This privacy statement was last updated on August 9, 2023 and applies to citizens and legal permanent residents of the European Economic Area and Switzerland.
In this privacy statement (the “Privacy Statement”), we explain what we do with the data we obtain about you. We may collect data via https://www.patrimonium.ch or when you interact with us, for example when you communicate with our staff, sign up to receive information by e‑mail, or participate to a meeting, a seminar or other events. We also collect or generate personal data in the course of providing our services, and we may collect personal data from other sources for example to keep your information up to date using publicly available sources. We recommend you carefully read this Privacy Statement. In our processing we comply with the requirements of privacy legislation. That means, among other things, that:
- we clearly state the purposes for which we process personal data. We do this by means of this Privacy Statement;
- we aim to limit our collection of personal data to only the personal data required for legitimate purposes;
- we first request your explicit consent to process your personal data in cases requiring your consent;
- we take appropriate security measures to protect your personal data and also require this from parties that process personal data on our behalf;
- we respect your right to access your personal data or have it corrected or deleted, at your request.
The controller of your personal data is Patrimonium Asset Management AG. References in this Privacy Statement to “we” or “us” are references to the controller.
This Privacy Statement applies to personal data collected from users of our website as well as our customers (including third parties which may be related to our customers, e.g. authorized representative, authorized signatory, holder of a power of attorney, director, beneficial owner, potential new client / prospect). All these data subjects are hereinafter referred to as “you”.
if you provide us with personal data relating to another person, it is your responsibility to provide such person with this Privacy Statement and, where necessary, to obtain their consent.
If you have any questions, or want to know exactly what data we keep of you, please contact us. We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by contacting us at the address indicated below, in Section 10.
1. Purpose, data and retention period
We may collect or receive personal information for a number of purposes connected with our business operations which may include the following:
1.1 Contact – Through phone, mail, email and/or webforms
For this purpose we use the following data:
- A first and last name
- A home or other physical address, including street name and name of a city or town
- An email address
- A telephone number
- IP address
- Geolocation data
- Professional or employment-related information
The basis on which we may process these data is:
Upon the provision of consent.
Retention period
We retain this data upon termination of the service for the following number of months: 12
1.2 Newsletters
For this purpose we use the following data:
- A first and last name
- An email address
- IP address
- Professional or employment-related information
The basis on which we may process these data is:
Upon the provision of consent.
Retention period
We retain this data until the service is terminated.
1.3 Compiling and analyzing statistics for website improvement.
For this purpose we use the following data:
- Internet activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
The basis on which we may process these data is:
Upon the provision of consent.
Retention period
Upon termination of the service we retain this data for the following period: 12 months.
1.4 Collecting information on customer, business relations and prospects
For this purpose we use the following data:
- your name and contact details (for example name, address, phone number or email address), information about the company you work for, your position or title, your family situation (civil status, number of children), your relationship to a person, authentication data (for example specimen signature) and other basic information;
- identification and background information provided by you or collected as part of our on-boarding process;
- financial information, for example payment-related information, creditworthiness data, scoring/rating data, origin of assets;
- tax situation;
- information in relation to products and services;
- information provided to us by you or on your behalf or generated by us in the course or providing services to you;
- information provided to us for the purposes of attending meetings, seminars and events, including data from interactions between you and us (for example meetings, calls, emails, documents exchanged);
- information in relation to materials and communications we send to you electronically, for example your use of marketing e-mails;
- and other data similar to the categories mentioned.
Retention period
We retain this data until the service is terminated.
2. Why do we use your personal data and on what legal basis ?
We process your personal data in accordance with the applicable Swiss Federal Data Protection Act, as follows:
2.1 To fulfil our contractual obligations:
- to comply with and enforce the applicable terms of contracts;
- to communicate with you;
- to provide our services to you;
- to administer our relationship with you, including to send you administrative information;
- to manage our pre-contractual relationship with you and, subsequently, to start a business relationship with you.
2.2 to comply with our legal and regulatory obligations:
- to follow all formalities that we have to undertake relating to your identification as a customer;
- to comply with regulations related to the prevention of money-laundering, financial crime, financing of terrorism and market abuse;
- to set up measures to prevent abuse, fraud and money laundering;
- to comply with regulations related to sanctions and embargoes;
- to comply with regulations related to financial markets;
- to comply with our regulatory obligations;
- to fight against tax fraud and to comply with any applicable tax supervision and reporting obligations; and
- to comply with any applicable reporting obligation.
2.3 To pursue our legitimate interests:
- to improve our business and to improve the quality of our services;
- to develop our relationship with you;
- to provide and improve our websites, including monitoring and evaluating its use (see “Use of our websites and e-mails” below for additional information);
- to promote our services, including by sending alerts, updates, event invitations etc., unless you have objected to the use of your data in this respect;
- in relation to credit checks;
- to prevent, detect and investigate crimes (in particular fraud);
- to establish, assert and/or defend actual or potential legal claims;
- to prove transactions;
- to ensure the security of our premises and infrastructures (such as access controls);
- to ensure our IT security and IT operations;
- to train our personnel (e.g. by recording phone calls);
- for risk management purposes within our Group.
2.4 On the basis of your consent
Where we would need to process personal data for purposes other than those listed in sections 1 and 2 above, we shall inform you, and, where necessary, request your consent.
In addition, you acknowledge that, as long as you have granted us your consent to process your personal data for certain purposes, this processing is legal on the basis of your consent. Consent given can be withdrawn at any time. Withdrawal of consent does not affect the legality of data processed prior to withdrawal.
Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal data if is it:
- required or permitted by law;
- necessary for the performance of a contract to which you are a party;
- necessary for the performance of a task carried out in the public interest, or
- necessary for our overriding legitimate interests, including the establishment, exercise or defence of legal claims.
We will not use your personal data for marketing purposes if you have objected to such processing.
3. Cookies
Our website uses cookies. For more information about cookies, please refer to our Cookie Policy.
4. Disclosure practices
4.1 In general
We disclose personal information if we are required by law or by a court order, in response to a law enforcement agency, to the extent permitted under other provisions of law, to provide information, or for an investigation on a matter related to public safety.
If our website or organisation is taken over, sold, or involved in a merger or acquisition, your details may be disclosed to our advisers and any prospective purchasers and will be passed on to the new owners.
We have concluded a data Processing Agreement with Google.
Google may not use the data for any other Google services.
The inclusion of full IP addresses is blocked by us.
4.2 Who do we share your personal data with ?
Within our company, every department which requires personal data to fulfill our contractual and legal obligations shall have access to it, on a need-to-know basis only.
In addition, we may share your personal data with entities of our group, as well as trusted third parties including:
- Providers to whom we outsource certain support services such as administrative and management services (e.g., accounting);
- Payment service providers;
- IT service providers;
- Certain types of professionals (e.g. legal advisors, accountants, auditors, insurers and tax advisors);
- Credit agencies and/or encashment agencies (for credit checks purposes);
- Courts, tribunals, regulatory authorities, government agencies and law enforcement agencies, upon request and to the extent permitted by law.
We may also be required to disclose your information to comply with legal or regulatory requirements. In this case, you understand that, if you withdraw or refuse your consent to such transfer, we may be precluded from having a relationship with you and/or from rendering all or part of our services to you.
Through the selection of data processors and suitable contractual agreements, we ensure that data protection is also ensured by third parties during the entire processing of your personal data. Our data processors are obliged to process your personal data exclusively on our behalf and according to our instructions.
4.3 to which countries may we transfer your personal data to ?
We may transfer your personal data to recipients outside Switzerland:
- in the context of the conclusion or execution of contracts directly or indirectly related to the business relationship (i.e. a contract concluded with you or with a third party, but in your interest);
- it is required by law;
- where such a transfer is necessary to safeguard an overriding public interest;
- where such a transfer is necessary to enable us to establish, enforce or oppose a current or future claim, or to enable us to handle an investigation by a public authority, in Switzerland or abroad; and
- where you have given your consent.
If such a transfer of personal data is made to a country that does not provide an adequate level of protection as Swiss law, we will, if required by applicable law, either 1. obtain your consent or 3. implement appropriate contractual, technical and/or organisational safeguards to ensure that your personal data is protected, for example by requiring the recipient to agree to data processing agreements.
The list of destination countries may be found under the following link
To obtain more details on international data transfers, you may contact us, at the address provided for in Section 10 below.
5. Security
We are committed to the security of personal data. We take appropriate security measures to limit abuse of and unauthorized access to personal data. This ensures that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed. These technical and organizational measures help protect your personal data from unauthorized access, use, disclosure, alteration or destruction.
6. Third-party websites
This Privacy Statement does not apply to third-party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of these websites.
7. Amendments to this privacy statement
We reserve the right to make amendments to this Privacy Statement. It is recommended that you consult this Privacy Statement regularly in order to be aware of any changes. The most current version of the Privacy Statement will be posted on our website. In addition, we will actively inform you wherever possible.
8. Accessing and modifying your data
If you have any questions or want to know which personal data we have about you, please contact us. You can contact us by using the information below. You have the following rights:
- You have the right to know why your personal data is needed, what will happen to it, and how long it will be retained for.
- Right of access: You have the right to access your personal data that is known to us, i.e., the right to obtain information with respect to the data we process, as well as to receive a copy of your personal data.
- Right to rectification: you have the right to supplement, correct, have deleted or blocked your personal data whenever you wish, to the extent permitted by law.
- If you give us your consent to process your data, you have the right to revoke that consent. However, such withdrawal only applies to the future; processing that was carried out before the withdrawal is thus not affected by it.
- Right to transfer your data: you have the right to request all your personal data from the controller and transfer it in its entirety to another controller.
- Right to receive your personal data that you have provided us with, in a commonly used and machine-readable format.
- Right to object: you may object to the processing of your data. We comply with this, unless there are justified grounds for processing.
Please make sure to always clearly state who you are, so that we can be certain that we do not modify or delete any data of the wrong person
9. Submitting a complaint
If you are not satisfied with the way in which we handle (a complaint about) the processing of your personal data, you have the right to submit a complaint to the Data Protection Authority.
10. Contact details
Patrimonium Asset Management AG
Zugerstrasse 74
6340 Baar
Switzerland
Website: https://www.patrimonium.ch
Email: privacy@patrimonium.ch
Phone number: +41 58 787 00 00
