Privacy Policy

Last updated: 24 March 2026

RV Capital AG ("RV Capital", "we", "us", "our") is committed to protecting your personal data. This Privacy Notice explains how we collect, use, disclose, store, and otherwise process personal data when you visit our website, subscribe to investor letters or other communications, contact us, or otherwise interact with us.

This Privacy Notice is based on the Swiss Federal Act on Data Protection ("FADP" / revDSG).

1. Controller

The controller responsible for the processing of personal data described in this Privacy Notice is:

RV Capital AG
Einsiedlerstrasse 23
8834 Schindellegi
Switzerland
Email: info@rvcapital.ch
Telephone: +41 41 511 46 87
Website: https://www.rvcapital.ch

If you have any questions about this Privacy Notice or our processing of your personal data, you may contact us using the details above.

2. Categories of Personal Data

We may process the following categories of personal data, depending on your interaction with us:

Identification and contact data: name, email address, postal address, telephone number, company, and country.
Account or subscription data: newsletter preferences, registration status, and communication settings.
Communication data: emails, contact form submissions, letters, and records of correspondence.
Technical and usage data: IP address, browser type, device information, pages visited, timestamps, and log data.
Compliance-related data: records required for legal, regulatory, audit, or anti-abuse purposes.
Any other information you voluntarily provide to us.

We do not intentionally collect sensitive personal data unless this is necessary in a specific case and permitted by applicable law.

3. Purposes of Processing

We may process personal data for the following purposes:

To operate, maintain, and improve our website.
To provide investor letters, newsletters, and other requested communications.
To respond to inquiries and communicate with you.
To manage subscriptions, opt-outs, and suppression lists.
To administer business relationships and provide requested information or services.
To monitor and protect the security, integrity, and availability of our systems.
To comply with legal, regulatory, recordkeeping, audit, and reporting obligations.
To establish, exercise, or defend legal claims.
To prevent misuse, fraud, spam, unauthorized access, or other unlawful activity.

Where required by applicable law, we rely on one or more of the following grounds for processing: your consent, the performance of a contract or pre-contractual steps at your request, compliance with legal obligations, and our legitimate interests in operating our business in a secure and compliant manner.

4. Newsletter and Marketing Communications

If you subscribe to investor letters, newsletters, or other marketing communications, we process your email address and related subscription data in order to send you the requested communications.

You may unsubscribe at any time by using the unsubscribe link in the relevant communication or by contacting us. If you unsubscribe or object to receiving marketing communications, we will stop sending such communications to you.

In order to ensure that you do not receive marketing communications after an opt-out, objection, or deletion request, we may retain limited data, such as your email address and the fact of your opt-out, on an internal suppression list. We use such data solely to prevent future communications from being sent to you and not for marketing purposes.

5. Collection of Data Through the Website

When you visit our website, certain technical data may be collected automatically by our hosting providers and by technologies used on the website. This may include server logs, IP address, browser information, device information, referring URLs, and information about how the website is used.

If you register on our website, subscribe to our communications, or use our contact forms, your data is securely captured and stored within our Customer Relationship Management (CRM) system.

We may use cookies or similar technologies that are necessary for the operation, security, and functionality of the website. Where we use analytics services to measure website traffic, we ensure that data (such as IP addresses) is appropriately anonymized or truncated before processing. We use these tools based on your consent or our legitimate interest in analyzing and optimizing our website.

6. Sources of Personal Data

We generally collect personal data directly from you, for example when you:

visit our website;
subscribe to investor letters or other communications;
contact us by email, phone, or contact form;
provide information in the course of a business relationship.

We may also receive personal data from:

service providers acting on our behalf;
publicly available sources;
business partners or intermediaries, where legally permitted;
technical systems used for website operation, security, or communications.

7. Disclosure of Personal Data

We may disclose personal data to the following categories of recipients where necessary for the purposes described above:

IT, hosting, database, and cloud service providers (including website hosting and CRM platform providers);
email, newsletter, and communications service providers;
providers of analytics, security, and anti-abuse systems;
legal, compliance, audit, and professional advisers;
courts, authorities (e.g., FINMA, SEC), regulators, or law enforcement bodies, where required by law.

Where third parties process personal data on our behalf, we require them to process such data only on documented instructions and with appropriate safeguards in place.

8. International Data Transfers

We may transfer personal data to recipients outside of Switzerland. Depending on the service providers we use, personal data may be transferred to, or accessed from, the following jurisdictions:

Switzerland
The European Union (EU) / European Economic Area (EEA)
The United States
Israel

(The European Commission and Switzerland recognize Israel and the EU/EEA as providing an adequate level of data protection).

Where personal data is transferred to countries (such as the United States) that do not provide a level of data protection deemed equivalent under Swiss law, we ensure that appropriate safeguards are in place. These safeguards include the implementation of Standard Contractual Clauses (SCCs) approved by the relevant authorities, data processing agreements, and adherence to industry-standard security and technical measures to protect your personal data.

9. Retention Period

We retain personal data only as long as necessary for the purposes for which it was collected, for related legitimate business purposes, and for compliance with legal, regulatory, contractual, and audit obligations.

Retention periods may differ depending on the type of data and the purpose of processing. In particular:

Subscription and marketing data is generally deleted or anonymized when it is no longer needed, unless limited retention is required to maintain a suppression list;
Correspondence may be retained for documentation, compliance, and audit purposes;
Records subject to accounting, tax, regulatory, legal, or audit retention obligations may be retained for up to 10 years or longer where required in a particular case;
Backup data may remain in secure backup systems until overwritten in the ordinary backup cycle.

Where deletion is not immediately possible, for example because data is stored in secure archives, backups, or legally required records, we will restrict the processing and retain the data only for the legally permitted purpose.

10. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

These measures may include access controls, role-based permissions, encryption where appropriate, logging, secure hosting, backup procedures, and internal policies governing the handling of personal data.

11. Your Rights

Subject to applicable law, you may have the right to:

Request information about whether we process your personal data;
Receive information about the personal data we hold about you;
Request correction of inaccurate or incomplete personal data;
Request the deletion or anonymization of personal data;
Object to certain processing activities, including direct marketing;
Withdraw consent with effect for the future where processing is based on consent;
Request the delivery or transfer of personal data in a commonly used electronic format, where applicable;
Lodge a complaint with the competent data protection authority.

Please note that these rights may be limited where we are legally required or otherwise permitted to retain or continue processing certain data, for example for compliance, audit, evidentiary, security, or legal reasons.

To exercise any of these rights, please contact us using the details provided in Section 1 above.

12. Complaints

If you are not satisfied with how we handle your personal data, you may contact us first using the contact details in Section 1 above.

You may also lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (EDÖB):

Federal Data Protection and Information Commissioner (EDÖB)
https://www.edoeb.admin.ch
Fax: +41 31 324 01 02
Email: contact@edoeb.admin.ch

If you believe mandatory foreign data protection law applies in a particular case, you may also have the right to contact the competent supervisory authority in the relevant jurisdiction.

13. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in legal requirements, our services, our data processing activities, or other circumstances.

The current version published on our website is the authoritative version. We encourage you to review this Privacy Notice periodically to stay informed about how we protect your personal data.

Questions?

If you have any further questions or concerns about this Privacy Notice or our data protection practices, please contact us at info@rvcapital.ch.