Data protection

Data protection declaration

Version as of September 1^st, 2023

In this data protection declaration, we, Altrafin AG, explain how we collect and otherwise process personal data. This is not an exhaustive description; other data protection declarations or contractual conditions and similar documents may regulate specific matters. Personal data is understood to be all information that relates to a specific or identifiable person. If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only share their personal data with us if you are allowed to do so and if this personal data is correct. This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DPA”) and the revised Swiss Data Protection Act (“revDSG”). However, whether and to what extent these laws are applicable depends on the individual case.

1. Data controller / data protection officer / represenativ

Altrafin AG (Tödistrasse 5, 8002 Zurich) is responsible for the data processing described here. If you have any data protection concerns, you can send them to us at the following contact address: Altrafin AG, Tödistrasse 5, 8002 Zurich, Switzerland, e-mail: info@altrafin.com.

2. Collection and processing of personal date

We use the personal data we collect primarily to conclude and process our contracts with our clients and business partners, in particular within the scope of the financial services provided in the areas of professional asset management and investment advice for our clients and the purchase or brokerage of products and services from our partners (e.g. custodian banks, funds, providers of financial instruments), as well as to comply with our legal obligations in Switzerland and abroad (e.g. financial market regulatory requirements). If you work for such a client or business partner, your personal data may of course also be affected in this capacity.

In addition, we also process personal data of you and other persons, to the extent permitted and deemed appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

⎯ Offering and further developing our offers, services and website;

⎯ Customer verification and background checks (KYC) to comply with our regulatory requirements;

⎯ Review and administration of employee applications;

⎯ Review and optimisation of needs analysis processes for direct client engagement and collection of personal data from publicly available sources for client acquisition purposes;

⎯ advertising and marketing (including the organisation of events), insofar as you have not objected to the use of your data (if we send you advertising as an existing customer of ours, you can object to this at any time and we will then put you on hold). And we will then put you on a blocking list against further advertising mailings);

⎯ assertion of legal claims and defence in connection with legal disputes and official proceedings;

⎯ Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);

⎯ ensuring our operations, in particular IT and our website;

⎯ video surveillance to maintain housekeeping rights and other measures for IT, building and site security and protection of our employees and other persons and assets belonging to or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone records);

⎯ the purchase and sale of business units, companies or parts of companies and other transactions under company law and the associated transfer of personal data, as well as measures for business management and, to the extent necessary to comply with legal and regulatory obligations and internal regulations.

Where you have given us consent to process your personal data for specific purposes (for example, when you register to receive newsletters or to carry out a background check), we process your personal data within the scope of and based on this consent, unless we have another legal basis and we need such a basis. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.

4. Cookies / Tracking and andere Technologien im Zusammenhang mit der Nutzung unserer Website

We typically use “cookies” and similar technologies on our website to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you are using when you visit our website or install our app. This allows us to recognise you when you return to this website or use our app, even if we do not know who you are. In addition to cookies that are only used during a session and deleted after your visit to the website (“session cookies”), cookies can also be used to store user settings and other information for a certain period of time (“permanent cookies”). However, you can set your browser to reject cookies, to save them for one session only or to delete them prematurely.

session or otherwise delete them prematurely. Most browsers are preset to accept cookies. We use persistent cookies so that you can store user preferences (which can also happen on other companies’ websites; however, we do not tell them who you are, if we even know, because they only see that the same user is on their website who was on a particular page with us)]. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.

We also include visible and invisible image elements in our newsletters and other marketing emails in some cases and where permitted, by retrieving these from our servers we can determine whether and when you have opened the email so that we can also measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are pre-set to do this. By using our website and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, then you must set your browser or email program accordingly,or uninstall the app if this cannot be adjusted via the settings.

This website uses cookies. We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Please state your consent ID and date when you contact us regarding your consent.

Your consent applies to the following domains: altrafin.com

Cookie declaration last updated on 07.09.23 by Cookiebot:

5. Data disclosure and data transfer abroadDatenweitergabe und Datenübermittlung ins Ausland

In the course of our business activities and for the purposes set out in section 3, we also disclose data to third parties, where permitted and where it appears appropriate to us, either because they process the data on our behalf or because they wish to use it for their own purposes. This applies in particular to the following positions:

These recipients are partly domestic, but may be anywhere on the planet. In particular, you should expect your data to be transferred to all countries where Altrafin AG is active, as well as to other countries in Europe and the USA where the service providers we use are located (such as Microsoft).

6. Storage duration of personal data

We process and store your personal data for as long as it is necessary for the fulfilment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the time during which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as a matter of principle and as far as possible. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less generally apply.

7. Data security

We take appropriate technical and organisational security measures to protect your personal data from unauthorised access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymisation and controls.

8. Duty to provide personal data

In the context of our business relationship, you must provide such personal data as is necessary for the establishment and performance of a business relationship and the fulfilment of the associated contractual obligations (you do not generally have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or perform a contract with you (or the entity or person you represent). Also, the website cannot be used if certain information to secure traffic (such as IP address) is not disclosed.

9. Profiling

We process your personal data partly automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to be able to inform and advise you in a targeted manner about services and products. We use evaluation tools for this purpose. We also use profiling to fulfil our financial market regulatory obligations and tasks.

10. Rights of data subjects

Within the framework of the data protection law applicable to you and insofar as provided for therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing as well as to the release of certain personal data for the purpose of transfer to another body (so-called data portability). Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to retain or process certain data, or if we have an overriding interest in doing so (insofar as we are not obliged to do so).

have an overriding interest in doing so (insofar as we are entitled to rely on this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of revoking your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or costs. We will inform you in advance if this is not already contractually agreed.

The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card where your identity is otherwise not clear or cannot be verified). To exercise your rights, you can contact us at the address given in section 1. Any data subject also has the right to pursue his or her claims in court or before the

or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Modifications

We may amend this privacy policy at any time without prior notice. The current version published on our website will apply. If the privacy policy is part of an agreement with you, we will notify you of the change by email or other appropriate means in the event of an update.