Last Updated: 24.01.2025
At Apex we respect your right to privacy and take personal data protection extremely seriously, as we would like to provide you with the highest level of protection of the personal data that you have trusted us.
This Policy is based on applicable relevant legislation on the protection of personal data, in particular the General Data Protection Regulation of the EU.
In this Personal Data Protection Policy (hereinafter referred to as: Policy), we define ways of collecting your personal data, the purposes for which we collect it, the security measures we use to protect it, the persons with whom we share it, and your rights regarding the protection of personal data.
This Policy applies to all personal data collected and stored by Apex, to be organised under the laws of Switzerland (hereinafter referred to as "Apex", "We", "Us"). The Policy governs your access to and use of all websites operated by Apex, including all associated content, features, and functionalities (collectively "Features") made available on or through these websites or interfaces (collectively "Websites"). By accessing or using any Apex Websites or its associated services and Features, you agree to be bound by this Policy. If you do not agree to this Policy, you may not use our websites or services.
As a data controller, Apex shall be responsible for processing and storing of your personal data.
In order to further upgrade the level of personal data protection, Apex has appointed an authorized person for the protection of personal data, which ensures that the handling of personal data is at all times consistent with the relevant legislation.
If you have any questions regarding the use of this Policy or with regards to the exercise of your rights arising from this Policy, please contact us at any of the following contacts:
This Policy is for:
visitors to our Websites and
users of our Website and Features.
Here you can find an explanation of the basic concepts that we use in our Policy.
Each particular concept defined below has a meaning within this Policy as defined in this section.
Personal data means any information that refers to a specific or identifiable individual (for example, the name, surname, e-mail address, telephone number, and identifiers that are specific to the individual’s physical, physiological, genetic, economic, mental, cultural, or social identity, etc.).
A controller is a legal entity that determines the purposes and means of processing of your personal data.
Processor means a legal or natural person who processes personal data on behalf of the controller.
Processing means collecting, storing, accessing, and all other forms of use of personal data.
EEA means the European Economic Area, which identifies all the Member States of the European Union, Iceland, Norwa,y and Liechtenstein.
At Apex, we process your personal data solely on the basis of clearly stated and legitimate purposes, securely and transparently.
We collect your personal data when you provide it to us (for example, by becoming our member, using our website, signing up for our newsletter, inquiring by e-mail, telephone, or writing to our address or by any other means in which you provide us with your personal data).
Your personal data can also be obtained through your interaction with the website; such information can be obtained by using cookies and a cookie-like technology that allows us to customize and personalize our website to your needs.
5.1. What type of personal data do we collect?
Your personal data can be obtained directly from you when you provide us with this information (for example, by logging into your member account, etc.). We can also obtain your personal data through the use of our services (e.g. webpage, newsletter).
| Category of personal data | Personal data collected |
|---|---|
| Identity data | Name, surname, username, profile picture, data used for comfortable login/registration, KYC data |
| Contact data | e-mail, telephone number |
| Biography data | Biography, personal site, portfolio, preferences |
| Website and Features activity data | Profile, other activity on Websites and Features |
| Payment data | Digital wallet info, other information in accordance with terms of use |
| Technical data | Internet protocol (IP) address, your sign-in data, browser type and version, time zone setting, and location, browser plug-in types and versions, operating system, and other technology on the devices you use to access this website or use our services. |
| Website and Features usage data | Data related to your usage of the Websites and Features. |
At Apex, we carefully protect the principle of the minimum amount of data provided by law, and therefore we collect only data that is appropriate, relevant and limited to what is necessary for the purposes for which the data is processed. The purposes for which we collect personal data are defined in Chapter 4.3. of this Policy.
5.2. On what legal basis do we collect and process your personal data
In accordance with the legislation governing the protection of personal data, we may process your personal data on the following legal bases:
Contract. We process your personal data when such processing is required to complete the contract that you have concluded);
Consent. We process your personal data when you have given consent for the specific purposes of processing, and you are always entitled to revoke that consent;
Legitimate interest. We process your personal data when Apex has a legitimate interest in processing. We will expressly define within this Policy in what events we process the data on a legitimate interest basis. The list of legitimate interests and the processing methods we use is provided further in the document.
The law. When processing is necessary for the fulfillment of legal obligations.
Is the provision of personal data mandatory?
The provision of personal data is mandatory in certain cases. In most cases, you provide us with personal data on a voluntary basis. It is obligatory to provide only the personal data that we collect on the basis of the requirements of the legislation.
The provision of personal data that we need to fulfill the contract is voluntary. However, in the event that you do not provide us with all the personal data that we need to execute the contract, we will not be able to provide full services.
Granting consent is always voluntary. However, in case of consent revocation or denial of consent, we will not be able to provide certain services (such as advertising adjustments to suit your needs).
5.3. Processing purposes
Apex will only process your data for specified, explicit, and legitimate purposes. We undertake not to process your personal data in a manner incompatible with the purposes defined in this Policy.
The purposes for which we can use your personal data are defined below. Apex may use your personal data for one or more of the purposes identified below.
The purposes for which we will use your personal data are the following:
Maintenance of the services. In order to enable you to become a member we will process your personal data, necessary for registration. This purpose also includes enabling you to use your account and profile within the Websites and Features.
Enabling you comfortable registration. In order to enable you quick access to our Websites and Features we offer login with certain digital wallets (i.e. comfortable registration). By connecting your digital wallet with our Websites and Features you agree with our terms of use. When using comfortable registration this privacy policy applies. You can read more on comfortable registration below. We offer this based on our legitimate interest offering safe and comfortable usage of our Websites and Features.
Communicating with you to provide quality responses to your inquiries. Communication is carried out on the basis of our legitimate interest to ensure effective communication with our members as well as visitors.
Implementation of digital marketing. Marketing of our services and products can be done in a variety of ways - remarketing, ˝account-based˝ marketing and tracking users on our website. We will use digital marketing based on consent and/or legitimate interest and we will make sure that you will be informed about such marketing in advance.
Enabling the purchase. In order to process purchase procedures we process personal data of members (sellers) and buyers (visitors). We offer the possibility of downloading digital material via our website. Before transferring such materials, you will be explicitly informed about this, and we will also make such transfers based on contractual relationship (your purchase).
Transmission of personal data to third parties. We will only provide personal data to third parties as defined in Chapter 6 of this Policy.
To enforce any legal claims and to settle disputes. Personal data can be disclosed in order to protect our business and to enforce and / or protect our rights. We will disclose your personal information only in the manner and under the conditions required by law.
For the purposes of statistical analysis. In order to improve the user experience, we analyze the use of our website. Statistical analyzes are carried out on the basis of our legitimate interest in providing an optimal and efficient website.
Executing user satisfaction surveys. Categories of personal data we process differs depending on the theme of the survey, and shall be disclosed with each survey. We execute user satisfaction surveys based on our legitimate interest to improve and optimize our business activities.
In the event that there is a need for further processing of personal data (for a different purpose than for the purpose for which personal data were originally obtained), we will inform you in advance and, when necessary, request for consent. You are entitled to revoke at any time any processing of your personal data, based on your consent. You can notify us of the revocation of the consent at any of the contact points defined in Chapter 2 of this Policy.
What is a comfortable registration?
During account setup, you can automatically connect the previously saved data from your digital wallet with data required for registration. Please consult your digital wallet provider on information which data shall be transferred using comfortable registration. To provide our services, we only store and process your name and your email address.
After the execution of the comfortable registration, you no longer need to register on our site if you are already registered in your digital wallet. The appropriate cookie is set in your browser and used the next time you visit the Websites and Features.
The data stored as part of the comfortable registration is used exclusively for the provision of services of our site, in particular the possibility of login via digital wallet. We keep the data of registered users until the user account is deleted. A registered user can delete their accounts at any time. The user account also allows you to change or delete certain data entered during registration.
5.4. How much time do we keep your personal data?
We keep your personal data in accordance with the relevant legislation. We will keep your personal data:
only for as long as it is absolutely necessary to achieve the purposes for which we are processing (for the purposes for which we process personal data, please refer to Chapter 4.3 of this Policy),
for a period prescribed by the law (we note here that the deadlines for the retention of personal data may also be prescribed by other laws, not only in the field of personal data protection, such as 10 years for the issued invoices, in accordance with the tax legislation),
for the period necessary for the fulfillment of the contract, which includes guarantee periods and deadlines in which it is possible to enforce any claims on the basis of a concluded contract (e.g. 5 years after the fulfillment of contractual obligations).
When personal data is obtained on the basis of your consent, we keep it permanently or until you revoke this consent (see how to revoke the consent in Chapter 8 of this Policy). We will delete the information collected on the basis of your consent before your revocation, in case the purpose for which the data was collected has been achieved.
When the retention period for certain personal data expires, we will delete these personal data or anonymize them so that the reconstruction of personal data will no longer be possible.
The retention periods for each category of personal data are defined in Annex 1.
For any additional information, please contact us at any of the contact details defined in Chapter 2 of this Policy.
At Apex we protect your personal data against illegal or unauthorized processing and/ or access, and against unintentional loss, destruction or damage. We undertake all measures according to our technological capabilities (including the cost of implementing certain measures) and the impact assessment on your privacy.
In order to ensure that your personal data is safe, we have undertaken the appropriate technical and organizational measures at Apex, in particular:
ensuring the regular updating and maintenance of the hardware, software and application equipment that we use for the processing of personal data,
establishing a restriction on access to personal data,
regular backup,
ensuring the education of employees who process personal data at work,
careful selection of processors that we trust for the processing of personal data;
supervising both employees and processors and regular audits,
establishing protocols for preventing or limiting damage in case of potential security incidents.
In the event of a violation of the protection of personal data, we will notify without delay about any such violation the competent supervisory authority.
In the event that there is a suspicion of a criminal offense regarding the violation of personal data, Apex will also report such violations to the police and the competent state prosecutor’s office.
In the event of a violation of data protection that may cause a high risk to the rights and freedoms of individuals, we will inform you of such an event without undue delay.
Your personal data may be, exclusively in order to achieve the purpose for which it was collected, transmitted, or we may just allow access to them to certain third parties defined below. Such third parties may only process your personal data for the purposes for which they were collected.
Accordingly, any third party to whom we transmit personal data is bound to comply with the applicable law as well as to the provisions of this personal data protection policy. With external processors, however, the protection of personal data is further defined by the contract.
Your personal data may be transmitted to:
1. Our external processors who take care of the needs of Apex (accounting services, law firms, companies that provide marketing services, etc.) and also in order to provide our services.
2. When this is required by the law (e.g. tax authorities, courts, etc.).
3. In the event of Asset purchase, merger, reorganisation, dissolution or similar event.
We may transmit your personal data to third parties (defined above) outside the European Economic Area (EEA), where personal data processing occurs. In any transmission outside the European Economic Area, we will undertake specific additional measures to ensure the security of your personal data.
Such measures consist mainly of agreements with third parties on the establishment of binding rules in the field of personal data protection, verification that an approved certification mechanism is in place, which meets our standards for the protection of personal data and the conclusion of relevant contractual obligations that regulate the protection of personal data.
On our Websites we offer you the ability to use the following social networks: X, Discord, Telegram.
The mentioned social networks operate in accordance with their terms of use and privacy policy, where the usage of personal data for each social network is also defined.
Privacy policies are available at the links provided below:
We would like to remind you that any use of social networks that is enabled on our website is in the sole responsibility of the individual. In the event of any questions and/or requests, an individual is required to contact a particular social network.
Apex does not assume any responsibility for the use of social networks.
You have the following rights regarding personal data processing:
9.1. Access to personal data: You may request information from Apex whether we are processing your personal data, and if we do, you can request access to your personal data and information about the processing (which data is processed and from where this data originated).
9.2. Correction of personal data: you may request from Apex to correct or complete your incomplete or inaccurate data being processed.
9.3. Restriction of the personal data processing: you may request from Apex a restriction of the processing of your personal data (when, for example, checking the accuracy or the completeness of your personal data).
9.4. Deletion of personal data: you may request Apex to delete your personal data (we cannot delete those personal data that we keep on the basis of legal requests or contractual relations).
9.5. Printout of personal data: you may request Apex to provide you with the personal data that you have provided us with in a structured, widely used, and machine-readable form.
9.6. Revocation of consent: you have the right to withdraw consent as to the use of your personal data, which we collect and process on the basis of consent, at any time. The consent may be revoked in any manner specified in Chapter 2 of this Policy. The revocation of the consent has no negative consequences, but it is possible that Apex will no longer be able to provide you with certain services.
9.7. Objection to the processing of personal data: You have the right to object to the processing of your personal data when processing is for direct marketing purposes or in the event of transmitting your personal information to third parties for the purposes of direct marketing. You can also object processing when your data is used for direct marketing purposes using customized or individual offers (“profiling”). You can make an objection in any manner defined in Chapter 2 of this Policy.
9.8. The right to data transmission: you have the right to request the printout of personal data that you have provided us with. We will provide you with information in a structured, widely used and machine-readable form. You are entitled to provide this data to another controller of your choice. Where technically feasible, you may request that your personal data be transmitted directly to another controller.
Contacts for the exercise of rights:
If you have any questions regarding the use of this Policy or with regards to the exercise of your rights arising from this Policy, please contact us at any of the following contacts:
You have the right to file a complaint against us with the competent authority for the protection of personal data.
The integrity of personal data processed and regular updating is a priority for Apex. Please kindly inform us of any change of your personal data to the above contacts. We will take care of the correction or supplementing your personal data in the shortest possible time.
In case of exercising any of the rights, we may require additional personal data (such as name, surname, e-mail address) for identification purposes. We will only need additional information when the information you provide is not sufficient for reliable identification (in this way, we want to prevent your personal data from being transmitted to a third party due to unreliable identification).
At Apex, we can change this Policy at any time. We shall notify you of the change of the Policy on our website. We shall consider that you agree with the new version of this Policy if, after the new version enters into force, you continue to use our website and other services defined by this Policy.
The current version of this Policy will be available on our website: https://apexfusion.org/privacy-policy.