Privacy policy

Controller

No data protection officer has been appointed, because the statutory conditions for one are not met. For any question about data protection you can reach us at the details above.

What this website does not do

It is quickly said — and it is the reason this statement stays as short as it does:

• No analytics services from Google, Meta or anyone else.
• No advertising networks, no tracking pixels, no recognition across visits or across websites.
• No embedded fonts, maps, videos or scripts from external servers. The typefaces are on our own server too — your browser makes not a single connection to a third-party provider when visiting this page.
• No storage of your IP address in our database.
• No sale and no rental of data to third parties.

Visiting the website (server logs)

When a page is requested your browser transmits technically necessary details to the server this website sits on: the address requested, the time, the volume of data transferred, the browser type and the IP address. These logs arise at our hosting provider and serve operation, troubleshooting and the defence against attacks. We do not evaluate them in a personally identifiable way and do not combine them with other data.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in secure and trouble-free operation. The logs are deleted automatically after a short time.

Audience measurement without recognition

We want to know which pages are read — not who reads them. Our measurement runs on our own server and stores totals only: the date, the page requested, the domain of the referring website and the campaign identifiers from the address bar (utm_source and similar). No individual visitor can be reconstructed from an entry; further requests merely increase a counter.

Since August 2026 we additionally count how pages are read — again only as a total per page and day:

• what scroll depth was reached (25, 50, 75 or 100 per cent)
• how long a page was open, in broad bands from "under ten seconds" to "over ten minutes"
• whether a phone number, an email address or a button was clicked — what is recorded is the label of the element, never text you have entered
• whether the window was phone, tablet or desktop width

These figures are not linked to one another and not to your visit. No session, no identifier and no profile arises — only counters such as "page X, 18.08.2026, scroll depth 75%, 14 views". We cannot read from it how you moved through the site, only how all visitors to a page behave taken together. That is why we continue to manage without a cookie and without a consent banner.

In doing so no IP address, no identifier and no cookie is stored. No personal data arises.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in understanding and improving our own website.

Cookies

This website sets one single cookie — and not even that on every visit. It is called PHPSESSID, contains only a random session number with no connection to you personally, and is deleted when the browser closes.

All three cases are strictly necessary for the service you have asked for. No consent is required for that (§ 25(2)(2) TDDDG) — which is why you see no banner here.

Contact form and consultation enquiries

If you write to us through the form or by email, we store your details in our database in order to handle your enquiry. What is recorded:

• your name and, if given, your form of address and company
• your email address and, if given, your phone number and postal address
• your message and the apartment you are interested in
• the time of your consent and the source you came to us through

Legal basis: Art. 6(1)(b) GDPR for handling your enquiry and initiating a contract, and in addition Art. 6(1)(a) GDPR for the consent you give when you send the form. You can withdraw that consent at any time without formality — an email is enough. The lawfulness of the processing carried out up to that point is unaffected.

Retention: we delete your details as soon as they are no longer needed to handle the enquiry, and at the latest 24 months after the last contact — unless a contract has come about or statutory retention periods say otherwise.

The adviser in the chat window

Bottom right you can open an automated adviser. It answers questions about the project, the purchase process and the topics in the guides. It is a language model, not a person — the window says so too.

What is transmitted: your messages and the adviser's previous answers go to OpenAI, our processor for this service, in order to generate the next answer. The call is made from our server — your browser builds no connection to OpenAI. We transmit no identifier, no IP address and no name; OpenAI receives only the text of the conversation.

Third country: OpenAI also processes data in the United States. The transfer is based on the European Commission's standard contractual clauses and on the fact that, by its own account, OpenAI does not use content from the programming interface to train its models.

Please do not enter special category data in the chat — on health, origin or political views, for example. The adviser does not ask for it and does not need it. If you want to discuss medical treatment, please do so in person rather than here.

What we store: the course of the conversation on our own server, so that an adviser can read up on what it was about and so that we can improve the answers. Along with that the date, the number of messages and the source you came to us through. Conversations without any contact being made are deleted after 90 days at the latest. If you give your contact details in the conversation for a call back, the periods in the section "Contact form and consultation enquiries" apply; we tell you in the chat beforehand that the details are passed on to the seller in Georgia.

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in giving interested buyers a quick answer. You can object to the processing at any time; simply do not use the adviser, or write to us.

No automated decision about you: the adviser does not assess you and takes no decisions. It answers questions and, if you ask it to, passes your details on.

Documents on the guide topics

On the guide pages you can request a document as a PDF. For that we store your name, your email address, the topic chosen, the time of your consent and — where there is one — the source you came to us through. The document is generated afresh on each download and carries your name; we count whether and when it was downloaded.

We do not pass these details to the seller in Georgia. They stay with us as long as you have only requested a document. Only when you want an offer or advice on a specific apartment does the next section come into play — and we tell you so beforehand.

Legal basis: Art. 6(1)(a) GDPR — your consent, which you give when sending the form and can withdraw at any time without formality. Retention: as for enquiries, at the latest 24 months after the last contact.

Transfer to the seller in Georgia

This website makes introductions. If you want advice or an offer, we pass your contact details and your purchase interest to the seller of the apartments — AIXCO Global Assets GmbH, based in Adlia Street 59, Batumi, Georgia — and where applicable to an agent instructed by them. Without this transfer we cannot handle your enquiry, because we do not sell ourselves.

Georgia is a third country. There is no adequacy decision of the European Commission for Georgia. The level of data protection there therefore does not necessarily correspond to that of the GDPR; in particular it is not guaranteed that you can enforce your rights there as effectively as in the EU or Switzerland.

Legal basis for the transfer: Art. 49(1)(b) GDPR — the transfer is necessary for pre-contractual measures taken at your request; in addition your express consent under Art. 49(1)(a) GDPR. For Switzerland Art. 17 FADP applies correspondingly.

If you do not want this transfer, please tell us — we will then take your enquiry no further and delete your data.

Personal offers

On request we prepare a personal offer for you as a PDF file. It is produced on our own server from your details and the property data; no external service is involved. It is sent from our own mailbox.

Recipients of your data

Beyond that we pass data on only where we are legally obliged to.

Your rights

You have the right to information about the data stored about you, to rectification of inaccurate data, to erasure, to restriction of processing, to data portability, and the right to object to processing. You can withdraw consent once given at any time.

An informal email to info@batumi.ch is enough. We reply within one month.

Right to complain: you can complain to a supervisory authority. In Switzerland that is the Federal Data Protection and Information Commissioner (FDPIC), in the EU the data protection authority of your country of residence.

No automated decision-making

We take no decisions about you based solely on automated processing. The investment calculator on this website works with the values you set yourself; its result is neither stored nor evaluated.

Security

Transmission is encrypted over HTTPS. The administration area is password-protected; passwords are stored only as an irreversible hash. The database cannot be reached through the web server and is additionally locked down on the server side.

Changes to this statement

We adapt this statement when the website or the legal position changes. The version published here at the time applies. As of: 18 August 2026.