Privacy Policy

Effective date: 24 February 2026 Last updated: 24 February 2026

1. Controller

This website, zugoil.com (the “Site”), is operated by:

The Vanderbilt Portfolio AG Zurich, Switzerland

For data protection inquiries: [email protected]

2. Applicable Law

This Privacy Policy is governed by Swiss federal data protection law, specifically the revised Federal Act on Data Protection (revFADP / nDSG), which entered into force on 1 September 2023. To the extent that our processing activities fall within the scope of the European Union’s General Data Protection Regulation (GDPR), we also comply with GDPR requirements. Where Swiss and EU standards diverge, we apply the stricter standard.

3. Data We Collect

3.1 Data You Provide Directly

When you contact us via email ([email protected] or [email protected]), we collect your name, email address, and the content of your message. We use this data solely to respond to your inquiry and do not add you to marketing lists without your explicit consent.

3.2 Data Collected Automatically

When you visit the Site, certain technical data is collected automatically:

Log data: IP address (anonymised), browser type, operating system, referring URL, pages visited, time and date of visit
Cookies and similar technologies: See our Cookie Policy for full details

3.3 Google Analytics

The Site uses Google Analytics 4, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google Analytics collects anonymised data about how visitors interact with the Site, including pages viewed, session duration, and traffic sources. IP anonymisation is enabled; your full IP address is not stored by Google Analytics.

Google processes this data on our behalf under a Data Processing Agreement. Data may be transferred to Google servers in the United States under Standard Contractual Clauses. For more information: Google Privacy Policy.

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

3.4 Google Ad Manager

The Site uses Google Ad Manager (provided by Google Ireland Limited) to display advertising. Google Ad Manager may use cookies and similar tracking technologies to serve relevant advertisements. For information on how Google uses data for advertising purposes: How Google uses data when you use our partners’ sites or apps.

To opt out of personalised advertising: Google Ads Settings.

4. Legal Basis for Processing

Under the revFADP and GDPR, we process personal data on the following legal bases:

Legitimate interests (Art. 6(1)(f) GDPR / Art. 31 revFADP): website analytics and security monitoring
Contract performance: responding to editorial and commercial inquiries
Consent: where you have given explicit consent, including for non-essential cookies

5. Data Retention

Email correspondence: retained for up to 3 years after last contact
Analytics data: retained in accordance with Google Analytics default retention periods (26 months)
Log data: retained for up to 12 months for security purposes

We do not sell personal data. We share data only with:

Service providers acting as data processors on our behalf (Google Analytics, Google Ad Manager, hosting providers), under data processing agreements
Legal authorities, where required by applicable Swiss or EU law

7. International Transfers

Data may be transferred to countries outside Switzerland and the EU, including the United States, in connection with Google Analytics and Google Ad Manager. Such transfers are made under Standard Contractual Clauses approved by the European Commission and recognised under Swiss law.

8. Your Rights

Under the revFADP and GDPR, you have the right to:

Access: request a copy of personal data we hold about you
Rectification: request correction of inaccurate data
Erasure: request deletion of your data where we have no legitimate basis to retain it
Restriction: request that we limit processing of your data
Portability: receive your data in a structured, machine-readable format
Objection: object to processing based on legitimate interests
Withdrawal of consent: where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact: [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch.

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. The Site is served over HTTPS.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be indicated by updating the “Last updated” date above. Continued use of the Site after changes constitutes acceptance of the revised policy.

11. Contact

The Vanderbilt Portfolio AG Zurich, Switzerland [email protected]