Privacy Policy

1 Introduction

The protection of your personal data is important to us. Therefore, we process (i.e. collect, process and use) your personal data in accordance with the content of this Declaration and the applicable data protection regulations, in particular the Swiss Data Protection Act (DPA). This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation and similar documents may govern specific matters. We therefore ask you to read the following carefully.

2 Responsible

Responsible for data processing is Carbon Removal Partners AG, Basteiplatz 7, 8001 Zurich, Switzerland. Within Carbon Removal Partners AG, theCompliance Officer is responsible for data protection. If you have any questions or concerns regarding data protection, please contact the ComplianceOfficer of Carbon Removal Partners AG. There you can also view a current version of this Declaration at any time. 


3 Direct and indirect acquisition of personal data

Personal data within the meaning of this Declaration is any information relating to an identified or identifiable individual (hereinafter "data subject") (Art. 5 lit. a and b DPA). 

We primarily process the personal data that we receive from interested parties, investors, customers and other business partners in the course of our business activities from these and other persons involved in them. This also includes personal data of data subjects who advise or represent these customers and business partners or otherwise act together with them. 

To the extent permitted and necessary, we also obtain data from third parties. This includes in particular, but not exclusively, data from the following categories: (i) publicly accessible registers of all kinds (e.g. debt collection register, commercial register), (ii) press, internet, social media, etc., (iii) information that we learn in the course of administrative, judicial or other proceedings, (iv)information relating to your professional, political and other functions and activities, (v) information about you in correspondence and meetings with third parties, (vi) information about you that people close to you (family, advisors, legal representatives, etc.) give us so that we can conclude or perform contracts with you (e.g., references), (vii) powers of attorney, (viii)information to comply with legal requirements such as anti-money laundering requirements, and (ix) information from banks, insurance companies, distributors and other contractual partners of ours regarding the use or provision of services by you. 

If you send us data about third parties, we ask you to ensure that these third parties are informed about this Declaration and agree to the forwarding of their data to us.

4 Purpose

We use the personal data primarily to initiate and process our services and to enter into and comply with our contracts with our clients and business partners, as well as to comply with our legal obligations.In addition, we also process personal data about you and other individuals, as permitted and as we deem appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest consistent with the purpose:
• Communication with third parties (e.g. fund managers, transfer agents, administrator)
• Communication with target companies
• Communication with authorities (e.g. supervisory authorities such as FINMA, the CSSF, prosecutors, etc.) to fulfill information and reporting obligations, etc.
• Processing of orders and services
• Monitoring of payment flows, risks, limits, etc.
• Marketing of services and products to clients
• Assertion and enforcement of any legal claims
• Securing the IT infrastructure
• Satisfaction of compliance and risk management requirements

Insofar as you have given us your consent to process your personal data for specific purposes, we process your personal data within the scope of and based on this consent, insofar as we have no other legal basis and we require such a basis. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.

5 Cookies/ Tracking and other technologies in connection with the use of our website

We may use "cookies" and similar technologies on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you are using when you visit our website. This allows us to recognize you when you return to this website, even if we do not know who you are. In addition to cookies that are only used during a session and deleted after your website visit ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser to reject cookies, store them for one session only, or otherwise delete them early. Most browsers are preset to accept cookies. We use persistent cookies to remember user preferences (e.g. language, autologin), to help us better understand how you use our offerings and content, and to show you offers and advertisements tailored to you (which may also happen on other companies' websites; however, they will not learn from us who you are, if we even know, because they will only see that their website has the same user who was on a particular page with us). Certain of the cookies are set by us, and certain are also set by contractors with whom we work. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.

We may also include visible and invisible image elements in some of our newsletters and other marketing emails, where permitted, that allow us to determine if and when you have opened the email by retrieving them from our servers so that we can measure and better understand how you use our offers and tailor them to you here as well. You can block this in your email program; most are preset to do so.

By using our websites and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, then you must set your browser or e-mail programs accordingly, unless this can be adjusted via the settings.

We may use Google Analytics or similar services on our websites. This is a service provided by third parties that may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as an order processor (both "Google"),, with which we can measure and evaluate the use of the website (not on a personal basis). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the USA and thus cannot be traced. We have turned off the "Data Forwarding" and "Signals" settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these individuals. Insofar as you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider then takes place under the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

We may also use so-called plug-ins from social networks such as Facebook, Twitter, YouTube, Pinterest or Instagram on our websites. This is apparent to you in each case (typically via corresponding icons). We have configured these elements so that they are disabled by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator according to its data protection regulations. We do not receive any information about you from him.

6 Principles of data processing

When processing data, we take into account the legal processing principles of legality, proportionality, purpose limitation, transparency - in particular the fulfillment of information obligations - and data security.

7 Data Security

All information that you submit to us is stored by Carbon Removal Partners AG on servers within the EEA and / or Switzerland.  We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, and access controls and restrictions.

8 Data disclosure and data transfer abroad

Within Carbon Removal Partners AG, personal data is only accessible to those persons who actually require this data.

We may also disclose Personal Data to the following categories of third parties, as permitted and as we deem appropriate, in the course of our business activities and for the purposes set forth in Section 5:

• supervisory, administrative, tax and other authorities in Switzerland and abroad
• service providers of the investment vehicles, such as transfer agent, administrators, AIFMs, depositaries, auditing companies etc.
• accounting, tax, legal and compliance consulting services
• IT service provider
• other investors in a co-investment-scenario
• other financial service providers, in particular banks for processing payments of all kinds

We may also be entitled or obligated to disclose data due to legal provisions and/or official or court orders. In particular, this may involve the disclosure of information for the purposes of criminal prosecution, danger prevention, etc. As far as is apparent, no further disclosure of personal data to third parties will take place unless you have consented to the disclosure of data.Personal data may be transferred abroad, in particular to Luxembourg, where investment funds are domiciled.

9 Duration of the retention of personal data

We process and store your personal data as long as it is necessary for the fulfillment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of your business relationship with CarbonRemoval Partners AG (from the initiation, processing to the termination and settlement of a contract) and beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the time during which claims can be asserted against Carbon Removal Partners AG and to the extent that we are otherwise legally obligated to do so or legitimate business interests require this (e.g.for evidence and documentation purposes). 

As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as a matter of principle and as far as possible.

10 Obligation to provide personal data

Within the scope of our business relationship, you must provide the personal data that is required for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations. Depending on the service, you may have a legal obligation to provide us with data. This applies in particular in the fight against money laundering or terrorist financing (to the extent applicable). We may not be able to conclude a contract with you (or the entity or person you represent) or process it without this data.

11 Profiling

For the establishment and implementation of the business relationship and also otherwise, we generally do not use fully automated automatic decision-making. Should we use such procedures in individual cases, we will inform you separately about this, insofar as this is required by law, and inform you about the associated rights.

12 Rights of the person concerned

You have the right to request information about your personal data processed by us. In particular, you can request information about the personal data as such, the purpose of processing, the retention period or, if this is not possible, the criteria for determining this period, the origin of your data if it was not collected from you, and, if applicable, the recipients or categories of recipients to whom personal data is disclosed.

Furthermore, you also have the right to correct incorrect data, the right to request the restriction of processing of data that has been processed too extensively and the right to delete personal data that has been processed unlawfully or stored for too long (insofar as this does not conflict with any legal obligation to retain data and no other reasons according to the DPA). Finally, you also have the right to revoke any consent you may have given to use your personal data at any time.

You may exercise your aforementioned rights at any time by contacting us at the contact address provided. The exercise of such rights usually requires that you clearly prove your identity (e.g. by means of a copy of your ID card, where your identity is otherwise not clear or cannot be verified).

Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to rely on this) or require it for the assertion of claims. Please also note that the exercise of these rights may conflict with contractual agreements and may have consequences such as the premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.

In addition, every data subject has the right to enforce his or her claims in court or to file a complaint with the Federal Data Protection and Information Commissioner.

13 Changes

We may amend this Declaration at any time without prior notice. The current version published on our website applies. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.

September 30th, 2023