Privacy Policy
Privacy Statement for the Processing of Personal Data by de Pury Pictet Turrettini & Cie SA (hereinafter: “PPT” or “The Company”)
The following information gives you an overview of how our company processesThe 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.
Who is responsible for the processing of your data?
PPT, the collective investment manager, is responsible for processing your personal data.
What does this statement apply to?
This statement applies to all forms of use (“processing”) of personal data by PPT where you are a former, current or prospective client.
How is your data protected?
We continuously deploy technical and organisational measures to protect your personal data.
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 as a client (for example: your name, mailing address, email address, telephone number, etc.) or data associated with other information used for such identification (for example an account number).
The following personal data is covered, depending on the nature of your relationship with our Company:
- Personal information, such as your 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 as well as the investment strategy that is applied);
- 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?
We process your personal data in accordance with Swiss law, in particular the Swiss Federal Data Protection Act (nLPD).
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 primarily on the products and/or services you wish to obtain. In particular, 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 client 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;
- When opening an account with a banking institution based outside Switzerland and which PPT works with.
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 (example: newsletters). You are free to withdraw your consent at any time.
Please note your withdrawal of such consent is only valid for future mailings. Data processing 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 on Collective Investment Schemes, the Swiss Federal Act on Combating Money Laundering, etc.) as well as the regulations of the banking supervisory authorities (FINMA ordinances and circulars). 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 cross-disciplinary support functions (Compliance Officer, Risk Manager, Executive Management) that need your data to perform contractual and legal obligations have access to such data (“need to know” principle).
How long do we store your data?
The Company will only process and store your data for as long as is necessary for the performance of its duties and/or any contractual and legal obligations (subject to the retention obligations imposed by certain laws, for example the Swiss Code of Obligations, the Federal Law on Value Added Tax and the Federal Law on Stamp Duty).
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 rights in terms of data protection?
You may:
- request information on the personal data stored by the Company (art. 8 of the Data Protection Act);
- request that such data be rectified if they are incorrect (art. 5 of the Data Protection Act);
- request that such data be deleted (art. 5 of the Data Protection Act), provided that the Company does not have to retain the data due to legal or regulatory obligations.
- lodge a complaint with the relevant authority responsible for protecting personal data.
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 PPT?
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 you through official identification documents before initiating a business relationship with you. In addition, the Company must collect and retain your signature, your citizenship, your name, your place of birth, your 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 PPT immediately.
Where can you find the current Privacy Statement?
This privacy statement may be amended at any time. The current version is always accessible at our website www.ppt.ch
Your manager is available to answer any questions you may have about the use of your data. (data-protection@ppt.ch)
Geneva, August 2023