Data Privacy Statement

1. What is this privacy policy about?

The Swiss Three Asset Management (hereinafter also "we", "us") obtains and processes personal data , which concerns you or also other persons (so-called "third parties"). In this privacy policy, we describe what we do with your data when you use (hereinafter "website") , obtain our services or products, otherwise deal with us under a contract, communicate with us or other-wise deal with us.

If you transmit or disclose data to us about other persons, such as family members, we assume that you are authorised to do so, and that this data is correct. By submitting data about third parties, you confirm this. Please also ensure that these third par-ties have been informed about this privacy policy.

2. Who is responsible for processing your data?

We are responsible for the data processing described in this privacy policy. You can contact us for your data protection concerns and to exercise your rights pursuant to para. 11 as follows:
Swiss Three Asset Management GmbH
Stockerstrasse 27
CH-8810 Horgen
[email protected]

3. What data do we process?

We process different categories of data about you. The main categories are as follows:

  • Master and portfolio data such as name, address, date of birth, contract number and duration, documents to establish the customer's identity, information on the account, custody account, concluded transactions or on third parties such as life partners, authorised representatives and ad-visors who are also affected by data processing.
  • Residence for tax purposes and any other docu-ments and information relevant for tax purposes.
  • Transaction or order and risk management data such as beneficiary details, mandate details where applicable, details of your assets, investment products, risk and investment profile, fraud.
  • Records of telephone calls between you and us, if applicable.
  • Marketing data such as needs, wants, preferences.
  • Technical data, such as internal and external identifiers, business numbers, IP addresses, rec-ords of access or changes.

4. For what purposes do we process your data?

We process your data for the following purposes (in addition to those we notify you of separately):

  • Communication with you
  • Contract conclusion/processing with you, your employer and customers
  • Operation of the infrastructure, website, app
  • Marketing (e.g. mailings, with unsubscribe link/option, occasions), relationship management
  • Market analyses, planning, development of products & services, R&D
  • Compliance (adherence to laws, industry stand-ards, directives etc.)
  • Legal procedures, investigations
  • Safeguarding security, access control
  • Management, Risk Management
  • Corporate transactions (e.g. M&A)
  • Media relations, PR, publications
  • Shareholder Services, Investor Relations
  • Training, instruction, further education
  • Fighting crime and fraud

5. On what basis do we process your data?

Depending on the products and services we may provide to you or the purpose for which the per-sonal data is processed, the data processing is based on the following:

  • Entering into, concluding or performing a con-tract or business relationship with you or for the performance of our obligations under such con-tract or business relationship.
  • To safeguard our legitimate interests, e.g. statis-tics, planning or product development, business decisions; monitoring and controlling risks, business auditing; marketing, market research, comprehensive support, advice and information on the range of services, preparation and provi-sion of tailor-made services - insofar as no ob-jection has been made; safeguarding our inter-ests and securing the claims of our company, customers and employees.
  • To fulfil legal or regulatory obligations of our company or the performance of tasks in the public interest.
  • Based on your consent.

5. On what basis do we process your data?

We use various techniques on our website which enable us and third parties engaged by us to recog-nise you when you use our website and, in some circumstances, to track you across multiple visits. We inform you about this in this section.

In essence, this is so that we can distinguish accesses by you (via your system) from accesses by other users, so that we can ensure the functionality of the website and carry out evaluations and personalisa-tions. In doing so, we do not want to infer your identity, even if we can do so insofar as we or third parties engaged by us can identify you through a combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of the third parties) assigning you or your browser a specific identification number (so-called "cookie").

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can there-fore be "tracked" (traced). If we integrate offers from an advertising contractor or provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in individual cases.

We use such techniques on our website and allow certain third parties to do so as well. You can pro-gramme your browser to block or deceive certain cookies or alternative techniques, or to delete ex-isting cookies. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword "data protection") or on the websites of the third parties that we list below.

A distinction is made between the following cookies (techniques with comparable functions such as fin-gerprinting are included here):

Necessary cookies: Some cookies are necessary for the website to function as such or for certain func-tions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary ("session cookies"). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one ses-sion (i.e. one visit to the website) if you use this function (e.g. language selected, consent given, the function for automatic login etc.). These cookies have an expiry date of up to 24 months.

Performance cookies: In order to optimise our web-site and corresponding offers and to better adapt them to the needs of users, we use cookies to record and analyse the use of our website, possibly even beyond the session. We do this through the use of third-party analytics services. We have listed these below. Performance cookies also have an expiry date of up to 24 months. Details can be found on the websites of the third-party providers.

7. Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or oth-erwise to protect our legitimate interests, we also transfer your personal data to third parties, in par-ticular to the following categories of recipients:

  • Service providers (who process your data partly on our behalf, e.g. IT providers, partly on their own responsibility, e.g. banks)
  • Authorities at home and, if applicable, abroad
  • Business partners such as suppliers,
  • Customers, marketing and project partners
  • Third parties who collect data about you via website/app (see list on the website)

8. Does your personal data also end up abroad?

Yes, this is possible, to the EEA, but exceptionally to any country in the world (conceivable especially for online services that we use). If this is a country without sufficient data protection, we conclude contracts (so-called EU SCC), but may also rely on consent or transfer data abroad on a case-by-case basis, because it is necessary for the processing of a contract, where it concerns data published by you or it is necessary for legal proceedings abroad.

9. How long do we process your data?

The duration of the storage of personal data is de-termined by legal retention obligations or the pur-pose of the respective data processing. As a rule, we store personal data for the duration of the busi-ness relationship or the duration of the contract and then for a further five, ten or more years (de-pending on the applicable legal basis).

10. How do we protect your data?

We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect against the risks of loss, accidental alteration, unauthorised disclo-sure or access.

11. What rights do you have?

You have the right to information, correction, dele-tion, restriction, objection and - if applicable - the right to data portability. Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority. If you wish to exercise the above rights against us), please contact us in writing, at our premises or, unless otherwise stated or agreed, by e-mail. You will find our con-tact details in para. 2. In order for us to be able to exclude misuse, we must identify you (e.g. with a copy of your ID card, unless otherwise possible).

12. Can this privacy policy be changed?

This privacy policy does not form part of any con-tract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated: 31.12.2023