Who we are
CapitalSwiss Software [legal form], a company incorporated in Dubai, United Arab Emirates, under licence number [licence number], with its registered office at [registered address] ("CapitalSwiss Software", "we", "us"), is the controller of the personal data described in this policy.
Privacy contact: [email protected] EU representative under Article 27 GDPR: [name and address] [UK representative, if the UK market is targeted: name and address]
This policy explains how we process personal data when you visit capitalswiss-software.io and its subdomains (the "Website"), use the live demo, book a demo, contact us, request documents, or deal with our sales and investor relations teams. It is written to meet the requirements of the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), the EU General Data Protection Regulation (GDPR), the UK GDPR and the Swiss Federal Act on Data Protection (FADP).
Platforms built on our technology. This policy does not cover crypto platforms run by our clients ("Operators"). If you use one of those platforms, its Operator decides how your data is used and its own privacy policy applies. Where we host or maintain a platform for an Operator, we act only on the Operator's instructions, as its processor. Please contact the Operator to exercise your rights.
The data we collect
| When | What |
|---|---|
| You book a demo | Full name, work email, company, profile, country of operation, target launch date, licensing status, modules of interest and any message you add, together with the page from which you submitted the form and any campaign parameters (UTM) in the link you followed. If you complete only the first step of the form, we keep the details entered in that step. |
| You schedule a call | The time slot, time zone and any information you add when booking. We do not record calls without telling you first and asking for your agreement. |
| You contact us | Name, email, company, subject and message. |
| You use the live demo | The email address used for admin access, access dates and the actions you take in the demo environment. |
| You request the investor deck | Name, email, company, investor type, intended ticket size and investment horizon. |
| You download a document | Name, work email and company. |
| You correspond or speak with us | Emails, messages and notes of our discussions. |
| You browse the Website | Technical logs recorded by our hosting infrastructure for security and troubleshooting: IP address, browser and device data, pages requested and timestamps. We do not use analytics or advertising cookies. |
| Public professional information | To prepare a call, we may consult the public website of your company and your public professional profile (for example on LinkedIn). |
We do not ask for sensitive data (such as health data or identity documents). Please do not send any through our forms.
Why we use your data, and on what basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Answering your request, organising and holding the demo, preparing a quote | Steps taken at your request before entering into a contract (Art. 6(1)(b)); our legitimate interest in responding to business enquiries (Art. 6(1)(f)) |
| Routing your demo request (see "Automated routing" below) | Legitimate interest in allocating our sales resources efficiently |
| Following up by email after a request, a demo or live demo access, including a reminder if you did not complete the form | Legitimate interest in business-to-business prospecting. You can unsubscribe from any email. Where local law requires your prior consent, we ask for it. |
| Sending our newsletter, when available | Consent (Art. 6(1)(a)) |
| Providing access to the live demo | Legitimate interest in letting prospects evaluate the Platform |
| Managing investor relations and sending the investor deck | Steps taken at your request; legitimate interest in managing relations with prospective investors |
| Securing the Website and preventing fraud and abuse | Legitimate interest |
| Complying with legal obligations and defending legal claims | Legal obligation (Art. 6(1)(c)); legitimate interest |
Where we rely on legitimate interest, we have balanced our interest against your rights. You may object at any time (see section 7). Under the PDPL, we process your data on the basis of your request, the performance of a contract with you, our legal obligations or your consent, as applicable.
Automated routing. When you submit the demo form, your answers (for example your target launch date and licensing status) determine whether a booking calendar is shown immediately or whether we confirm that we will reply by email. This does not produce legal effects for you or significantly affect you, and you can always contact us directly at [email protected].
Who receives your data
We do not sell your personal data. We share it only with:
- our team, on a need-to-know basis;
- service providers that process data on our behalf and under our instructions:
| Service | Provider | Location |
|---|---|---|
| Website and live demo hosting, email sending | Amazon Web Services | [AWS region] |
- professional advisers (lawyers, accountants, auditors) bound by confidentiality;
- authorities, where required by law;
- a buyer, investor or successor, in connection with a merger, acquisition, financing or sale of all or part of our business, under confidentiality obligations.
If we add a service provider, we update this list before it starts processing your data.
International transfers
We are established in the United Arab Emirates. If you are located elsewhere, including in the European Economic Area, the United Kingdom or Switzerland, the data you submit through the Website is collected directly by us and processed in the United Arab Emirates and in the country where our hosting infrastructure is located ([AWS region]).
The United Arab Emirates is not covered by an adequacy decision of the European Commission, the United Kingdom or Switzerland. Wherever your data is processed, we apply the protections described in this policy. When we use a service provider located in another country, we put in place the safeguards required by applicable law, such as standard contractual clauses. You can request a copy of these safeguards by contacting us.
How long we keep your data
| Data | Retention period |
|---|---|
| Prospects (demo, contact, documents) | 3 years from our last contact with you, then deleted or anonymised |
| Clients | For the duration of the business relationship, then for the applicable statutory limitation period |
| Prospective investors | 3 years from our last contact with you |
| Live demo access logs | 12 months. Data entered in the demo is reset regularly. |
| Hosting security logs | 12 months |
| Consent records | For as long as needed to prove your consent |
| Accounting and contractual records | For the period required by law |
Your rights
Depending on the law that applies to you, you have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased;
- restrict how we use your data;
- object to our use of your data based on legitimate interest, and object at any time, without having to give a reason, to direct marketing;
- receive your data in a structured, machine-readable format (portability);
- withdraw your consent at any time, without affecting processing carried out before withdrawal;
- not be subject to a decision based solely on automated processing that produces legal effects for you or significantly affects you.
To exercise your rights, email [email protected]. We may ask you to confirm your identity. We will reply within one month, which may be extended by two months for complex requests, in which case we will let you know.
You may also lodge a complaint with a supervisory authority, in particular in the country where you live or work: in the United Arab Emirates, the UAE Data Office; in the European Union, your national data protection authority; in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC); in the United Kingdom, the Information Commissioner's Office (ICO).
Security
We protect your data with appropriate technical and organisational measures, including encryption in transit, restricted access and the selection of providers that offer adequate guarantees. No transmission or storage method is completely secure, but we work to protect your data and will notify you and the competent authorities of a breach where the law requires it.
Children
The Website is intended for professionals. It is not directed at anyone under 18, and we do not knowingly collect their data.
Changes to this policy
We may update this policy. The date at the top of the page shows the latest version. We will inform you of significant changes by a notice on the Website or, where appropriate, by email.
Contact
CapitalSwiss Software [legal form] [Registered address], Dubai, United Arab Emirates [email protected]