Privacy Policy

APEX Family Office Intelligence · TennoTenRyu Inh. Cesarano · CHE-272.196.618 · Baarerstrasse 87 · 6300 Zug · Switzerland · Last updated: June 2026

1. Data Controller

TennoTenRyu Inh. Cesarano, Baarerstrasse 87, 6300 Zug, Switzerland (CHE-272.196.618). Contact: info@cesaranogilbert.com

2. Data We Process

When you use the free assessment tool: email address, family office name, structure type, AUM range, jurisdiction, and generational stage. Assessment inputs (concerns, focus areas) are processed ephemerally and not stored permanently. No family financial data, client data, or personal data from your own systems is processed.

3. Legal Basis

Processing is based on your consent (GDPR Art. 6(1)(a) / nDSG Art. 31) when you submit the assessment form and confirm via double opt-in. Subscription processing is based on contract performance (GDPR Art. 6(1)(b)).

4. How We Use Data

To generate and return operating intelligence assessments
To send DOI confirmation and onboarding emails
To manage subscription billing via Stripe
To track free assessment usage per email address
To send intelligence briefs to confirmed subscribers

5. Data Retention

Email addresses and scan counts are retained for 24 months from last activity, or until you request deletion. Assessment inputs are processed ephemerally and not retained beyond the session. Subscription data is retained for the duration of the contract plus 10 years for Swiss accounting obligations (OR 958).

6. Your Rights

Right of access to your personal data (GDPR Art. 15 / nDSG Art. 25)
Right to rectification (GDPR Art. 16)
Right to erasure (GDPR Art. 17)
Right to restriction of processing (GDPR Art. 18)
Right to data portability (GDPR Art. 20)
Right to object (GDPR Art. 21)

To exercise your rights: info@cesaranogilbert.com

7. Third Parties

Payment processing: Stripe Inc. (PCI-DSS compliant, no card data is stored by us). Email delivery: Resend Inc. No data is sold to or shared with third-party advertisers or data brokers.

8. Supervisory Authority

You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch, or with the data protection authority of your EU member state.

9. Contact

info@cesaranogilbert.com · Baarerstrasse 87 · 6300 Zug · Switzerland

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