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1. Introduction

1.1. Casari and Murray ("CAM"), the company running Headswap ("HS"), respects Users’ privacy. This Privacy Policy explains (i) what information CAM collects through the Users access and use of the Website as well as through the access and use of the Services; (ii) the use CAM makes of such information; and (iii) the security level CAM provides for protecting such information.

1.2. By expressly accepting this Privacy Policy, the Users agree to the terms and conditions of this Privacy Policy and are aware that CAM’s policies may change in the future to adapt to future practices, technology or modification in the law. All terms not defined herein are defined in the Terms accessible at

2. Collected information

2.1. When Users access and use the Services, CAM collects the specific following personal data and information ("User Information"):

(i) Full name;

(ii) company name, if applicable;

(iii) email address;

(iv) address;

(v) nationality;

(vi) birthday;

(vii) phone number;

(viii) payment information;

(ix) Know Your Client (KYC) data, such as education, reviews, certified ID copies, etc.);

(x) IP address;

(xi) visiting date on the Website;

(xii) research criteria;

(xiii) list of the Classes viewed on the Website;

(xiv) Users’ interaction with the Services such as their navigation details on the Website, notably without limitation information about Users’ Web browser, webpages Users visited and saved, and log files; and

(xv) data collected from third-party plugins/websites such as without limitation Facebook, Google, LinkedIn, Twitter, XING, Keen IO, Intercom, Mailchimp, Sentry, Cloudflare, Amazon Cloudfront, that are provided when Users submit their User Information through the Services.

2.2. CAM collects the User Information when Users access and use the Services, in particular:

(i) when Users access and navigate through the Website;

(ii) when Users willingly and voluntarily submit User Information through web forms, by uploading User Content on the Website or through the Management Tools of the Website, or with their explicit consent by separate submission outside the Website;

(iii) when Learners submit an inquiry about a Class of their interest;

(iv) when Teachers submit an inquiry about an Class of their interest;

(v) through third-party plugins/websites; and

(vi) through cookies and other analytics tools.

3. Use of collected information

3.1. The User Information listed in Section 2.1 (i) to (ix) are strictly necessary for CAM’s core Services, to provide notably a meeting place for Entrepreneurs of early stage ventures and Investors and enabling Investors to invest within such early stage ventures. Users can withdraw at any time theirs consent for such specific data processing. Please note however that such data processing is strictly necessary to provide the Users the Services and that a withdrawal may lead to the drawback that CAM would not be able to provide and perform properly the Services any more. In such case, CAM may terminate the Users’ access and/or use to all or part of the Services without incurring any liability whatsoever.

3.2. In addition, CAM collects the User Information listed in Section 2.1 for the following specific purposes:

(i) to provide Users email alerts on interesting early stage ventures;

(ii) to communicate with the Users;

(iii) to provide the Business Management Tools to the Users;

(iv) to fuel a jobs posting section on the Website;

(v) the Users’ subscription to CAM’s newsletter, in order to provide them further news and updates such as new early stage ventures matching their interest;

(vi) to provide Users with targeted marketing and advertising tailored to their preferences;

(vii) to offer Users similar Services;

(viii) to re-engage Users accessing and using the Services;

(ix) to improve the Services;

(x) for cybersecurity of the Services; and

(xi) for statistical and planning purposes.

Users can withdraw at any time their consent for the such specific data processing listed in this Section 3.2. In addition, Users have the rights set forth in Section 10 of this Privacy Policy.

4. Third-party websites

The Website may contain links to other websites. This Privacy Policy does not apply to the practices of any company or individual that CAM does not control, nor to any websites that may be linked from the Website. Users should carefully review the privacy policies of any websites that Users visit from the Website to learn more about their information and privacy practices. The collection and use of User Information or any other personal information shall be governed by such other party or website’s privacy policy. CAM cannot be held responsible for their privacy practices. In particular, the Website contains links to third-party websites such as listed in Section 2.1 (xv), of which privacy policies can be found on their respective websites.

5. Communication to third parties

CAM may in some limited instances communicate the User Information to specific third parties, on a strict need-to-know basis, to achieve the purposes described in this Privacy Policy:

(i) CAM’s personnel;

(ii) Investors, with respect to Entrepreneurs and vice versa;

(iii) CAM’s service providers such as the companies listed under Section 4, in particular for targeted marketing and advertising;

(iv) competent courts or supervisory or regulatory bodies, when CAM shall compellingly disclose User Information, pursuant to any applicable law, regulation or order, e.g. in case of merger, sale or acquisition, or in case of bankruptcy and liquidation, if applicable.

(v) CAM’s IT systems providers, cloud service providers, database providers and consultants;

(vi) business partners with whom CAM conducts business with, which is necessary to offer the Services jointly with CAM; and

(vii) any third-party to whom CAM assigns or transfers any of CAM’s rights or obligations.

6. International transfer

User Information may be transferred to and maintained on computers located outside of the Users state, province, country or other governmental jurisdiction, where the privacy laws may not be as protective as those in Users’ jurisdiction. In submitting such User Information, each User specifically agrees to that transfer.

7. Cookies

7.1. CAM also uses “cookies” to collect information. A cookie is a small data file that CAM transfers to electronic device and is stored on the User’s electronic device. When Users access and use the Services, e.g. the Website, the cookie identifies the User’s electronic device. CAM also uses cookies to measure the traffic to and usage of the Services and their different features, and other miscellaneous uses. CAM’s Cookies Policy is set forth herein below.

7.2. If Users do not wish to have cookies placed on their electronic device, Users should set their browser or electronic device to refuse cookies before using the Services, with the drawback that certain features of the Services may not function properly without the help of cookies.

8. Privacy Policy changes

Any future modifications or amendment to this Privacy Policy and/or to the processing of User Information, as described in this Privacy Policy, will be notified to Users in advance through an individual notice through CAM’s usual communication channels (e.g. by email or communication within their Account) as well as through the Website (via banners, pop-ups or other notification mechanisms).

9. Data security

CAM always strive to ensure security, integrity and privacy of the User Information. CAM has adopted and implemented technical and organizational measures to avoid unauthorized access or disclosure of any User Information.

10. Users’ rights

Users may exercise the following rights under the conditions and within the limits set forth under applicable law:

(i) the right to access their User Information, as processed by CAM and, if Users believe that any information relating to them is incorrect, obsolete or incomplete, to request its correction or update;

(ii) the right to request the erasure of their User Information or the restriction thereof to specific categories of processing;

(iii) the right to object to a channel of communication used for direct marketing purposes;

(iv) the right (i) to be informed about any decision making, based the fully automated processing of their User Information, (ii) to express their view on such decision and (iii) to require that it be verified by a human being, except if (a) such decision is directly related to the conclusion of an agreement between CAM and their request is accepted or (b) if they have given their express consent to such automated decision making; and

(v) the right to request their User Information’s portability, i.e. that the User Information Users have provided to CAM be returned to the concerned User or transferred to the person of their choice, in a structured, commonly used and machine-readable format without hinderance from CAM and subject to their confidentiality obligations.

11. Governing law and jurisdiction

11.1. This Privacy Policy and all matters arising out of or relating to this Privacy Policy shall be governed by Swiss law at the exclusion of any provisions of conflict of law rules that might lead to the application of other than Swiss law.

11.2. Users irrevocably submit to the exclusive jurisdiction of the competent courts of Zug, Switzerland, for any conflict arising from or in connection with this Privacy Policy.

12. Questions

For any question about this Privacy Policy or CAM’s policies, please contact CAM at


1. Type of cookies used

1.1. CAM uses several types of cookies. Some are essential, while other Users can opt out of or block. Opting out or blocking some cookies may affect the functionality of the Services.

1.2. The below explanations shall help Users to make informed choices about the information Users provide to CAM when Users access and use the Services, in particular when Users visit the Website.

2. Why and how CAM uses cookies

2.1. There are broadly four reasons why a cookie might be stored on Users’ electronic device when accessing and using the Services:

cookies that make the Services work properly for Users;

cookies that collect data about Users’ use of the Services which is then used on an anonymous basis to help CAM improve the Services;

cookies that remember the personal preferences and make the Services easier for Users to use;

cookies that are placed by third-party services which allow a full access and use of the Services online. CAM has no control over these third-party cookies.

2.2. These cookies are placed on User’s electronic device either by CAM or by the third parties whose services Users use as part of the Services.

2.3. Some cookies are retained in the Users’ electronic device for only as long as Users access and use the Services, while others persist for a longer specified or unspecified period.

3. How to block cookies

Users can restrict or block cookies which are set during use of the Services by changing Users electronic device's or browser’s settings. For more detailed information, see Some Services may not work if Users completely disable cookies, but many third-party cookies can be safely blocked. Check also information in User’s browser's help section for specific instructions on how to manage cookies.

4. Strictly necessary cookies

Some cookies CAM places on the User’s electronic device ensure that the Services, deliver the information and/or Services securely and optimally. Users must accept these cookies to be able to make access and use of the Services.

5. Functionality cookies

Some cookies enable websites to remember choices persons make, for example, user name, and language or text size. These cookies are known as "functionality cookies" and help to improve a person's experience of a website by providing a more personalized service.

6. Performance cookies

CAM uses a number of tools that monitor User’s access and use of the Services to help CAM improve and customize the provided information and/or Services. In particular the Website uses the Cookie Google Analytics which collects information and reports website usage statistics without personally identifying individual visitors to Google. Users can opt out of providing CAM with this information if User wishes so, with no impact on User’s experience of the Website. To opt out of being tracked by Google Analytics when using the Website:

7. Third-party cookies

7.1. The Services use third-party services or software. Many of these services may set cookies on Users’ electronic devices.

7.2. Users can block or remove cookies themselves by altering the settings of their electronic devices or browsers. Blocking these cookies is unlikely to impact on User’s experience of the Services.

8. Cookies set across the Services

8.1 Strictly necessary cookies

CookieCookie name(s)Data storedWhen does it expire?DescriptionAction
hsAuthentication cookieSession id1 year since creationIs used to remember that the user has logged in-
hs-authAuthentication cookieSession id1 year since creationIs used to remember that the user has logged in-
hs-checkoutAuthentication cookieSession id1 year since creationIs used to remember that the user has logged in-
GDPR_CONSENTGDPR consentUser answers10 year since creationRemembers decision of the user with regards to GDPR.-

8.2 Functionality cookies

CookieCookie name(s)Data storedWhen does it expire?DescriptionAction

8.3 Performance cookies

Google AnalyticsUsed to provide statistics about what pages are most visited on the platform (See all cookies)Opt-out
Google TagsUsed to provide statistics about the user experience on the site.
Facebook PixelUsed to provide statistics about the user experience on the site.
IntercomUsed to provide Chat functionality in application and targeted newsletters.
KeenUsed to provide targeted newsletter to customers.
MixpanelUsed to provide targeted newsletter to customers.

8.4 Third-party cookies