Last modified on 30 December 2019

Privacy Introduction

Your privacy is critically important to us. Wee have a few fundamental principles:

  • We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
  • We store personal information for only as long as we have a reason to keep it.
  • We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
  • We help protect you from overreaching government demands for your personal information.
  • We aim for full transparency on how we gather, use, and share your personal information.

Definitions

  • Customer Relationship Management (CRM) is a technology for managing a company’s relationships and interactions with customers and potential customers.
  • General Data Protection Regulation (GDPR) is the European Union law for data protection.
  • Information Security Management System (ISMS) is a set of policies and procedures for systematically managing sensitive data. The goal of an ISMS is to minimize risk, ensure business continuity, and pro-actively secure sensitive information.
  • International Organization for Standardization (ISO) is an organization, headquartered in Switzerland, that sets internationally-accepted standards across a number of fields, including information security.
  • Personal Information Protection Act (PIPA) is the British Columbia law on data protection.
  • Personal Information Protection and Electronic Documents Act (PIPEDA) is the Canadian Federal-level law governing data protection.
  • Personally Identifiable Information (Personal Data) is any data that could potentially identify a specific individual.

What is swissam.ch and what legislation do we adhere to?

The website www.swissam.ch is a website owned by Swiss International Asset Management AG (Swiss IAM), for asset management services.

Your privacy is very important to us. Because of our international reach, we adhere to the highest legislative standards, including the Swiss Federal Act on Data Protection, and equivalent international legislation such as the GDPR).

The General Data Protection Regulation (GDPR) has been in force since May 2018 and regulates the data protection practices of any companies which deal with all personal data of private individuals in the EU, irrespective of whether these companies are based in the EU or not. Since the 28 member states of the EU together constitute the world’s biggest economy, and since 80 nations are their most important trading partners, many companies all over the world buy and sell goods and services to EU people.

What data does Swiss IAM collect through our website?

We collect only the data that we need to respond to your inquiries or to provide you with the services you request from us. Specifically we collect the following data:

  • We collect the Internet Protocol (IP) address of the device you use to browse www.swissam.ch. This data on its own is anonymous and we are unable to identify you on this alone.
  • Personal identification information (Name, email address, phone number, etc.)
  • We also collect cookies, which are small files that a site or its service providers embed on your computer (with your permission) to enable the site’s or service providers’ systems to recognize your browser and capture and retain certain information. Learn more about cookies here. For more information on how we use cookies, and how to change your cookies preferences, please also read our complete Cookie Policy.

Optional information sharing

  • If you choose to communicate with us via chat, as applicable, we will collect your name and your email, as well as logs of your chat with our staff.
  • If you choose to subscribe to our newsletter, we will collect your name and your email address. Newsletters may be sent periodically with highlights and news about our industry and particular companies. You can unsubscribe from the newsletter at any time by updating your email preferences using the ‘Click here to opt out’ link, or by sending an email to dpo(at)swissam.ch with the subject line “UNSUBSCRIBE” from the email address you wish to unsubscribe.
  • If you choose to contact us directly, the contact forms on our website collect your name, email address, contact number, company name and any free text field information you choose to include.
  • Note: at the completion of a contact form, your IP address is no longer anonymous, and we will be able to identify you by the combination of your IP and contact information.

Your information may be transferred internationally

Personal information that you share through the www.swissam.ch website may be transferred internationally, including to or through areas where the standards for data privacy differ from those in force in Switzerland.

Some of these countries may not be among those listed by the EU Adequacy Decisions.

Please see the section below for additional detail.

Why do we collect your data?

We collect your data for the following purposes:

  • To fulfill a contract to supply our goods or services.
  • For legal compliance, such as to fulfil our AML-KYC compliance duties or for due diligence purposes.

How is your information collected?

We may collect certain sensitive information from clients manually to fulfill AML-KYC requirements including but not limited to passports, KYC forms, source of funds statement, bank references, bank account balance and signatory information and copies of statements, criminal background information, proof of residence address,

We may collect certain sensitive information from clients or potential clients manually to fulfill due diligence requirements including but not limited to passports of intended clients and related information such as full name, nationality and date of birth as well as residence address, telephone numbers, email addresses, marital status, CVs and criminal background information and proof of residence address.

We may collect certain sensitive information from clients or potential clients manually in the process of procuring an agreement with you. Such information and requirements may include but not limited to passports of intended shareholders and related information such as full name, nationality and date of birth as well as residence address, telephone numbers, email addresses, marital status (as required for the regulators in Switzerland) CVs and criminal background information and proof of residence address.

Information is also collected automatically (with your consent) from Cookies. Cookies are discussed in more detail herein, and in our Cookies Policy. You can always disable Cookies by clicking the “Privacy and Cookie Statement” tab in the lower right hand corner of our website.

Information is also collected and stored via various newsletter and/or contact forms on our website (see next section for full list)

Sign-up and contact forms

Personal data that Swiss IAM collects through forms on the www.swissam.ch website might be collected and processed by the following third-parties:

RSFormPro is a component provided by RS Joomla, a company not affiliated with Joomla. RS Joomla processes and stores your data in RS Joomla servers. In addition to the data that you manually enter in the form, RS Joomla’s RSFormPro also receives your IP address and location. Learn more about how RS Joomla processes your data.

Rapid Contact is a Joomla contact form module developed by Mavrosxristoforos.com. Rapid Contact processes and stores your data in Rapid Contact servers Learn more about how Rapid Contact processes your data.

Contact Form 7 is a WordPress plugin. Contact Form 7 processes and stores your data in Contact Form 7 servers. In addition to the data that you manually enter in the form, Contact Form 7 also receives your IP address and location. Learn more about how Contact Form 7 processes your data.

We also store and access personal information collected through our website subscriber function via The Newsletter Plugin. The Newsletter Plugin processes personal data in accordance with a variety of well-documented standards. Where The Newsletter Plugin transfers data outside the EEA, the Privacy Shield Principles are adhered to. Learn more about how The Newsletter Plugin processes your data.

How do we store your data?

We securely store your data in our computer hard drive database. We use the following technical measures to prevent data breeches:

  • Encryption, adequate password protection, firewalls and regular computer updates.
  • Ongoing security reviews.
  • Back-up and restore facilities.
  • Regular testing of contingency plans and security.
  • Educating staff about how to keep information secure, including hacking, phishing and other malware issues.
  • Ensuring policies on IT and related device use are kept up to date.

For data collected for AML-KYC purposes, as applicable, such as passport copies, criminal reports, CVs, source of funds reports, etc. (“AML Data”), we use encrypted software mechanism “1Passord” and we will keep the data for 10 years. Once this time period has expired, we will delete your data from our computer hard drive(s) and destroy any hard copies in our possession.

1Password is an independent software mechanism we use to protect sensitive data on our hard drives. Learn more about how 1Password processes your data.

We will keep your other data only as long as is necessary. Once this time period has expired, we will delete your data from our hard drive(s) and destroy any hard copies in our possession.

How will we use your data?

  • Where you provide it, and consent, your email address may be used:
    • to send you information and updates related to your specified interests,
    • to send you occasional company news, updates, and
    • to provide related product or service information.
  • We collect website performance data, which includes visitor IPs and cookies, to understand:
    • how many users visit our site,
    • how users interact with our site, and
    • how we can improve site performance.
  • We use your data to conduct due diligence.
  • We use your data to satisfy legal requirements.
  • We use your data to fulfill a contract.
  • We may use the information you provide to improve the effectiveness of our advertising and marketing campaigns, and to improve, modify or otherwise enhance our products and services for the benefit of our customers.
  • We use GlobalPass to analyse passports, documents for AML-KYC related information to assist us in satisfying our KYC obligations and also in furtherance of the due diligence process leading to the procurance of an agreement with our clients. Globalpass processes and stores data in ISO 27001 certified datacentres worldwide. Learn more about how GlobalPass processes your data. When you send us these documents, you authorize us to analyze them using GlobalPass.

How long will your information be stored for?

We will retain your information until you notify us that you’d like to be removed from our contact lists.

For data collected for AML-KYC purposes, as applicable, such as passport copies, criminal reports, CVs, source of funds reports, etc. (“AML Data”), we will keep the data for 10 years. Once this time period has expired, we will delete your data from our computer hard drive(s) and destroy any hard copies in our possession.

Will your information be disclosed to outside parties?

Swiss IAM does not sell, trade, or otherwise transfer your Personal Data to outside parties without your express consent.

Express consent to share your Personal Data is not required in the case of trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep your information confidential (refer to ‘How is your information collected and stored?’).

Swiss IAM does release your Personal Data in cases where we believe such release is necessary to comply with the law, enforce our site policies, in its duty to conduct AML-KYC or protect our or others’ rights, property, or safety.

Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third-party offers on the this website

Occasionally, at our discretion, we may refer to third-party products or services on our website. Use of these third-party products or services will require your acceptance of a services agreement.

These third parties have separate and independent privacy policies. Swiss IAM has no responsibility or liability for, nor direct control over, the content and activities of these third parties.

What are your data protection rights?

Swiss IAM would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete the information you believe is incomplete.

The right to erasure – You have the right to request that Swiss IAM erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that Swiss IAM restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to Swiss IAM’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Swiss IAM transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: dpo(at)swissam.ch.

Please note that all requests under the rights listed above must be made in writing either by letter or email to dpo(at)swissam.ch or at the following address: Swiss International Asset Management AG C/O DPO, Rigistrasse 2, 6300 Zug, Switzerland.

Please be aware that requests for rights may require subsequent verification procedures to confirm the requestor’s identity.

We may make changes to this Privacy Policy

We may, solely at our discretion, make changes or updates to this policy. If we make changes, we will post those changes on this page, and update the Website Privacy Policy modification date at the top of this Privacy Policy.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Swiss IAM has not addressed your concern in a satisfactory manner, you may contact The Federal Data Protection and Information Commissioner (FDPIC).

Contact us

If you have any questions regarding this privacy policy, please contact by one of the following methods:

  • send an email to dpo(at)swissam.ch; or
  • call us at +41 41 588 05 02; or
  • write to us at: Swiss International Asset Management AG, C/O DPO, Rigistrasse 2, 6300 Zug, Switzerland.