Website Privacy Notice

Brightside Capital SA ("Brightside", the "Company" or "we") understand that your personal data and your privacy is important to you.

The purpose of this Website Privacy Notice (the "Website Notice") is to inform data subjects ("you" or the "User") who access the website https://brightside-capital.com/ (the "Website") about how we collect, store, process and protect their personal data ("Data").

The Website Notice only applies to your use of the Website. For how we process data if you are a potential/actual client or a contractual partner/service provider, please refer to our Data Privacy Notice available at https://brightside-capital.com/data-privacy-notice/. The Website furthermore uses cookies. For more information, please refer to our Cookie policy available at https://brightside-capital.com/cookie-policy/.

1. Which Data we collect

The type of Data collected and processed by the Company depends on how you use the Website.

i. Use of the Website

Whenever you use the Website, we will gather the information that is forwarded to our servers based in Germany by your browser, notably the access data required for technical reasons to be able to display the Website and warrant its stability and security. This includes the IP address, the date and time of your visit, the access status/HTTP status code, the referrer URL, the browser used, etc.

ii. Newsletter

By registering for our newsletter, you consent to the sending of the newsletter and the associated processing of your personal data, as well as to other marketing activities such as invitations (the "Newsletter").

In connection with the Newsletter subscription, we collect your email address, first and last name, and optionally company name. In this framework, Brightside uses Mailchimp, which is a service from The Rocket Science Group in the United States of America to organize and analyze the distribution of newsletters. The Rocker Science Group store the data in the United States of America. By registering for the Newsletter, you consent to the information you provide being transmitted to our service provider for processing in accordance with its own privacy policy.

You can unsubscribe at any time via a link in each newsletter and/or by sending an email to info@brightside-capital.com. Data collected in the framework of the Newsletter subscription will be stored for as long as you subscribe to the Newsletter. It will be deleted if you unsubscribe to the Newsletter.

iii. Contact by email, phone or by the contact form

You can contact Brightside by email, phone or by using the contact form available on the Website. The contact form is being generated by Contact Form 7 which is a form creation and management service provided for by Rock Lobster LLC, a Japan-based company. The contact form will collect your email and name as well as all information you provide it, which will be processed in Japan (see https://contactform7.com/privacy-policy/).

Regarding any contact by email, phone or through the contact form, in addition to the elements mentioned under Chapter 1.i, we will receive the personal information you voluntarily provide us in your communication, for instance your name, address, email, telephone number, date and time of the request and content of your request. The emails you send us are stored in our servers in Switzerland.

iv. Commentary on the content

Commenting services allow you to formulate and make public your comments regarding the blog. You are responsible for the content of your comments. In the event that a comment service provided by third parties is installed on the Website, it is possible that, even if you do not use the comment service, it collects traffic data relating to the pages in which the comment service is installed.

v. Statistics

The statistics services allow Brightside to monitor and analyze traffic data on the Website. They are used to keep track of the user of the Website behavior. The Website uses the following services:

1. Google Analytics (Google Ireland Limited)

Google Analytics is an analysis service provided by Google Ireland Limited. Google uses the Personal Data collected for the purpose of tracking and examining the use of the Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. Google may also transfer this information to third parties where this is required by law or where such third parties process the aforementioned information on behalf of Google. The IP address anonymization function is active on the Website. The IP address transmitted by the browser for purposes related to Google Analytics will not be incorporated into other data already held by Google.

The browser add-on for deactivating Google Analytics is made available by Google at the following link . Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy

2. Facebook Pixel Conversion Tracking (Facebook Ireland Ltd.)

Facebook conversion tracking (Facebook pixel) is a statistics service provided by Facebook. The Facebook pixel tracks conversions that can be attributed to Facebook ads. Personal Data collected: Cookies; Usage data. Place of processing: Ireland – Privacy Policy

vi. Interaction with social networks

These services allow you to interact with social networks directly from the pages of the Website. The interactions and information acquired from the Website are in any case subject to the User's privacy settings relating to each social network. If an interaction service with social networks is installed on the Website, it is possible that, even if you do not use the service, it collects traffic data relating to the pages on which it is installed.

1. Facebook (Facebook Ireland Ltd.)

Facebook buttons are interaction services with the Facebook social network, provided by Facebook Ireland Ltd. Personal Data collected: Cookies and Usage data. Place of processing: Ireland – Privacy Policy

2. LinkedIn (LinkedIn Ireland Unlimited Company)

LinkedIn buttons are interaction services with the LinkedIn social network, provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy

3. Twitter (Twitter International Company)

The Twitter buttons are interaction services with the Twitter social network, provided by Twitter, Inc. Personal Data collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy

vii. Remarketing and retargeting

These services allow the Website to communicate, optimize and serve advertisements based on the User's past use of the Website. This activity is carried out through the tracking of Usage Data and the use of Cookies. The Website uses the following services:

1. Facebook Remarketing (Facebook Ireland Ltd)

Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, which connects the activity of the Website with the Facebook advertising network. The Website uses the Facebook Pixel tool to measure conversions. Thanks to the Facebook Pixel, it is possible to understand the actions that people perform on the Website. The data collected can be used to:

  • ensure that adverts are shown to the right people;
  • create audience groups to target with adverts;
  • take advantage of the additional advertising tools of the platform on which you advertise.

The information collected is anonymous and cannot be used to identify the identity of an individual user. However, the information is saved and analyzed by Facebook, which may link the action to an individual profile and use this information for Facebook's internal advertising purposes, as outlined in Facebook's privacy policy. This will allow Facebook to show ads both on Facebook and on third-party sites. Brightside has no control over how this data is used. For more information on how users can protect their privacy, please refer to Facebook's privacy policy.

2. Insight Tag LinkedIn (LinkedIn Ireland Unlimited Company)

The Website uses a script called “LinkedIn Insight Tag”. The LinkedIn Insight Tag adds a cookie to Users' browsers each time they visit the Website. Thanks to this tool, Brightside can record when a LinkedIn member carries out a certain action on the Website (such as booking a service or leaving an email). This tool is used to collect statistical data that helps measure the effectiveness of paid advertising. Thanks to the LinkedIn Insight Tag it is possible to understand the actions that people perform on the Website.

The Data collected is used to:

  • ensure that adverts are shown to the right people;
  • create audience groups to target with adverts;
  • take advantage of the additional advertising tools of the platform on which you advertise.

The Website uses the LinkedIn Insight Tag to carry out "remarketing" and "Retargeting" activities; thanks to these activities, the cookies that the User leaves on the Website are used, without however identifying him. Personal Data collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy:

3. Twitter ADS (Twitter International Company)

Twitter Ads is an advertising service offered by Twitter International Company. Twitter Ads allows advertisers to purchase promoted tweets to reach a specific target of users, identified on the basis of the specific products/services offered by the advertiser. Personal Data collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy.

viii. Content on external platforms

These services allow you to view content hosted on external platforms directly from the pages of the Website and interact with them. If a service of this type is installed, it is possible that, even if you do not use the service, it collects traffic data relating to the pages on which it is installed. The Website uses:

1. Youtube (Google Ireland Limited)

Youtube is a video content viewing service managed by Google that allows the Website to integrate such content within its pages. Personal Data collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy.

2. Why we process the Data

We may process the Data for the following reasons:

  • to provide you with access to the Website;
  • to be able to manage, secure, stabilize, develop and optimize the Website;
  • to carry out statistical and other analysis regarding the use of the Website;
  • to process your request, if you contact us using the contact form of the Website;
  • to send you the Newsletter if you subscribe to it;
  • to reply to your email/to any request submitted by you;
  • to comply with any applicable laws and regulations;
  • to comply with the request or requirement of any court of any relevant jurisdiction or any relevant authority; and
  • for use in connection with any legal proceedings or regulatory action (including prospective legal proceedings/ regulatory action) and for obtaining legal advice or for establishing, exercising or defending legal rights.

3. How we store and protect the Data

Brightside only stores the Data for as long as necessary for the purposes described under Chapter 2 above and/or for as long as it has your permission to keep it, or if otherwise required by law.

Data will only be stored in our physical server/cloud located in Germany. We have taken the appropriate technical and organizational precautions to ensure that our servers are accessible exclusively to duly authorized persons. We have taken suitable technical measures to safeguard the Data.

4. Your rights

You may exercise the following rights with respect to the Data:

  • right to information – you can ask Brightside if it processes Data about you;
  • right to access Data – you can ask Brightside to provide you with a copy of the Data it processes;
  • right to request the rectification of Data – you can ask Brightside to correct the Data if it is inaccurate;
  • right to request the deletion of Data - you can ask Brightside to delete the Data, subject to the Company being under a legal obligation to retain the Data or subject to Brightside having a legitimate interest to retain the Data;
  • right to request a limitation of the processing of Data – you can ask Brightside to temporally restrict or to limit the processing of the Data, subject to any potential applicable legal provisions;
  • right to request a prohibition on the processing of Data – you can ask Brightside to stop the process of the Data, subject to any potential applicable legal provisions;
  • right to withdraw your consent to the processing of Data – you can inform Brightside that you revoke your consent, to the extent that you have given said consent to any specific purpose of processing the Data. The withdrawal of your consent will not affect the lawfulness of any processing of Data carried out before said withdrawal/carried out based on another grounds for justification.

The exercise of any right set forth in this Chapter 4 shall be carried out as per the modalities provided for in Chapter 7. It may be refused or limited for legal reasons or based on the applicable data protection law. Brightside will inform you of the reasons for such refusal/restriction to the extent permitted by law.

5. Recipients of your Data

We may disclose Data in the situations described below:

  • to third parties who provide services to us (e.g. IT companies);
  • to public authorities, regulators or governmental bodies or other third parties, when required by law or regulation; or
  • otherwise if you consent to such disclosure.

We do not sell the Data.

6. Transfer of Data abroad

We may transfer the Data we collect to countries other than the country in which the information was originally collected.

Your Data might/will be transferred to or made accessible from the following countries:

  • Switzerland;
  • Countries within the EEA;
  • United States of America;
  • Singapore;

These destination countries may not have the same laws on personal information as the country in which you initially provided the information through the Website.

When we transfer your Data to other countries, we will protect that information as described in the Website Notice and in accordance with applicable law. If necessary, we require the recipients referred to in Chapter 5 above to comply with appropriate safeguards designed to protect personal information.

7. Communications

In case of questions about the Website, the Website Notice or more generally about data protection, please contact us by email at info@brightside-capital.com.

If we are unable to assist you, if you are not satisfied with our answer or if you believe that our processing of the Data is in contradiction with the applicable legal provisions, you can contact the Swiss Federal Data Protection and Information Officer and/or with any competent EU supervisory authority if applicable based on your place of residence.

8. Amendments

The Website Notice does not form part of any contract/contractual relation between you and Brightside and your consent to the Website Notice is not required. We may revise the Website Notice unilaterally at any time without prior notice. Any change will be immediately posted on the Website. The current version of the Website Notice available on the Website https://brightside-capital.com/privacy-policy/ shall apply. It is therefore recommended to consult the Website Notice regularly.