Legal Protocols
Effective Date: January 1, 2026 | Compliance: Swiss Federal Act on Data Protection (revDSG/nFADP)
1. CONTROLLER & JURISDICTION
1.1 Legal Controller:
The Data Controller is Alain Walder (Walder Capital), domiciled in Neuchâtel, Switzerland.
1.2 Swiss Law Primacy:
All data processing is governed exclusively by Swiss Law. We explicitly disclaim the jurisdiction of the GDPR for users residing outside the EU/EEA, operating solely under the sovereign framework of the Swiss nFADP.
2. THE "DATA FORTRESS" ARCHITECTURE
2.1 Data Residency:
All proprietary client financial data is hosted exclusively on Swiss Soil (Zurich Region) via ISO-27001 certified infrastructure.
2.2 Isolated Computation:
Financial computations (Valuation/Solvency) are performed on air-gapped or isolated instances to prevent cross-contamination.
2.3 Non-Export Policy:
No sensitive financial data is transferred to jurisdictions lacking an adequacy decision by the Swiss Federal Data Protection and Information Commissioner (FDPIC).
3. THE "BLIND MARKET SOUNDING" PROTOCOL
3.1 Anonymization Mandate:
By using our diagnostic tools, you authorize Walder Capital to process your raw data into a "Sanitized Blind Profile" (The Asset). This profile is stripped of all "Personal Data" (Name, Address, UID) as defined by Art. 5 nFADP.
3.2 Circulation Consent:
You explicitly consent to the discrete circulation of this Sanitized Blind Profile to our vetted network of Institutional Investors for the purpose of "Market Sounding" (Interest Verification).
3.3 The "Veto" Release:
Your actual identity (Personal Data) is never disclosed to a Capital Partner without your specific, written "Release Authority" for that specific partner.
4. DATA RETENTION & DELETION
4.1 Retention:
Data is retained for the duration of the mandate or "Market Test."
4.2 Right to Erasure:
Users may request the permanent deletion of their raw data at any time via legal@valindex.ch, provided no regulatory retention obligation (e.g., Art. 957 CO) exists.