Privacy Notice

Privacy Statement for the Processing of Personal Data by de Pury Pictet Turrettini & Cie SA (hereinafter: “PPT”)

The following information gives you an overview of how our company processes, administers and stores data as well as your data protection rights. The nature of the data and how we process such data may differ depending on the nature of the service requested.

 

What data does PPT use?

The company processes data that it receives in connection with our business relationship with you. Aside from personal data, this includes data that identify you (for example: your name, mailing address, email address, telephone number, etc.) and data associated with other information used for such identification (for example, an account number).

The following personal data may be involved, depending on the nature of your relationship with our company:

• Personal information, such as name, mailing address, email address and other contact information, date and place of birth and nationality;
• Identification data (for example, an official identity document) and authentication data (for example, a signature specimen);
• Information relating to instructions (for example, a payment instruction “routed” to your custodian bank);
• Data relating to performance of contractual obligations;
• Information regarding your financial situation (for example, information regarding your investor profile or management profile);
• Information contained in documents (for example, an investment advisory report);
• Other data similar to these categories.

 

For what purposes does the company use your data and on what legal bases?

a) To perform contractual obligations

The processing of your data enables the company to offer the services we have agreed to provide to you. The purpose of processing the data depends first on the products and/or services you wish to have. Your data are used to analyze needs, provide advice, manage assets and monitor any changes, and execute transactions through your custodian bank.

b) To perform regulatory obligations

The company processes your data for the following purposes:

• To verify and analyze needs;
• To manage investment risks;
• To provide and monitor the operation and security of information systems tools;
• To take measures with regard to conducting business and developing products and services.

c) On the basis of your consent

You have the option to receive information on our investment funds (for example, factsheets) and/or general financial market information (for example: newsletters). You are free to withdraw your consent at any time.

Please note your withdrawal of such consent is valid only from that time forward. Data usage prior to the withdrawal of consent is not affected.

d) On the basis of legal provisions or on the grounds of public interest

The company is subject to various legal obligations (for example, the Swiss Federal Act of 23 June 2006 on Collective Investment Schemes, the Swiss Federal Act of 10 October 1997 on Combating Money Laundering and the Financing of Terrorism in the Financial Sector, FINMA ordinances and circulars, etc.) and the rules of the banking supervisory authorities (FINMA). The purposes of data processing include verification of identity and age, prevention of fraud and money laundering, oversight and tax reporting obligations, as well as risk assessment and management at de Pury Pictet Turrettini & Cie SA.

 

Who has access to your data?

Within the company, only the management teams and support functions (Compliance Officer, Risk Manager, Executive Management) that need your data in the context of their work have access to such data (“need to know” principle).

 

How long do we store your data?

The company processes and stores your data only for the time needed to perform our duties and/or any contractual and legal obligations (retention obligations imposed by certain laws, for example the Swiss Code of Obligations, the Swiss Federal Act on Value Added Tax and the Swiss Federal Act on Stamp Duties, remain reserved).

When the business relationship between a client and our company ends, our company must retain client data for a ten-year period.

 

What are your privacy rights?

You may:

• Request information on the personal data stored by the company;
• Request that such data be rectified if they are incorrect;
• Request that such data be deleted as long as the company may not or must not retain the data due to legal or regulatory obligations.

If you are not satisfied with any aspect of the processing of your personal data, we would like to discuss the matter with you. Your satisfaction is first and foremost.

 

What data must you provide to de Pury Pictet Turrettini & Cie SA?

The company needs to obtain the data necessary to establish and operate a business relationship and to perform contractual and/or legal obligations. Without such data, the company is generally not in a position to enter into an agreement with you or to perform under such agreement.

Under the legislative provisions to combat money laundering and terrorist financing, the company is in particular bound to identify its clients through official identification documents before initiating a business relationship. In addition, the company must collect and retain the client’s signature, citizenship, name, place of birth, date of birth, and the information that appears on an official identification document or passport.

Should there be any changes to this information during the business relationship, you are bound to inform de Pury Pictet Turrettini & Cie SA immediately.

 

This privacy statement may be amended at any time.

Your manager is available to answer any questions you may have about the use of your data.

Geneva, May 2018