR SWITZERLAND'S DLT ECOSYSTEM
DLT Securities Issued CHF 500M+| SDX Participants 25+| Swiss DLT Firms 1,200+| Project Helvetia Active| FINMA DLT Licences 2+| DLT Act Aug 2021| DLT Securities Issued CHF 500M+| SDX Participants 25+| Swiss DLT Firms 1,200+| Project Helvetia Active| FINMA DLT Licences 2+| DLT Act Aug 2021|

Privacy Policy

Effective date: 1 February 2026 Last updated: 24 February 2026

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

1. Data Controller

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

2. Data We Collect

2.1 Data You Provide Directly

When you contact us by email, we collect your email address and any personal data you include in your message. We use this data solely to respond to your inquiry and do not use it for marketing without your explicit consent.

2.2 Data Collected Automatically

Analytics data (Google Analytics) We use Google Analytics to understand how visitors use our Site. Google Analytics collects data including your IP address (anonymised), browser type, operating system, pages visited, time on site, and referral source. This data is processed by Google LLC and is subject to Google’s Privacy Policy. We have enabled IP anonymisation. Data is retained for 14 months.

Google Analytics data is processed on the basis of our legitimate interest in understanding Site usage and improving editorial content (Swiss FADP Art. 31; GDPR Art. 6(1)(f)).

Advertising data (Google Ad Manager) We use Google Ad Manager to display advertisements. Google Ad Manager and its partners may collect data about your device, browser, and browsing behaviour to serve relevant advertisements. This may involve the use of cookies and device identifiers. You can opt out of personalised advertising via Google’s ad settings at adssettings.google.com.

Advertising data is processed on the basis of your consent, where required by applicable law, or our legitimate interest in funding editorial operations.

Server logs Our hosting infrastructure automatically records standard server log data including IP addresses, request timestamps, pages requested, and HTTP status codes. Server logs are retained for 30 days and used solely for security and operational purposes.

3. Cookies

We use cookies and similar tracking technologies. For full details, see our Cookie Policy. You can control cookies through your browser settings or our cookie consent tool.

4. How We Use Your Data

We use personal data to:

  • Deliver and improve the editorial content of the Site
  • Analyse Site traffic and user behaviour (via Google Analytics)
  • Serve and measure advertising (via Google Ad Manager)
  • Respond to your inquiries
  • Comply with legal obligations

5. Data Sharing

We do not sell your personal data. We share data only with:

  • Google LLC — for analytics (Google Analytics) and advertising (Google Ad Manager) services, under data processing agreements compliant with Swiss and EU data protection law
  • Hosting providers — who process server log data under data processing agreements
  • Legal authorities — where required by applicable Swiss law or court order

6. International Data Transfers

Google LLC is based in the United States. Where personal data is transferred to the US, such transfers are protected by the EU-US Data Privacy Framework or Standard Contractual Clauses approved by the European Commission and recognised under Swiss law.

7. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy or as required by law:

  • Email correspondence: 3 years
  • Google Analytics data: 14 months (as configured)
  • Server logs: 30 days

8. Your Rights

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

  • Access your personal data
  • Rectify inaccurate data
  • Request erasure of your data
  • Restrict processing of your data
  • Object to processing based on legitimate interests
  • Data portability (where processing is automated and consent-based)
  • Lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch

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

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, including HTTPS encryption for all Site traffic.

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

11. Children

The Site is not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, contact us at [email protected].

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page indicates when the most recent changes were made. Continued use of the Site after changes constitutes acceptance of the revised policy.

13. Contact

Questions about this Privacy Policy: [email protected]

The Vanderbilt Portfolio AG, Zurich, Switzerland.