Privacy Policy
Effective Date: January 1, 2026 Last Updated: January 1, 2026
The Vanderbilt Portfolio AG (“Company,” “we,” “us,” or “our”) operates pitruquinhas.com (“Website”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our Website, in compliance with the Swiss Federal Act on Data Protection (FADP/DSG), the EU General Data Protection Regulation (GDPR), and other applicable data protection laws.
1. Data Controller
The data controller responsible for your personal data is:
The Vanderbilt Portfolio AG Bahnhofstrasse 21 6300 Zug, Switzerland Email: privacy@pitruquinhas.com
2. Information We Collect
Information Collected Automatically:
When you visit our Website, we automatically collect certain information, including:
- IP address (anonymized where required by law)
- Browser type and version
- Operating system
- Referring URL
- Pages visited and time spent on each page
- Date and time of access
- Device type and screen resolution
Cookies and Tracking Technologies:
We use cookies and similar tracking technologies to enhance your experience. See our Cookie Policy for detailed information about the cookies we use and how to manage your preferences.
Information You Provide Voluntarily:
When you subscribe to our newsletter, contact us, or submit content, you may voluntarily provide:
- Name
- Email address
- Organization or affiliation
- Message content
3. Legal Basis for Processing
We process your personal data on the following legal bases:
- Legitimate Interest: To operate and improve the Website, analyze usage patterns, and deliver relevant content (Art. 6(1)(f) GDPR)
- Consent: For newsletter subscriptions, non-essential cookies, and marketing communications (Art. 6(1)(a) GDPR)
- Contractual Necessity: To respond to your inquiries and provide requested services (Art. 6(1)(b) GDPR)
- Legal Obligation: To comply with applicable laws and regulations (Art. 6(1)(c) GDPR)
4. How We Use Your Information
We use collected information to:
- Operate, maintain, and improve the Website
- Analyze usage trends and user preferences
- Deliver personalized content and advertising
- Send newsletter communications (with your consent)
- Respond to inquiries and support requests
- Comply with legal obligations
- Detect and prevent fraud or abuse
5. Third-Party Service Providers
We share data with the following categories of third-party service providers:
Analytics: Google Analytics (with IP anonymization enabled) to analyze Website usage patterns. Google’s privacy policy is available at policies.google.com/privacy.
Advertising: Google AdSense to display relevant advertisements. Google may use cookies to serve ads based on your browsing history. You can opt out of personalized advertising at adssettings.google.com.
Hosting: Cloudflare, Inc. provides content delivery and security services. Cloudflare’s privacy policy is available at cloudflare.com/privacypolicy.
Email: Newsletter distribution is handled by third-party email service providers who process your email address and name solely for delivery purposes.
6. International Data Transfers
Your data may be transferred to and processed in countries outside Switzerland and the European Economic Area. When such transfers occur, we ensure adequate safeguards are in place, including:
- EU Standard Contractual Clauses (SCCs)
- Swiss-U.S. Data Privacy Framework
- Adequacy decisions by the Swiss FDPIC or European Commission
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes described in this policy:
- Analytics data: 26 months
- Newsletter subscriptions: Until you unsubscribe
- Contact form submissions: 12 months after resolution
- Server logs: 90 days
8. Your Rights
Under applicable data protection laws, you have the right to:
- Access your personal data held by us
- Rectify inaccurate or incomplete personal data
- Erase your personal data (right to be forgotten)
- Restrict processing of your personal data
- Data portability — receive your data in a structured, machine-readable format
- Object to processing based on legitimate interest
- Withdraw consent at any time without affecting the lawfulness of prior processing
To exercise any of these rights, please contact us at privacy@pitruquinhas.com. We will respond to your request within thirty days.
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS/SSL), access controls, and regular security assessments.
10. Children’s Privacy
This Website is not directed at individuals under the age of sixteen. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child under sixteen, we will take steps to delete such data promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on this page with a revised “Last Updated” date. Your continued use of the Website after any changes constitutes acceptance of the updated policy.
12. Supervisory Authority
If you believe your data protection rights have been violated, you have the right to lodge a complaint with:
- Swiss Federal Data Protection and Information Commissioner (FDPIC): edoeb.admin.ch
- Your local EU/EEA supervisory authority (if applicable)
13. Contact
For any questions or concerns about this Privacy Policy or our data practices, please contact:
The Vanderbilt Portfolio AG Bahnhofstrasse 21 6300 Zug, Switzerland Email: privacy@pitruquinhas.com