Privacy Policy
Effective Date: 22 February 2026
The Vanderbilt Portfolio AG (“Publisher,” “we,” “us,” or “our”) operates the WE THE UAE 2031 website at wetheuae2031.com (the “Platform”). This Privacy Policy explains how we collect, use, store, and protect information when you access or use the Platform.
We are committed to protecting your privacy and handling your data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).
1. Data Controller
The data controller responsible for processing personal data collected through this Platform is:
The Vanderbilt Portfolio AG [email protected]
2. Information We Collect
2.1 Information Collected Automatically
When you visit the Platform, certain information is collected automatically through cookies and similar technologies. This may include:
- IP address (anonymized where required by law)
- Browser type and version
- Operating system
- Referring URL
- Pages visited on the Platform
- Date and time of access
- Approximate geographic location (country or region level)
- Device type and screen resolution
2.2 Information You Provide Voluntarily
If you subscribe to our newsletter, create an account, or contact us, we may collect:
- Email address
- Name (if provided)
- Organization name (if provided)
- Content of your correspondence
2.3 Subscription and Payment Data
If you purchase a subscription, payment processing is handled by our third-party payment provider. We do not store credit card numbers, bank account details, or other sensitive financial information on our servers. Our payment processor may collect information necessary to complete transactions in accordance with its own privacy policy.
3. How We Use Your Information
We use the information collected for the following purposes:
- Platform operation: To deliver content, maintain functionality, and ensure security.
- Analytics: To understand how visitors use the Platform, identify popular content, and improve the user experience.
- Communication: To respond to inquiries, send newsletter digests to subscribers, and provide subscription-related notifications.
- Advertising: To display relevant advertisements through third-party advertising services.
- Legal compliance: To comply with applicable laws, regulations, and legal processes.
4. Third-Party Services
We use the following third-party services that may collect data through the Platform:
4.1 Google Analytics (GA4)
We use Google Analytics 4 to collect and analyze visitor traffic data. Google Analytics uses cookies to collect anonymized information about how visitors use the Platform. This data is processed by Google LLC in accordance with its privacy policy. IP anonymization is enabled.
You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on or by adjusting your cookie preferences on this Platform.
4.2 Google AdSense
We use Google AdSense to display advertisements on the Platform. Google AdSense may use cookies and web beacons to serve advertisements based on your prior visits to this Platform and other websites. Google’s use of advertising cookies is governed by its own privacy policy.
You may opt out of personalized advertising by visiting Google Ads Settings or the Network Advertising Initiative opt-out page.
4.3 Substack
Our newsletter is delivered through Substack. When you subscribe to the free newsletter, your email address is collected and processed by Substack Inc. in accordance with its privacy policy. We use Substack solely for newsletter delivery.
5. Cookies
The Platform uses cookies and similar tracking technologies. For detailed information about the types of cookies we use and how to manage them, please see our Cookie Policy.
6. Legal Basis for Processing (GDPR)
For users in the European Economic Area (EEA), the United Kingdom, and Switzerland, we process personal data on the following legal bases:
- Legitimate interest: For analytics, Platform improvement, and security monitoring, where our legitimate interests are not overridden by your data protection rights.
- Consent: For non-essential cookies, personalized advertising, and newsletter subscriptions. You may withdraw consent at any time.
- Contractual necessity: For processing data related to paid subscriptions and service delivery.
- Legal obligation: Where processing is required to comply with applicable laws.
7. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this policy:
- Analytics data: Retained for up to 26 months, in accordance with Google Analytics default settings.
- Newsletter subscriber data: Retained for the duration of the subscription, plus 30 days following unsubscription.
- Correspondence: Retained for up to 24 months following the last communication.
- Subscription account data: Retained for the duration of the subscription and for a reasonable period thereafter to comply with legal and accounting obligations.
After the applicable retention period, personal data is deleted or anonymized.
8. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Access: The right to request a copy of the personal data we hold about you.
- Rectification: The right to request correction of inaccurate or incomplete data.
- Erasure: The right to request deletion of your personal data, subject to legal retention requirements.
- Restriction: The right to request restricted processing of your data in certain circumstances.
- Data portability: The right to receive your data in a structured, commonly used, machine-readable format.
- Objection: The right to object to processing based on legitimate interest, including profiling.
- Withdraw consent: The right to withdraw consent for processing based on consent, without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at: [email protected]
We will respond to verifiable requests within 30 days, or within the timeframe required by applicable law.
9. International Data Transfers
Your data may be transferred to and processed in countries outside the EEA, including the United States (in connection with Google services). Where such transfers occur, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission or reliance on the service provider’s certification under applicable data transfer frameworks.
10. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, and regular security reviews. However, no method of electronic storage or transmission is entirely secure, and we cannot guarantee absolute security.
11. Children’s Privacy
The Platform is not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If you believe that a child has provided us with personal data, please contact us so that we can take appropriate action.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.
13. Contact
For questions or concerns about this Privacy Policy or our data practices, contact:
The Vanderbilt Portfolio AG [email protected]
This Privacy Policy was last updated on 22 February 2026.