The Swiss Capital Wealth Management AG (hereinafter referred to as «the Company») provides essential information regarding the collection and processing of personal data within the scope of our asset management and investment advisory services.

Identity and Contact details of the Responsible Person for Data Processing

Swiss Capital Wealth Management AG

Klausstrasse 4

8008 Zürich

scwm_mail@swisscap.com

www.swisscap.com

This document is aligned with the EU General Data Protection Regulation («GDPR») and the new Federal Act on Data Protection («nFADP») and aims to fulfill the Company's information obligations. The application of these laws depends on the specific circumstances of each case.

A.    Collection and Processing of Personal Data

Personal data refers to any information related to an identified or identifiable natural person. As part of our mandate, the Company collects and processes various types of your personal data.

This includes, but is not limited to:

·         Personal details (e.g. name, address, date of birth, nationality, marital status, identification documents)

·         Physical characteristics (gender, health data, racial or ethnic origin)

·         KYC information (e.g. origin of assets/money, transaction details)

·         Bank account/deposit information (e.g. IBAN)

Additionally, this encompasses all other information provided to us or inevitably collected during the course of delivering the agreed services. 

To the extent we are authorized, we may also receive personal data from affiliated companies, authorities, or other third parties (such as custodian banks, sales partners, etc.). In addition to the data provided directly by you, the categories of data we may receive from third parties include:

·         Information from public registers

·         Data received in connection with administrative or court proceedings

·         Customer details from correspondence and discussions with third parties

·         Information provided by individuals associated with you (e.g., family members, advisors, legal representatives) for the purpose of concluding
    or processing contracts

·         Information provided with customer cooperation (e.g., powers of attorney)

·         Information related to legal regulations such as anti-money laundering

·         Information found in the media or on the internet (if specified in individual cases)

In general, we store this data for 12 months after the conclusion of the processing purpose. This period may be extended if necessary for evidentiary reasons or to fulfill legal or contractual requirements.

B.    Purpose of Data Processing and Legal Basis

The Company primarily uses the data collected to provide the agreed services to you, procure products and services from our suppliers and subcontractors, and fulfill legal obligations.

Additionally, in accordance with applicable law and where appropriate, we may process personal data for the following purposes:

• Provision and development of our products, services, websites, apps, and other platforms on which we operate
• Advertising and marketing (including the organization of events), unless you have objected to the use of your data for this purpose. If you are part of our customer base and receive advertising, you can object at any time, and we will place you on a blacklist to prevent further advertising mailings
• Assertion of legal claims and defense in legal disputes and official proceedings
• Ensuring the smooth operation of our business, including our IT systems, websites, apps, and other applications
• These purposes are pursued based on the legal grounds provided by applicable data protection laws, including your consent where necessary, our contractual obligations to you, our legitimate interests, and compliance with legal requirements.

C.    Rights of the Data Subject

In accordance with applicable law, individuals whose personal data is processed («data subjects») have several rights regarding the processing of their data. The Company is committed to ensuring that you can exercise your rights easily and transparently.

You have the following rights:

·         to request and receive information about whether we are processing your data and, if so, which data

·         to request that inaccurate or incorrect data be corrected

·         to object to all or certain processing of your data

·         to request the deletion of your data

·         to withdraw consent where our processing is based on your consent

·         to receive further information on the exercise of these rights upon request.

In general, exercising these rights requires proof of identity (e.g., by providing a copy of identification documents if your identity is not otherwise apparent or cannot be verified in any other way). To assert these rights, please contact us in writing using the contact details provided above.

Please note that we reserve the right to assert legal restrictions or exceptions, for instance, if we are obliged to store or process certain data, have an overriding interest (insofar as we can invoke such interests), or require the data to assert claims.

Additionally, every data subject has the right to assert their rights in court or 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/ edoeb/en/home.html)

D.    Disclosure of Data to Third Parties and Transfer of Data Abroad

In connection with our mandate, services, products, legal obligations, and the aforementioned purposes of data processing, we may transfer data to third parties when such a transfer is permitted and deemed appropriate for them to process the data on behalf of the Company («Processor») or, if applicable, for their own purposes («Controller»). The following categories of recipients may be affected: 

·         External legal, compliance, and risk management providers

·         CRM/PMS providers

·         Data hosting providers

·         Audit firms

·         Custodian banks

 

All recipients are located in Switzerland, and your personal data will not be transferred abroad.

E.    Changes to this Data Protection Client Information

We may amend this Data Protection Client Information at any time without prior notice. The current version published on our website shall apply. If this data protection information is part of an agreement with you, we will notify you of any changes by email or other suitable means.