Privacy & Cookie Policy

Version: September 2022

1. General

Protecting the data of each of existing or prospective investors of Opera Investment Partners AG (“Opera” or “Us”), or, in general, of the user of this website (together, the “User” or “You”) is of the highest importance to Us and we go to great lengths to make sure that we keep it safe.  We take your trust and right to privacy seriously.  Nevertheless, in the course of serving our Users with this website (hereinafter, the “Site”) or in subsequent direct contacts with You, we may process information which constitutes Personal Data (as defined in section 2) under data protection laws such as the General Data Protection Regulation (“GDPR”) of the European Union, the Swiss Federal Act on Data Protection (“FADP”) or equivalent laws in other jurisdictions around the globe.

2. Personal Data
   • Your name, address, email address, IP address and other information of personal nature that describe You and that may be correlated with You as an individual may be processed by Us (“Personal Data”).
   • By accessing the Site or providing Us with your Personal Data, You are expressly consenting to the Processing of your Personal Data, as set forth hereinafter. We use cookies to save your preferences and to make your use of the Site as seamless as possible (more details on cookies can be found in section 10).
3. Processing of Personal Data
   • We store and process the Personal Data that You have provided to Us as well as data that we may infer from your use of the Site (the latter generally being in anonymous form).
   • Your Personal Data may be subject to storage, collection, registration, organization, preservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, transmission, cancellation and destruction (the “Processing”). Any of these operations may be performed applying those electronic or physical instruments and legal means that we deem appropriate for the security, confidentiality and protection of Personal Data.
   • Personal Data is processed at the offices of Opera or of any other affiliated entity of the Opera group and at any other places where the parties involved in the Processing are located. More details on the parties involved in the Processing can be found in section 7.
   • Opera uses either its own servers or third-party providers servers, which may be located outside of the EU.
   • While processing Personal Data, we make sure to take all reasonably possible security measures, both technically and organizationally, to keep Personal Data safe. If You would like to know more about how we keep You and your Personal Data safe, please see section 8.
4. Purpose of Use

Opera may process Personal Data for the following purposes:

• • to improve the content, functionality and performance of the Site;
  • to provide services to You;
  • to enhance your browsing experience;
  • to recognize You when You return to the Site;
  • to provide (technical) support when You reach out to Us;
  • to assess and manage risk and fulfil our legal and regulatory requirements;
  • to exercise and defend our legal rights; and
  • for any other legitimate business purposes.

5. Legal Base of Processing
   • Our Processing activity is executed in conformity with the applicable legal requirements:

• • • the processing activities set forth in items (a) to (e) of section 4 are necessary for the use of the Site;
    • the processing activities set forth in items (f) and (g) of section 4 are necessary to comply with our legal obligations; and
    • the processing activities set forth in items (h) of section 4 are based on our legitimate interest and might be needed for the furtherance of our business relationship.
  • Opera does not sell or otherwise distribute your Personal Data to third parties other than those indicated in section 7 and shall not use your Personal Data for any other purposes than stated above without your prior consent. Be aware that we may allow our advertisers to add third party cookies in their wallpaper campaigns.  For more details on cookies, please see section 10.

6. Duration of Storage of Personal Data
   • Our retention periods for Personal Data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the Processing purpose(s) for which the information was collected, and any other permissible, related purpose.  When Personal Data is no longer needed, our policy is to either irreversibly anonymize Personal Data (and we may further retain and use the anonymized information) or securely destroy such Personal Data.
   • Based on your consent for the Processing activities set forth above, we keep your Personal Data in our database for as long as required for the use of the Site and/or our business relationship and for a maximum time period of five (5) years thereafter, subject to statutory limitation periods, whereupon it will be deleted.
   • You have the right at any time to request the deletion of all your Personal Data (more details on the deletion of Personal Data can be found in sections 9 and 11).
7. Responsible Person
   • Opera Investment Partners AG, with registered office at Utoquai 43, 8008 Zurich, Switzerland, registered with the Zurich commercial register under no. CHE-133.317.527, is the data controller of your Personal Data.
     Contact email: .
   • Opera has several data processors to (a) operate the Site and (b) provide support to Opera in its business activity and we may need to share some of your Personal Data with them.
   • Opera’s data processors can be categorized as:

• • • Opera’s directors, officers, employees, agents, counsels or other advisers;
    • Opera’s legal advisors;
    • Opera’s IT persons;
    • Opera’s regulatory and financial auditors;
    • Opera’s administrators; and
    • Opera’s third-party service providers entrusted with its client relationship management and/or compliance and risk assessment.
  • Unless we tell You differently, our data processors do not have any right to use the Personal Data we share with them beyond what is necessary to assist Us in providing the Site or our services to You.
  • When we cooperate with data processors and they process your Personal Data on our behalf, we make sure that your Personal Data will be handled with the same integrity and security as we do.

8. Data Security
   • Opera carries out the Processing of Personal Data in compliance with the principles of correctness, fairness, lawfulness, transparency and confidentiality, and in accordance with any applicable law (such as the European GDPR and the Swiss FADP) or additional rules protecting these principles.
   • Opera takes appropriate technical and organizational measures to protect your Personal Data against loss or other forms of unlawful processing.
   • In case of Personal Data sent to a country outside of the European Union that does not ensure an adequate level of protection for Personal Data, Opera will undertake to implement safeguards, including technical and contractual safeguards, necessary to ensure an adequate level of data protection for any such Personal Data transferred to such country, based on the requirements of article 46 of the GDPR.
9. Rights of Users
   • The rights with respect to Personal Data include your rights, at any time: (a) to receive confirmation regarding the Processing of Personal Data and the persons involved in the Processing of Personal Data, (b) to access Personal Data, (c) to obtain Personal Data in a structured, machine readable and organized way and to transfer or have transferred such Personal Data to another data controller, (d) to object to the Processing of Personal Data, (e) to obtain rectifications of Personal Data, (f) to imply restrictions on Personal Data, have Personal Data be transformed into anonymous form or be erased, or to withdraw consent to the Processing of Personal Data, where the Processing of Personal Data is no longer legally justified and (g) to be informed about any data breach of Personal Data.
   • If You do not agree on the Processing of your Personal Data, we will no longer process your Personal Data, but we might no longer be able to provide You with our services. If You no longer want Us to process your Personal Data, either terminate your use of the Site or our business relationship and ask Us to delete your Personal Data.
10. Cookies
    • A cookie is a small text snippet sent from the web server to the User’s internet browser and saved in the User’s computer. Cookies are designed to hold a small amount of data specific to the User or the website that had sent them.  At your next visit on that website, these files will be re-sent to the website that generated them in order to improve your use of the site in question.
    • “Third parties” cookies, on the other hand, are sent from websites that You are not directly visiting. It occurs namely when accessing certain elements (like images, links, etc.) that are hosted by a different server from the one of the visited website.
    • Some cookies are necessary for the correct use of the website and cannot be disabled. Others, like the ones regarding memorization of preference parameters, can be disabled.
    • There are various kinds of cookies, each one having a specific purpose. Opera uses the following cookies:

• • • technical cookies or “first-party” cookies: these cookies are managed by the owner and/or the publisher of the website and are strictly needed for the proper operation of the website but also provide aggregate data for internal surveys regarding the numbers of website-visits, the popularity of the website and traffic flow information. Technical cookies do not collect information that may be used for advertisements, neither do they track the User’s personal browsing history.  In order to install these cookies, the consent of the User is not required (as all data collected remains anonymized).  If the User refuses the installation of these cookies, his/her access to the website will automatically be denied; and
    • “third party” cookies: these cookies are installed on the User’s browser by a party that is not the owner and/or the publisher of the visited website. There are various types of such “third party” cookies, among which:
    • analytics cookies: used to collect and analyze data. They do not identify the individual User; and
    • advertising cookies: applied to understand and store User preferences for advertising purposes during the User’s online browsing. Opera has no influence on the use of cookies installed by entities or third parties linked to its website and declines all responsibility thereto.
  • Cookies help to improve our services and your browsing experience. The advantage for a User to have cookies installed on his/her computer consists in the fact that he/she is no longer required to provide the same information every time he/she accesses the same website, as his/her personal information is remembered by the website through the cookies.
  • Through the use of the Site, the User’s consent to the installation of cookies is assumed by Opera. Users who do not wish to receive cookies may block “first party”, and/or “third party” cookies following the instructions provided by each browser, set forth hereinafter:
    • chrome;
    • firefox;
    • internet explorer; and
    • safari.
  • For further information on third parties installing cookies on the Site, with which direct or indirect commercial relations have been established by Opera, kindly refer to the respective information on the privacy policy of such third parties.

11. Revisions to this Privacy & Cookie Policy

We may from time to time change and adapt this Privacy & Cookie Policy and publish it on the Site, without giving the User specific notice thereof.  Opera recommends that You review the Site from time to time and take note of any changes.  If You do not agree with this Privacy & Cookie Policy, You should no longer use the Site and terminate your relationship with Us.  By continuing to use the Site and your relationship with Us, You accept any changes made to this Privacy & Cookie Policy.

12. Questions

If You have questions about the way Opera processes your Personal Data or the personal information Opera stores about You, please contact Opera by sending an email with your question to: .