centriacapital.ch

This privacy policy provides information on how and for what purposes companies belonging to Centria Capital SA (hereinafter “we” or “Centria Capital”) process Your Personal Data (hereinafter "You").

"Personal Data" means all details and information relating to an identified or identifiable natural person.

We process Personal Data in accordance with the requirements of the Swiss Federal Data Protection Act (hereinafter "FDPA") and, if and to the extent applicable, in accordance with the EU General Data Protection Regulation (hereinafter "GDPR") and local data protection laws. Where we deem it appropriate, we may provide you with additional privacy policies.

The contact person for any queries You may have regarding data protection is:

Centria Capital SA
Attn: Susana Monje
c/o Fidinam (Zürich) AG, Zweigniederlassung Zug
Baarerstrasse 137
6302 Zug
E-Mail: s.monje@centriacapital.ch

Please contact us at the above addresses with any questions regarding data protection at Centria Capital SA.

We primarily process Personal Data that we receive or collect from our guests, customers (including their employees, shareholders, directors, etc.), service providers, banks and other business partners in the course of our business activities. In addition, we may also process Personal Data that we have obtained from publicly accessible sources (e.g. websites or public registers such as the commercial register, etc.). Finally, we may also have received Your Personal Data from family members of Yours, from business partners of ours, from official agencies and authorities or from other third parties.

The Personal Data we process includes, as the case may be, in particular name and contact details (e.g. address, telephone number and e-mail address), identification and background information (e.g. passport number, ID-number, language, date of birth, nationality, gender, religious denomination), license plate, political data, job title and business relationship, country of residence, geographic location, origin-related data, family situation (e.g. marital status, number of children), data on criminal proceedings, financial information for payment purposes (e.g. bank account details, credit card details), economic data (e.g. financial assets, origin of funds), investment related information (e.g. investment profile, risk profile, suitability test, asset allocation, investments), transaction data (e.g. payment instructions, investment instructions) and information of any kind from correspondence, contacts and interactions (e.g. photographs, videos and voice recordings) with us.

We process Your Personal Data primarily in order to provide our services in connection with our business activities. In particular, we process Your Personal Data for the following purposes:
- to communicate with You, in particular to provide You with information or to process Your requests. If You contact us by e-mail, You authorise us to reply to You via the same channel. Please note that unencrypted e-mails are transmitted via the open Internet, which is why it cannot be ruled out that they can be viewed, accessed and manipulated by third parties. Therefore, we ask You not to send us confidential information by e-mail. We exclude - as far as legally permissible - any liability which You may incur in particular as a result of faulty transmission, falsification of content or disruption of the network (interruptions, overloading, illegal interventions, blocking);
- to make our services available to You and to evaluate and improve them;
- to organise events and webinars and report them (e.g. in the form of texts, photographs, videos and voice recordings);
- for the conclusion, administration and performance of our contractual relationships;
- to maintain and manage the business relationship with You (incl. issuing invoices);
- to inform You of recent updates or to provide You with other information about our services;
- to promote services of ours;
- for statistical purposes;
- for IT and building security measures (such as access controls, visitor lists, network and mail scanners, telephone recordings) and risk control reasons;
- for the assertion of legal claims and defence in connection with legal disputes as well as proceedings before the authorities;
- to comply with our legal obligations nationally and internationally.
We process Your Personal Data for the purposes specified above, depending on the situation, in particular on the following legal bases:
- the processing of Personal Data is necessary for the performance of an agreement with You;
- You have given Your consent to the processing of the Personal Data relating to You;
- the processing of Personal Data is necessary for the fulfilment of a legal obligation;
- the processing is necessary to protect the vital interests of the data subject or another natural person; or
- we have a legitimate interest in processing the Personal Data.

You can contact us by e-mail addresses and telephone numbers provided. The Personal Data You send us will be stored and processed by us for the purpose of processing Your request. The legal basis for this Personal Data processing is Your consent and our legitimate interest in processing Your request.

You can submit Your application for a position with us by post or via e-mail. Your application documents and all Personal Data thereby disclosed to us will be treated in the strictest confidence, will not be disclosed to any third party and will only be processed for the purpose of processing Your application for employment with us. Unless You have given consent which provides otherwise, Your application file will either be returned to You after the conclusion of the application process or will be deleted/destroyed, unless it is subject to a statutory retention requirement. The legal basis for the processing of Your data is Your consent, the performance of the contract with You and our legitimate interests.

In addition to the transfers of data to recipients expressly mentioned in this privacy policy, we may to the extent permitted – disclose Personal Data to the following categories of recipients:
- Providers to whom we have outsourced certain services (e.g. IT and hosting providers, payment service providers, debt collection service providers, risk management and compliance providers etc.);
- Service providers, subcontractors and other business partners;
- Banks and insurance companies;
- Tax advisors, auditors, lawyers, notaries and other external professional advisors of Centria Capital SA;
- Counterparties;
- National and foreign authorities, agencies and courts.

Your Personal Data may be processed within Switzerland, the European Union or the European Economic Area (hereinafter "EU/EEA") but may also be processed in and transferred to a country outside of Switzerland, EU or EEA, for example the USA.

Should we ever need to transfer data to a country without adequate legal data protection, we ensure an adequate level of protection as provided for by law by using appropriate contracts (namely on the basis of the so-called standard contractual clauses of the European Commission) or we rely on the legal exceptions of consent, the performance of a contract, the establishment, exercise or enforcement of legal claims, overriding public interests, published Personal Data or because it is necessary to protect the integrity of the data subjects. We would like to point out that data transmitted abroad is no longer protected by Swiss law and foreign laws as well as official orders may require the disclosure of this data to authorities and other third parties.

We process and store Your Personal Data only for as long as is necessary in accordance with the relevant purpose of processing or if there is another legal basis for doing so (e.g. statutory retention periods). We retain Personal Data that we hold on the basis of a contractual relationship with You for at least the duration of that contractual relationship and the statutory limitation periods for potential claims or based on contractual retention obligations. As soon as Your Personal Data are no longer required for the above-referenced purposes, they will be set inactive, deleted or anonymised as far as possible.

Under the data protection law applicable to You and to the extent provided for, You have the right to information, rectification, erasure, the right to restrict data processing and otherwise to object to our data processing as well as to the handover of certain Personal Data for transfer to another location (so-called data portability). Please note, however, that we reserve the right to assert the statutory restrictions on our part, for example if we are obliged to retain or process certain data, if we have an overriding interest in this (to the extent we are entitled to rely on such interest) or if we need the data in order to assert claims. If this results in costs for You, we will inform You in advance.

If data processing is based on Your consent, after giving Your consent You may withdraw it at any time with future effect. However, this does not affect the lawfulness of the processing carried out on the basis of Your consent prior to Your withdrawal of consent.

The exercise of such rights generally requires that You clearly prove Your identity (e.g. by means of a copy of an identification document, where Your identity is otherwise unclear or cannot be verified). In order to assert Your rights, You may contact us at the address specified in Section 1 of this privacy policy.

In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority may vary depending on Your place of residence or the place where the alleged infringement of the applicable data protection law takes place.

We take appropriate security measures in order to maintain the required security of your Personal Data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

We expressly reserve the right to amend this privacy policy at any time. If such amendments are made, we will immediately publish the amended privacy policy on our website. The privacy policy published on our website, as from time to time amended, shall apply.