Privacy Policy

This data protection declaration provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name northlightholding.com. In particular, we provide information about what personal data we process, how and where we process it. We also provide information about the rights of individuals whose data we process. For individual or additional activities and operations, we may publish further data protection declarations or other information on data protection.

We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized in its decision of July 26, 2000July 2000 that Swiss data protection law ensures adequate data protection. With report dated January 15, 2024, the European Commission confirmed this adequacy decision.

1. Contact addresses

The entity responsible for data protection in accordance with data protection law is:

NorthLight Holding
Fortune Executive Tower
2402 JLT. Cluster T
Dubai, UAE

info@northlightholding.com

In individual cases, third parties may be responsible for processing personal data, or joint responsibility with third parties may exist. We will be happy to provide data subjects with information about the respective responsibility upon request.

2. Terms and legal basis

2.1 Terms

Data subject: Natural person about whom we process personal data.

Personal data: All information relating to an identified or identifiable natural person.

Sensitive personal data: Data relating to trade union, political, religious, or philosophical beliefs and activities, data concerning health, privacy,or belonging to an ethnic group or race, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.

European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DSV).

We process personal data in accordance with at least one of the following legal bases, insofar as the European General Data Protection Regulation (GDPR) applies:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to safeguard legitimate interests – including the legitimate interests of third parties – unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are, in particular, the permanent, people-friendly, secure, and reliable performance of our activities and operations, the assurance of information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal datafor the fulfillment of a legal obligation to which we are subject under all applicable laws of member states of the European Economic Area (EEA).
  • Art. 6 para. 1 lit e GDPR for the necessary processing of personal data for the fulfillment of a legal obligation to which we are subject in accordance with the applicable law of Member States of the European Economic Area (EEA).for the performance of a task carried out in the public interest.
  • Art. 6 (1) (a) GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or of another natural person. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

    The European General Data Protection Regulation (GDPR) defines the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

    3. Type, scope, and purpose of personal data processing

    We process personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may fall into the following categories: browser and device data, content data, communication data, meta data, usage data, master data including inventory and contact data, location data, andcommunication data, meta data, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. Personal data may also include particularly sensitive personal data.

    We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, insofar as such processing is permissible.

    We process personal data to the extent necessary with the consent of the persons concerned. In many cases, we can process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.

    We process personal data shy;data for the period necessary for the respective purpose. We anonymize or delete personal­data in particular in accordance with statutory retention and limitation­periods.

    4. Disclosure of personal­data

    We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.

    We may disclose personal data within the scope of our activities and operations, in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, trade associations, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, and other service providers.representatives, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companiescompanies, organizations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

    5. Communication

    We process personal data in order to communicate with individuals as well as with authorities, organizations, and companies. In doing so, we process in particular data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or using similar tools. Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals themselves. In particular, they must ensure that such data is accurate and may be transferred.

    6. Data security

    We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data processed, without however being able to guarantee absolute data security.

    Access to our website and our other digital presence is via transport encryption (SSL/TLS, in particular with the 7. Personal data abroad

    We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular for processing or to have it processed there.

    We may transfer personal data to all countries in the world and elsewhere in the universe, provided that the local law complies with decision of the Swiss Federal Council and, if and to the extent that the General Data Protection Regulation (GDPR) applies, also in accordance with decision of the European Commission ensures adequate data protection.

    We may transfer personal data to countries whose laws do not guarantee adequate data protection if data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards.or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the data subjects or a direct link to the conclusion or fulfillment of a contract. We will be happy to provide data subjects with information about any guarantees upon request.We will be happy to provide data subjects with information about any guarantees or a copy of any guarantees upon request.

    8. Rights of data subjects

    8.1 Data protection and legal claims

    We grant data subjects all claims in accordance with applicable law. Data subjects have the following rights in particular:

    • Information: Data subjects may request information about whether we process personal data about them and, if so, what personal data this is.data is involved. Data subjects shall also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed shy;data processed as such, but also, among other things, information on the purpose of the processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data. Data subjects may correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
    • Right to express your own point of view and right to human review: Data subjects have the right to express their own point of view and have their data reviewed by a human being in the event of decisions based solely on automated processing of personal data that have legal consequences for them or significantly affect them (automated individual decisions).shy;decisions), to express their own point of view and request review by a human being.
    • Deletion and objection: Data subjects may have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
    • Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

    We may postpone, restrict, or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we mayWe may, for example, refuse to provide information on the grounds of confidentiality obligations, overriding interests, or the protection of other persons, either in whole or in part. We may also refuse to delete personal data, in particular personal data, on the grounds of confidentiality obligations, overriding interests, or the protection of other persons, either in whole or in part.obligations, overriding interests, or the protection of other persons. For example, we may also refuse to delete personal data, in particular with reference to legal retention obligations, in whole or in part.

    We may charge a fee for exercising these rights in exceptional cases. We will inform the persons concerned in advance of any costs that may be incurred.

    We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

    Affected persons have the right to enforce their data protection claims through legal channels or to file a complaint with a data protection supervisory authority.

    The data protection supervisory authority for private controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (EDÖB).

    European data protection supervisory authorities are organized as members of the European Data Protection Board (EDSA). In some member states of the European Economic Area (EEA), the data protection supervisory authoritiesare structured at the federal level, particularly in Germany.

    9. Use of the website

    9.1 Cookies

    We may use cookies. Cookies—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data that are stored in your browser. Such stored data is not necessarily limited to traditional cookies in text form.

    Cookies can be stored in the browser temporarily as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable us, in particular, to recognize a browser when you next visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

    Cookies can be deactivated, restricted, or deleted in whole or in part at any time in your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may not be fully available. We request – at least to the extent required by applicable law – actively request your express consent to the use of cookies.

    9.2 Logging

    We may log at least the following information for each access to our website and our other digital presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time, including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed including the amount of data transferred, the last website accessed in the same browser window (referrer).

    We log such information, which may also constitute personal data, in log files. The information is necessary to ensure that our digital presence is permanent, user-friendly, and reliable. The information is also necessary to ensure data security, including by third parties or with the help of third parties.

    9.3 Tracking pixels

    We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those of third parties whose services we use – are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is logged in log files.

    10. Third-party services

    We use services provided by specialized third parties to enable us to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. These services enable us, among other things, to embed functions and content into our website. When such embedding takes place, the services used collect, for technical reasons, at least temporarily, the IP addresses of users for technical reasons.

    For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to provide the respective service.

    We use the following in particular:

    10.1 Digital infrastructure

    We use services from specialized third parties to provide the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

    10.2 Map material

    We use third-party services to embed maps on our website.

    In particular, we use:

    11. Final notes on the data protection declaration

    We have created this privacy policy using the Privacy Policy Generator from Data­protection­partner to create this privacy policy.

    We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current data protection declaration on our website.