Data Protection Notice
ISPartners Investment Solutions AG (hereinafter referred to as “ISPartners” or the “Company”) is committed to protecting the privacy and security of your personal information. This data protection notice describes how we collect and use personal data and which rights and options you have in this respect.
Personal data refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “Personal Data”).
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall be in line with the General Data Protection Regulation (GDPR), or in accordance with the country-specific data protection regulations applicable to ISPartners.
As the controller, ISPartners has implemented technical and organizational measures to ensure the most complete protection of personal data processed through personal contact as well as this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
1. General Information
Where your details are provided to ISPartners as a result of your interest in our Company or subscription in the products, ISPartners, acting as a data controller may itself (or through a third party acting in its capacity as the Company’s service provider (collectively, the “Authorised Processor”)) process your personal information, in the case of individuals, or that of your directors, officers, employees and/or beneficial owners, in the case of legal entities.
Please ensure that you provide a copy of this Data Protection Notice to any third parties whose personal data you provide to ISPartners.
This Data Protection Notice may be updated at any time and ISPartners will notify you, in writing of any substantial changes; otherwise an updated version of this Data Protection Notice will be available from the Company.
2. Purposes of processing of Personal Data and legal basis for processing
Your Personal Data may be processed by the Company, or on behalf of the Company, for the following purposes:
- Managing and administering your holdings, if any, in the products, including assessing and processing applications, communicating with you about your holdings and account related activities on an on-going basis;
- Managing and administering any requests made by you in respect of any enquiry or considered investment in the products;
- To update and maintain records and provide net asset valuation and other calculations; and
- To manage and maintain our relationships with you;
Please note that the above-mentioned uses of your Personal Data are necessary for us to be able to provide you with the necessary information in relation to your interest in our products.
- In order to carry out anti-money laundering checks and related actions including sharing data with police, law enforcement, tax authorities or other government and fraud prevention agencies where the Company has a legal obligation, including screening transactions, reporting suspicious activity and complying with production and court orders:
- To report tax related information to tax authorities;
- To investigate and resolve complaints and manage contentious regulatory matters, investigations and litigation;
- To monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation;
- To enforce or defend the Company’s rights, itself or through third parties to whom it delegates such responsibilities; and
- To comply with any applicable legal, tax or regulatory obligations on the Company, which derive from anti-money laundering and counter-terrorism legislation.
Please note that the above-mentioned uses of your Personal Data are necessary in order for us to comply with any legal or regulatory obligations.
The day to day running and management of the Company include to:
- monitor, maintain and improve the processes, information and data, technology and communications solutions and services used by the Company;
- perform general, financial and regulatory accounting and reporting;
- monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of the Company to improve its service delivery; and
- protect our legal rights and interests including screening transactions for fraud prevention and anti-money laundering purposes.
Please note that the above-mentioned uses of your Personal Data are necessary for our legitimate business interest in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime provided our interests are not overridden by Your interests.
3. Collection of Personal Data from sources other than from you, as data subject
ISPartners and/or any Authorised Processor may collect Personal Data on you, as the data subject, from third party sources, including but not limited to, from public sources and introduces. The purposes of the collection of such Personal Data are the purposes which are included in this Data Protection Notice.
The types of Personal Data which may be collected from third parties including the following:
- Name and Surname;
- Company Name;
- Email Address;
- Contact Details;
- General interest and preferences.
4. Collection of Personal Data for other purposes
ISPartners may also undertake business development and marketing activities and where the Company relies on your consent for such purposes, you have the right to object at any time to the processing of your Personal Data for such purposes.
In the case that you want to exercise your right to object, kindly contact ISPartners by using the contact details mentioned under Section 9 hereunder.
5. Recipients of Personal Data and International Transfer of Personal Data
The Company may disclose your personal information as follows:
- to their affiliates and third-party service providers, including the administrator, the depositary, the external funds and managers and other service provider as may be appointed from time to time and who are engaged in connection with the oversight, safekeeping, administration, distribution or operation of the Company, in order to process the Personal Data for the above-mentioned purposes; and
- to competent authorities (including tax authorities), courts and bodies as required by applicable law or requested by such entities or to affiliates for internal investigations and reporting.
ISPartners will store your personal data for as long as it needs to do so, and in accordance with applicable law.
Data Subject Rights
You have various rights in relation to your personal information, including the following:
- the right to obtain information regarding the processing of your personal data and access to the personal data which the Company holds about you;
- the right to withdraw your consent to the Company’s processing of your personal data at any time, if relevant;
- the right to request a copy of the personal data about you. This right only applies to personal data which you have provided to the Company;
- the right to request that the Company rectifies your personal data if it is inaccurate of incomplete;
- the right to request that the Company erases your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but the Company is legally entitled to retain it;
- the right to object to, and the right to request that the Company restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask the Company to restrict, its processing of your personal data but the Company is legally entitled to continue processing your personal data and / or to refuse that request; and
- the right to lodge a complaint with the local data protection regulator if you think that any of your rights have been infringed by the Company.
If you are a client and have any questions or would like to check whether your personal data are correct and up-to-date, please contact your relationship manager or email firstname.lastname@example.org.
How to contact ISPartners
If you have any questions about our use of your personal information, please contact us by using the below contact details:
ISPartners Investment Solutions AG
Odeon Haus, Limmatquai 2
8001 Zurich, Switzerland
ISPartners Investment Solutions AG