Privacy Policy of SquaredData AG
Version effective as of 26 May 2026
With this Privacy Policy we, SquaredData AG, Weissenrainstrasse 28, 8707 Uetikon am See, Switzerland (hereinafter SquaredData, we or us), describe how we collect and further process personal data.
The term "personal data" in this Privacy Policy shall mean any information that identifies or could reasonably be used to identify any person.
If you provide us with personal data of other persons (such as employees, end clients, family members, work colleagues), please make sure the respective persons are aware of this Privacy Policy and only provide us with their data if you are allowed to do so and such personal data is correct.
This Privacy Policy is aligned with the EU General Data Protection Regulation ("GDPR") and the Swiss Data Protection Act ("DPA"). However, the application of these laws depends on each individual case.
1. Controller / Data Protection Officer / Representative
The "controller" of data processing as described in this Privacy Policy (i.e. the responsible person) is SquaredData. You can notify us of any data protection related matters using the following contact details: Weissenrainstrasse 28, 8707 Uetikon am See, Switzerland or info@etfbook.com.
2. Collection and Processing of Personal Data
We primarily process the following personal data that we obtain from our clients/users and other business partners as well as other individuals in the context of our business relationships with them or that we collect from clients/users when operating our platform, websites (in particular www.etfbook.com) and applications in the field of ETF data analytics ("Platform"):
full name (first name, middle name, last name and gender);
address;
email address;
telephone and/or mobile number;
other user account, authentication and subscription-related information, including login credentials, account preferences, user identifiers and subscription status;
further personal data you may provide or upload in your discretion.
Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data (also see cookies Section 4 below).
3. Purpose of Data Processing and Legal Grounds
We primarily use collected personal data in order to conclude, process and fulfill contracts with our clients/users and business partners, in particular in connection with providing consulting and online Platform solutions in the field of data analytics (in particular flow and performance analytics of ETFs and respective screening and reporting) and related software, products or services, as well as in order to comply with our domestic and foreign legal and regulatory obligations. You may also be affected by our data processing in your capacity as an employee of such a client/user or business partner.
In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:
offer, provide, develop and improve our Platform services;
review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
market and opinion research;
internal reporting, analytics, business planning, audit, governance, risk management and administrative purposes;
asserting legal claims and defense in legal disputes and official proceedings;
prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
ensuring the functionality of our operation, including our IT, our websites, software (including the Platform) and other appliances;
analysis of user behavior and interactions with our Platform, including through analytics, diagnostics and profiling tools, in order to improve the feasibility, usability, desirability, functionality, performance and user experience of our Platform and services, as well as for debugging, troubleshooting, bug simulation, feature development and security purposes;
acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of SquaredData.
If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.
4. Cookies, Analytics and Similar Technologies
We use cookies and similar technologies on our websites and software applications (including the Platform) to ensure functionality, improve security and performance, analyze usage and, where permitted, personalize content and communications. Cookies are small files stored on your device that allow your browser or device to be recognized upon a subsequent visit.
We may use session cookies, which are deleted once you leave the Platform, and permanent cookies, which remain stored on your device for a defined period of time. You may configure your browser settings to refuse, restrict or delete cookies at any time. Please note that disabling cookies may affect the functionality of the Platform.
Subject to applicable law, our newsletters and marketing communications may contain tracking technologies (e.g. tracking pixels) that allow us to measure user engagement and improve our communications. You may disable such technologies through your e-mail settings.
We may use analytics and related services provided by third parties, including Google Analytics, Microsoft Clarity and Microsoft Application Insights (AppInsights), or comparable services. Such providers may process technical and usage-related information, including IP addresses, device and browser information, interaction data, navigation behavior and performance data, including on servers located outside Switzerland and the European Economic Area (EEA).
These services help us analyze, maintain, secure and improve the functionality, performance and user experience of the Platform. We generally receive aggregated or non-directly identifying information regarding the use of the Platform. In certain circumstances, however, the respective providers may be able to associate collected information with specific users in accordance with their own privacy notices.
Where required under applicable law, such processing is based on your consent. In all other cases, it is based on our legitimate interests in operating, securing and improving the Platform and our services.
5. Datatransfer and Transfer of Data Abroad
In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:
our service providers and subcontractors, including processors (e.g. IT providers, cloud storage providers, third-party payment providers, third-party analytics services providers);
domestic and foreign authorities or courts;
acquirers or parties interested in the acquisition of SquaredData or business divisions or other parts of SquaredData;
other parties in possible or pending legal proceedings;
affiliates of SquaredData;
together Recipients.
Certain Recipients may be within Switzerland, but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to countries of the EU, EFTA and/or EEA, the UK and the USA where some of our service providers are located (such as cloud computing/storage providers).
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with appropriate data protection standards (for this purpose, we use the revised European Commission's standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules (like the Swiss-U.S. Data Privacy Framework or the EU-U.S. Data Privacy Framework) to ensure data protection, unless we can rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing. You acknowledge that data transferred to countries outside Switzerland, the EU, EFTA and/or the EEA, in particular to the USA, may be subject to access by foreign authorities in accordance with applicable local laws.
6. Retention Periods for your Personal Data
We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g. for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g. system logs).
7. Data Security
We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, inspections. However, no method of transmission over the Internet or electronic storage is completely secure and we cannot guarantee absolute security.
8. Obligation to Provide Personal Data To Us
In the context of our business relationship you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the Platform cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).
9. Profiling and Automated Individual Decision-Making
We may process your personal data, including through automated means, in order to evaluate certain personal aspects relating to your use of the Platform (profiling). In particular, we may use profiling, analytics and behavioral analysis tools to better understand how users interact with the Platform, to improve functionality, performance, usability and user experience, to diagnose technical issues, and to develop and optimize features, products and services. Such processing may include the analysis of usage patterns, navigation behavior, interactions with Platform features and related technical telemetry data. We may also use such tools to provide information, functionalities, applications, features or tools that may be relevant to users.
In establishing and carrying out a business relationship, we generally do not use any solely automated individual decision-making producing legal effects concerning you or similarly significantly affecting you (such as pursuant to article 22 GDPR). Should we use such procedures in certain cases, we will inform you separately of this and advise you of your relevant rights if required by law.
10. Your Rights
In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above. Please further note that the exercise of these rights may be in conflict with your contractual obligations, and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.
In general, exercising these rights requires that you are able to prove your identity (e.g. by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.
In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
11. Amendments of this Privacy Policy
We may amend this Privacy Policy at any time without prior notice. The version published on our Platform at the time of your visit or use of the relevant services shall apply.