Privacy Policy

Effective Date: 24 February 2026 Last Updated: 24 February 2026

This Privacy Policy describes how The Vanderbilt Portfolio AG (“we,” “us,” or “our”) collects, uses, and protects information when you visit ZUG ESTATES (zugestates.com). We are committed to compliance with the Swiss Federal Act on Data Protection (FADP / nDSG, effective 1 September 2023) and, where applicable, the EU General Data Protection Regulation (GDPR).

1. Data Controller

The Vanderbilt Portfolio AG Zurich, Switzerland

For privacy enquiries: [email protected]

2. Data We Collect

2.1 Automatically Collected Data

When you visit ZUG ESTATES, we automatically collect certain technical information through Google Analytics and Google Ad Manager:

IP address (anonymised before storage in Google Analytics)
Browser type and version
Device type and operating system
Pages visited and time spent on pages
Referral source (how you arrived at our site)
Geographic region (country and city level)
Scroll depth and interaction events

This data is collected via cookies and similar tracking technologies. See our Cookie Policy for full details.

2.2 Contact Form and Email Data

If you contact us via email ([email protected] or [email protected]), we collect the information you provide — your email address, name (if given), and the content of your message. This data is used solely to respond to your enquiry and is not shared with third parties for marketing purposes.

2.3 Data We Do Not Collect

We do not collect payment information, social security numbers, identity documents, or sensitive personal categories as defined under the FADP and GDPR. We do not require account creation to access our content.

3. How We Use Your Data

We use collected data for the following purposes:

Analytics: Understanding how visitors use ZUG ESTATES to improve content quality and site structure (Google Analytics)
Advertising: Displaying relevant advertisements through Google Ad Manager
Communication: Responding to editorial and commercial enquiries
Legal compliance: Complying with applicable Swiss and EU law

4. Legal Basis for Processing

Under the Swiss FADP and GDPR, we process your data on the following legal bases:

Legitimate interests: Analytics to improve our site; security monitoring
Consent: Advertising cookies and tracking (obtained via our cookie consent banner)
Contract performance: Responding to enquiries and commercial relationships
Legal obligation: Complying with applicable law

5. Google Analytics

ZUG ESTATES uses Google Analytics 4, operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics collects anonymised usage data to help us understand site traffic and user behaviour.

We have enabled IP anonymisation. Data is stored on Google’s servers and may be transferred to the United States pursuant to Standard Contractual Clauses. Google’s privacy policy is available at policies.google.com/privacy.

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on (available at tools.google.com/dlpage/gaoptout) or by declining analytics cookies in our cookie consent banner.

6. Google Ad Manager

ZUG ESTATES displays advertising through Google Ad Manager, operated by Google Ireland Limited. Google Ad Manager uses cookies to serve relevant advertisements based on your interests and browsing behaviour. This involves processing of personal data by Google.

You may manage your Google ad personalisation settings at adssettings.google.com. You can opt out of interest-based advertising through the Network Advertising Initiative or the Digital Advertising Alliance.

7. Data Retention

Analytics data: Retained in Google Analytics for 14 months
Email correspondence: Retained for up to 3 years for legitimate business purposes
Cookie data: Per the retention periods described in our Cookie Policy

We do not sell personal data. We share data with the following categories of third parties:

Google LLC: For analytics (Google Analytics) and advertising (Google Ad Manager). Data may be transferred to the United States under applicable data transfer mechanisms including Standard Contractual Clauses.

We do not share personal data with other third parties except where required by Swiss or EU law.

9. Your Rights

Under the Swiss FADP and GDPR, you have the following rights:

Right of access: Request a copy of the personal data we hold about you
Right to rectification: Request correction of inaccurate data
Right to erasure: Request deletion of your personal data (subject to legal retention obligations)
Right to restriction: Request that we restrict processing of your data
Right to data portability: Receive your data in a structured, machine-readable format
Right to object: Object to processing based on legitimate interests
Right to withdraw consent: Withdraw consent for cookie-based tracking at any time via our cookie banner

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

If you are located in the EU/EEA and believe we have not adequately addressed your privacy concerns, you may lodge a complaint with your local data protection supervisory authority. Swiss residents may contact the Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch.

10. Security

We implement reasonable technical and organisational measures to protect data against unauthorised access, loss, or destruction. Our site is served over HTTPS. No data transmission over the internet is fully secure; we cannot guarantee absolute security.

11. Children’s Privacy

ZUG ESTATES is not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us at [email protected].

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be noted by updating the “Last Updated” date above. Continued use of ZUG ESTATES after any changes constitutes acceptance of the updated policy.

13. Contact

Privacy enquiries: [email protected]

The Vanderbilt Portfolio AG, Zurich, Switzerland