DATA POLICY /
DISCLAIMER

Preface

We, Leo Trust Switzerland AG, take the protection of your personal data seriously and would like to inform you at this point about the data protection in our company through this data protection declaration. Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the European General Data Protection Regulation (hereinafter abbreviated as "EU GDPR") in order to ensure the protection of personal data of the data subject.

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (cf. Art. 13 and 14 EU-DSGVO). With this privacy policy, we inform you about the way in which your personal data is processed by us.

Our privacy policy has a modular structure. It consists of a general part for all processing of personal data and processing situations that come into play each time a website is called up (A. General) and a special part, the content of which only relates to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites as detailed here (B. Visit to websites).

A. General

1. definitions

The terms used in this data protection declaration are based on the following definitions, modelled on Art. 4 EU-DSGVO:

- "Personal data" (cf. Art. 4 No. 1 EU GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information regarding his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).

- Processing" (cf. Art. 4 No. 2 EU GDPR) means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such ascollection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, as well as alteration of a purpose or use for which a data processing was originally intended.

- "Controller" (cf. Art. 4 No. 7 EU GDPR) means any natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

- "Processor" (cf. Art. 4 No. 8 EU GDPR) means any natural or legal person, authority, institution or other body which processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). In the sense of data protection law, a processor is in particular not a third party;

- "Third party" (cf. Art. 4 No. 10 EU GDPR) means any natural or legal person, public authority, agency or other body, other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor. This also includes legal persons belonging to a group.

- "Consent" of the data subject (cf. Art. 4 No. 11 EU GDPR) means any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

2. the name and address of the controller

We are the controller of your personal data within the meaning of Art. 4 No. 7 EU-DSGVO:

Leo Trust Switzerland AG

Löwenstrasse 11

8001 Zurich

Tel: +41 44 512 55 55

Fax: +41 44 512 55 00

E-mail address:

info@leotrust.ch

Further information about our company can be found in the imprint details on our website.

3. contact details of the data protection officer (cf. Art. 37 EU GDPR) Our company data protection officer is available at all times to answer any questions you may have and to act as your contact person on the subject of data protection at our company. His contact details are:

Leo Trust Switzerland AG

Data Protection Officer:

Melanie Syz

Löwenstrasse 11, 8001 Zurich

Tel: +41 44 512 55 55

Fax: +41 44 512 55 00

E-mail address: compliance@leotrust.ch

In principle, any processing of personal data is prohibited by law and only permitted if the data processing falls under one of the following justifications:

- Art. 6 para. 1 sentence 1 lit. a EU GDPR ("consent"): If the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous affirmative action that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;

- Art. 6 para. 1 p. 1 lit. b EU-DSGVO: If the processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject;

- Art. 6 para. 1 p. 1 lit. c EU-DSGVO: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to keep records);

- Art. 6 para. 1 p. 1 lit. d EU-DSGVO: If the processing is necessary to protect the vital interests of the data subject or another natural person;

- Art. 6 para. 1 sentence 1 lit. e EU-DSGVO: Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or

- Art. 6 (1) p. 1 lit. f EU-DSGVO ("Legitimate Interests"): If the processing is necessary to safeguard legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject prevail (in particular if the data subject is a minor).

For the processing operations carried out by us, we indicate below the applicable legal basis in each case. A processing operation may also be based on several legal bases.

5. data deletion and storage period

For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. In principle, your data will only be stored on our servers in Switzerland, subject to any transfer that may take place in accordance with the regulations in Part A. Section 7 and 8.

However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings or if storage is provided for by legal regulations to which we are subject as the responsible party. If the storage period prescribed by the legal regulations expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.

6. data security (cf. Art. 32 EU GDPR)

We use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see Part A. Section 3).

7. cooperation with processors (cf. Art. 28 EU GDPR)

As with any larger company, we also use external domestic and foreign service providers (e.g. for IT, logistics, telecommunications, sales and marketing) to process our business transactions. They only act on our instructions and have been contractually obliged to comply with data protection regulations in accordance with Art. 28 EU-DSGVO.

If personal data from you is passed on by us to our partner companies or is passed on to us by our partner companies (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.

8. conditions for the transfer of personal data to third countries

In the course of our business relationships, your personal data may be passed on or disclosed to third party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries.

Such processing takes place exclusively for the fulfilment of contractual and business obligations and to maintain your business relationship with us. We will inform you about the respective details of the transfer in the following at the relevant points.

Some third countries are certified by the European Commission as having a level of data protection comparable to the EEA standard through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is sufficiently guaranteed. This is possible through binding company regulations, standard contractual clauses of the European Commission for the protection of personal data, certificates, recognised codes of conduct or self-certification via the EU-US Privacy Shield (information on this can be found here: https://www.privacyshield.gov/welcome). Please contact our data protection officer (see Part A. Section 3) if you would like more information on this.

9. no automated decision making (including profiling)

We do not intend to use any personal data collected from you for any automated decision making process (including profiling).

10. no obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in the context of the products or services offered by us presented below, you will be informed of this separately.

11. legal obligation to transmit certain data

We may, under certain circumstances, be subject to a specific legal or statutory obligation to make the lawfully processed personal data available to third parties, in particular public bodies (cf. Art. 6 (1) p. 1 lit. c EU-DSGVO).

12. your rights

You can exercise your rights as a data subject with regard to your personal data processed by us at any time using the contact details provided at the beginning of Part A. Section 2 at any time. You have the right as a data subject:

- in accordance with Art. 15 EU-DSGVO to request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details;

- in accordance with Art. 16 EU-DSGVO to demand the correction of incorrect or the completion of your data stored by us without delay;

- in accordance with Art. 17 EU-DSGVO to request the deletion of your datastored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legalobligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;

- to request the restriction of the processing of your data in accordance with Art. 18 EU-DSGVO, insofar as the accuracy of the data is disputed by you or the processing is unlawful;

- pursuant to Art. 20 EU-DSGVO to receive your data that you have provided to us in a structured, common or machine-readable format or to request the transfer to another controller ("data portability");

- pursuant to Art. 21 EU-DSGVO to object to the processing, provided that the processing is carried out on the basis of Art. 6 (1) p. 1 lit. e or lit. f EU-DSGVO. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the merits of the case and either cease or adapt the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;

- in accordance with Art. 7 (3) EU GDPR, to revoke your consent given once (also before the applicability of the EU GDPR, i.e. before 25 May

2018) - i.e. your voluntary will, made understandable in an informed manner and unambiguously by means of a declaration or other unambiguous confirming act, that you agree to the processing of the personal data concerned for one or more specific purposes - at any time vis-à-vis us, if you have given such consent. This has the effect that we may no longer continue the data processing based on this consent in the future; and

- pursuant to Art. 77 EU-DSGVO to complain to a data protection supervisory authority about the processing of your personal data in our company, such as the data protection supervisory authority responsible for us. The supervisory authority/data protection agency responsible for us is the data protection commissioner of the canton of Zurich in which our company has its registered office. A list of the data protection officers and their contact details can be found at the following link:

https://www.zh.ch/de/kantonsrat/datenschutzbeauftragte-des-kantons-zuerich.html.

13. changes to the privacy policy

In the context of the further development of data protection law as well as technological or organisational changes, our data protection declaration is regularly reviewed for the need to adapt or supplement it. You will be informed of any changes in particular on our website at www.leotrust.ch. This data protection declaration is valid as of October 2020.

2. personal data processed

During the informative use of the websites, the following categories of personal data are collected, stored and processed by us:

a) "Log data": When you visit our websites, a so-called log data record (so- called "server log files") is stored temporarily and anonymously on our web server. This consists of:

- the page from which the page was requested (so-called "referrer URL")

- the name and URL of the requested page- the date and time of the request- the description of the type, language and version of the web browser used- the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established- the amount of data transferred- the operating system

- the message whether the request was successful (access status/http status code)- the GMT time zone difference

b) "Contact form data": When contact forms are used, the data transmitted through them are processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).

3. purpose and legal basis of the data processing

We process the personal data described in more detail above in accordance with the provisions of the EU Data Protection Regulation, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1)sentence 1 lit. f EU-DSGVO, the aforementioned purposes also represent our legitimate interests. The processing of the log data serves statistical purposes and the improvement of the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. f EU-DSGVO). Contact form data is processed for the purpose of handling customer enquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit. f EU-DSGVO).

4. duration of the data processing

Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; for this purpose, the legal bases stated in the context of the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please refer to Part A. Section 5 and our disclaimer. Third parties engaged by us will store your data on their system for as long as is necessary in connection with the provision of the services for us in accordance with the respective order. You can find more details on the storage period under Part A. Section 5 and in our disclaimer.

5. transfer of personal data to third parties; justification basis

The following categories of recipients, which are usually processors (see Part A. Section 7), may have access to your personal data:- Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data centre services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f EU-DSGVO, insofar as it does not involve order processors;

- Government agencies/authorities, insofar as this is necessary to fulfil a legal obligation. The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. c EU-DSGVO;

- persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. b or lit. f EU-DSGVO.

For the guarantees of an adequate level of data protection in the event of a transfer of data to third countries, see Parts A. Section 8. Furthermore,we will only transfer your personal data to third parties if you have given your express consent to do so in accordance with Art. 6 (1) sentence 1 lit. a EU-DSGVO.

6. use of cookies, plugins and other services on our website

a) Cookies: We use cookies on our websites. Cookies are small text files that are assigned to the browser you are using and stored on your hard drive by means of a characteristic string of characters and through which certain information flows to the body that sets the cookie. Cookies cannot execute programmes or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offer more user-friendly and effective overall, i.e. more pleasant for you. Cookies can contain data that make it possible to recognise the device used. In some cases, however, cookies only contain information on certain settings thatcannot be related to a specific person. However, cookies cannot directly identify a user. A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. In terms of their function, a distinction is made between cookies:

- Technical cookies: these are mandatory to move around the website, usebasic functions and ensure the security of the website; they do not collect information about you for marketing purposes nor do they store which web pages you have visited.

- Performance cookies: these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you

- all information collected is anonymous and is only used to improve our website and find out what interests our users.

- Advertising cookies, targeting cookies: These are used to offer the website user tailored advertising on the website or offers from third partiesand to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months.

- Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.

Any use of cookies that is not absolutely technically necessary constitutes data processing that is only permitted with your explicit and active consent pursuant to Art. 6 (1) sentence 1 lit. a EU-DSGVO. This applies in particular to the use of advertising, targeting or sharing cookies. Furthermore, we will only pass on your personal data processed by cookiesto third parties if you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a DS-GVO.

For more information about which cookies we use and how you can manage your cookie settings and disable certain types of tracking, please see our disclaimer.

b) Social media plugins: We do not use social media plugins on our websites. If our websites contain icons from social media providers (e.g. LinkedIn), we only use these for passive linking to the pages of the respective providers.

II. DISCLAIMER

A. Terms of use

These terms and conditions govern the use of this website operated by Leo Trust Switzerland AG. The terms of use may be changed at any time without prior notice. Please read the terms carefully, as your use of the website constitutes your agreement to be bound by these terms of use.

B. Disclaimer

The contents of our website have been created with the utmost care. However, Leo Trust Switzerland cannot guarantee the accuracy, completeness and up-to-dateness of the website content. The website is a non-binding offer of information on products and services of Leo Trust Switzerland AG, which may be changed at any time without prior notice.All warranties are excluded, including the warranty of fitness for a particular purpose. Leo Trust Switzerland AG shall not be liable for any consequences arising from actions taken in reliance on the information provided on this website. Your use of this website is at your own risk; all associated costs are to be borne by you.

C. External links

Our website contains links to third-party websites (so-called "externallinks"), over whose content we have no influence. External links are provided solely as a service to you. We have no influence on the content of these websites and for this reason cannot accept any liability for the content of these websites. The respective provider or operator of the websites is always responsible for the content of the linked websites. The use of external links is at your own risk.The inclusion of external links does not imply that we adopt the content behind the external link as our own. It is not reasonable for us to constantly monitor external links without concrete indications of legal violations. However, we will delete such external links immediately if we become aware of any legal violations. Deeplinking or framing of the website or other techniques whereby our website (or parts thereof) are integrated into third-party websites - in any form - are not permitted without our prior written consent.

D. Intellectual property

The entire content (text, graphics, images, etc.) and the structure of thewebsite are the intellectual property of Leo Trust Switzerland AG or the partners listed in the imprint and are protected by Swiss copyright law. The complete or partial reproduction, distribution, modification, linking or use for commercial or public purposes and any kind of exploitation outside the limits of copyright law requires our prior written consent or the consent of the partners listed in the imprint.

The content of this website may only be used for private, non-commercial purposes. Unauthorised reproduction or distribution of individual contents or complete pages is not permitted and is punishable by law.

This website does not grant a licence to use the intellectual property of third parties.

E. Google Analytics

We create pseudonymous usage profiles with the help of Google Analytics in order to design our websites according to your needs. Google Analytics uses targeting cookies that are stored on your terminal device and can be read by us. In this way, we are able to recognise and count returningvisitors as such and to find out how often our web pages have been accessed by different users. The data processing is based on Art. 6 para. 1lit. a EU-DSGVO (consent).

The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. However, as we have activated IP anonymisation on our website, your IP address will be shortened by Google beforehand within member states of the European Union. Only in exceptional cases will the full IP address be transferred to a Google server in the USA (an adequate level of data protection exists according to Art. 45 (1) EU-DSGVO due to Google's participation in the EU-US Privacy Shield, see also our Privacy Policy under Part A. Section 8) and only shortened there (for more information on the purpose and scope of data collection, see e.g. https://policies.google.com/privacy?hl=de&gl=de ). We have also concluded an order processing agreement with Google LLC (USA) inaccordance with Art. 28 EU-DSGVO. Accordingly, Google will use all information strictly for the purpose of evaluating the use of our websites for us and compiling reports on website activity.

Google sets the following cookies when you visit our website and consent to the use of the Google Analytics cookie:

Name Purpose Duration

_ga This helps us to count how many people visit our 2 year internet presentation if you have already visited it.

_gid This helps us to count how many people

visit our 24 hour

internet presentation if you

have already visited it.

_gat This helps us manage the frequency in which 1 minute requests were

made to view a page.

You can revoke your consent at any time. Please use one of the following

options to do so:

- You inform us that you wish to withdraw your consent.

- You may refuse the use of cookies by selecting the appropriate settingson your browser, however please note that if you do this you may not be able to use the full functionality of this website.

- You can also prevent the collection of data generated by the cookie and related to your use of our websites (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link (https://tools.google.com/dlpage/gaoptout?hl=de).

F. Applicable law; place of jurisdiction

These terms of use and their interpretation shall be governed by Swiss law. Disputes arising in connection with this website shall be subject to the non-exclusive jurisdiction of the courts of Switzerland.