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Privacy Policy

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  1. General Information

This privacy policy provides information on how Amicum Capital AG (“Amicum”), in its capacity as a financial institution, collects and processes personal data under its own responsibility.

Amicum is committed to transparent and customer-friendly handling of personal data, and protecting this data is a priority for Amicum. This privacy policy gives you an overview of how Amicum handles personal data and informs you of the rights granted to you by data protection laws.

“Personal data” refers to any information relating to an identified or identifiable natural person. This includes, in particular, contact or master data such as names, telephone numbers, postal and email addresses.

“Processing” refers to any handling of personal data, regardless of the means and procedures used, including collecting, storing, retaining, using, altering, disclosing, archiving, deleting, or destroying personal data.

This privacy policy is addressed to prospective customers, customers, and persons associated with them (e.g., family members and authorized representatives).

If you provide Amicum with personal data of other persons (e.g., family members, authorized representatives), Amicum assumes that you are authorized to do so and that the personal data is accurate. By transmitting third-party personal data, you confirm this. Please ensure that these persons are aware of this privacy policy.

  1. Controller and Contact Information

Amicum is responsible for processing your personal data. To exercise your rights, you can contact Amicum as follows:

NAME: Amicum Capital AG

ADDRESS: Brandschenkestrasse 2, 8001, Zurich, Switzerland

PHONE: +41 44 512 18 80

EMAIL: info@amicum-capital.com

  1. Collection and Processing of Personal Data

Amicum primarily collects and processes personal data provided by the person concerned, such as when establishing business relationships, executing contracts, utilizing products and services, or on websites or other applications. It also processes personal data that arises and is transmitted in the context of utilizing products or services. Amicum may, to the extent permitted, obtain personal data from publicly accessible sources, authorities, or other third parties.

  1. Origin and Categories of Personal Data

Amicum processes personal data that you provide (e.g., during visits, consultations, ordering marketing materials, or service provision) and data that is publicly accessible (e.g., in directories, commercial registers).

Amicum processes various categories of personal data, with the most important being:

  • Communication data (e.g., data in written, telephonic, including mobile applications, or electronic communication)
  • Documentation data (e.g., compliance-related documents, including copies of identification cards or passports, consultation or meeting records)
  • Master and inventory data (e.g., name, address, residence, nationality, date of birth, tax residence, relevant tax documents and information, account information, completed transactions and contracts, information about third parties affected by data processing, such as spouses, partners, children, authorized representatives, and advisors)
  • Financial data (e.g., creditworthiness data, information on assets and their origin, liabilities, risk, and investment profile)
  • Education and employment information, if relevant (e.g., professional title, experience, knowledge in investment matters)
  • Transaction, order, and risk management data (e.g., details of transfer beneficiaries, beneficiary banks, transfer amounts, reasons for transfers, including supporting documents, investment product information)
  • Technical data (e.g., business numbers, IP addresses, internal and external identifiers, access records)
  • Visitor and interest data (e.g., users of websites)
  • Marketing data (e.g., preferences, needs)
  • Communication data (e.g., contact details such as postal and email addresses, phone numbers)
  • Other data (e.g., video or audio recordings, access data)
  • Special categories, where relevant and legally permissible (e.g., information regarding criminal convictions or offenses)

Many of these data categories are provided by the person concerned. The categories of personal data that Amicum receives from third parties may include information from public registers, data related to legal and judicial procedures, credit information, data regarding compliance with legal requirements such as fraud, money laundering, and terrorism prevention, information from banks and other Amicum partners, and data from media and the internet.

  1. Your Rights

You have the right to request access, rectification, deletion, restriction, objection, and, where applicable, data portability. Additionally, there is a right to lodge a complaint with a relevant data protection supervisory authority.

Amicum accepts written requests for information, accompanied by a clear copy of a valid official identification document (e.g., passport, identity card, driver’s license). Contact details are provided in Section 2.

The rights to deletion and objection are not unlimited. Depending on the individual case, overriding interests may necessitate further processing. Amicum reviews each case individually and informs you of the result.

  1. Purpose of Processing

Amicum processes personal data primarily to provide its own services, manage contracts with customers and business partners, and comply with legal obligations.

Additionally, Amicum processes personal data, as permitted and indicated, for the following purposes:

  • Concluding and fulfilling contracts, managing and administering products and services (e.g., invoices, payments).
  • Monitoring and controlling risks (e.g., investment profiles, anti-money laundering measures, limits, market risks).
  • Planning, making business decisions (e.g., developing new or evaluating existing services and products).
  • Marketing, communication, information about service offerings, and reviewing the same (e.g., advertising in print and online, customer, prospective, or other events, determining future customer needs, assessing customer, market, or product potential).
  • Compliance with legal or regulatory obligations in the context of regulatory and compliance obligations (e.g., legal requirements in the financial sector and prevention of money laundering, tax laws).
  • Fulfilling legal or regulatory disclosure, information, or reporting obligations to courts and authorities, fulfilling official orders (e.g., reporting obligations to FINMA and foreign supervisory authorities, orders from public prosecutors related to money laundering and terrorism financing).
  • Preventing and investigating criminal offenses or other misconduct (e.g., through internal investigations).
  • Safeguarding Amicum’s interests and securing claims, e.g., in the event of claims against Amicum or claims by Amicum against third parties.
  • Ensuring operations, particularly IT, website, and other platforms.

If consent has been given for the processing of personal data for specific purposes (e.g., signing up for a newsletter), personal data will be processed within the framework and based on this consent, unless another legal basis is given and necessary. Consent can be revoked at any time, but this does not affect any processing already carried out.

  1. Data Security

Amicum is committed to protecting personal data within its responsibility in accordance with applicable laws. This protection includes appropriate technical and organizational security measures (e.g., access restrictions, firewalls, personalized passwords, encryption and authentication technologies, staff training, etc.).

  1. Disclosure to Third Parties and Data Transfer Abroad

Amicum discloses personal data in the following cases to the following third parties (recipients):

  • For outsourcing according to Section 9 and for customer support to other service providers.
  • To fulfill orders, i.e., when using products or services.
  • In the context of the triangular relationship between the client, custodian bank, and asset manager, forwarding personal data to custodian banks.
  • Due to legal obligations, legal justification, or official orders, e.g., to courts, supervisory authorities, tax authorities, or other third parties.
  • Where necessary to protect legitimate interests, e.g., in the event of legal action threatened or initiated by customers against Amicum, in public statements, to secure Amicum’s claims against customers or third parties, in debt collection, etc.
  • With the consent of the affected individuals, to other third parties.
  • To lawyers, auditors, accountants, insurers, and other third parties who provide legal, auditing, accounting, or insurance services for Amicum.

Recipients of personal data are usually located within the country. In particular, when using certain products or services, personal data may also be disclosed to third parties outside Switzerland (e.g., Europe).

If a recipient is located in a country without adequate data protection levels, Amicum obliges the recipient to comply with applicable data protection laws (e.g., through standard contractual clauses), unless the recipient is already subject to a legally recognized framework to ensure data protection, or Amicum relies on an exception.

  1. Outsourcing of Business Areas or Services (Outsourcing)

Amicum outsources certain business areas and services wholly or partially to third parties.

The service providers processing personal data on behalf of Amicum (so-called processors) are carefully selected. Wherever possible, Amicum uses processors domiciled in Switzerland. Processors may, in some cases, be entitled to have certain services provided by third parties.

The processors may only process personal data received in the same way as Amicum itself as the sole controller and are contractually obligated to ensure the confidentiality and security of the data.

  1. Use of Websites and Cookie Policy

When a person visits the Amicum website, the web server automatically records details of their visit (e.g., the website from which the visit takes place, the visitor’s IP address, the content of the Amicum website accessed, including the date and duration of the visit). Such tracking data is used to optimize the Amicum website and provides information on how visitors use and navigate through Amicum’s products, services, and offers. However, such tracking data typically does not allow conclusions about the visitor’s identity. Therefore, no personal data is processed.

Additionally, by using the Amicum website, a visitor agrees to the use of cookies. Cookies are small files stored on the visitor’s computer to track the respective website visit and navigation between different pages and/or save settings (e.g., selected language). Cookies are used to collect statistical data about the frequency and timing of visits to individual website areas and help to design tailored, useful, and user-friendly websites. The visitor can opt-out of the use of cookies at any time by deleting the cookies set by the Amicum website. Deletion is possible through the visitor’s internet browser settings.

  1. Retention Period

The retention period for personal data depends on the purpose of the respective data processing and/or legal retention and documentation obligations, which, depending on the applicable legal basis, may be five, ten, or more years. Once personal data is no longer required for the above purposes, it will generally be deleted or anonymized as far as possible.

  1. Rights of the Data Subject

Anyone can request information from Amicum about whether personal data concerning them is being processed. There is a right to object, restrict processing, and, where applicable, the right to data portability. Incorrect data can be corrected. Moreover, the deletion of personal data can be requested, provided there are no legal or regulatory requirements (e.g., legal retention obligations for business-relevant data) or technical barriers. The deletion of data may result in the inability to provide certain services. Additionally, where applicable, there is a right to lodge a complaint with a competent authority. If Amicum processes personal data based on consent, this consent can be revoked at any time. It should be noted that Amicum reserves the right to invoke legally prescribed restrictions, for example, when they are required to retain or process certain data, have an overriding interest in doing so (if they are allowed to rely on it), or need the data to assert claims.

  1. Changes to Personal Data

To keep your personal data properly updated and accurate, Amicum will periodically ask you to review and confirm your personal data and/or notify us of any changes to your personal data.

  1. Changes

This privacy policy is not a contractual component between Amicum and you. Amicum may amend this privacy policy at any time without prior notice. The current version published on Amicum’s website applies.