This privacy notice ("Privacy Notice") informs our website visitors, customers and business partners (or persons acting on behalf
of our customers and business partners) and job applicants ("you") about how Partners Advisers SA ("we", "us") treats personal
data ("Data") in accordance with the Swiss Federal Act on Data Protection ("DPA") and the EU General Data Protection Regulation
("GDPR"), as applicable, when using our website, when using any of our services/products ("Services"), when supplying
services/products to us, when applying for a job vacancy or in any of the other situations set out in Section 3 below. Within the
scope of the DPA, references in this Privacy Notice to the GDPR shall be understood as references to the corresponding provisions
in the DPA.
1 Controller and Contact Details
Controller is Partners Advisers SA.,
Marie Cochet, Compliance Officer,
6 Cours de Rive,
1204 Geneva, Switzerland.
+41 22 716 00 60
Email: cochet@partnersadvisers.com
2 Obligation to Provide Data and Your Sharing of Third-Party Data
You are in general under no obligation to provide us with any Data. However, if you do not provide the required information
regarding certain use cases set out in Section 3, we may not be able to process your corresponding request, get in contact with
you or provide the Services to you.
If you share with us Data regarding any other individual (e.g. regarding your employer/employees, relatives, family members,
colleagues, ultimate beneficial owners, etc.), we assume that this Data is correct. By sharing such Data with us, you confirm that
you are authorized to do so and that you have informed the affected individuals about this Privacy Notice and our processing of
their Data.
3 Processed Data, Purpose and Legal Basis
3.1 In General
We may process various categories of Data, depending on the circumstances as set out hereinafter. To the extent required
under the GDPR, our processing is generally based on:
the need for performance of our contract with you or for processing your request for a contract (GDPR 6.1.1.b; e.g. in
relation to services/products provided by us or supplied by you);
the need for compliance with legal obligations to which we are subject (GDPR 6.1.1.c; e.g. in order to comply with
statutory requirements, directives and recommendations from authorities);
legitimate interests in fulfilling the purposes mentioned below (GDPR 6.1.1.f; e.g. for security and access control purposes
as well as to comply with internal regulations, including such purposes as compliance, risk management, corporate
governance and business organization); and/or
as otherwise specified hereinafter.
3.2 Website Use
The Data processing related to your use of our website is limited to Data that is required to operate, provide and secure
the website and the services provided thereon ("Website Use Data") and for web analysis purposes ("Website Analysis
Data").
Categories of Data: When accessing our website (and, through our website, the Services), the following information
about your device may be collected automatically: IP address, operating system, type of device, browser name and
version, date and time of access, address of the website from which you were redirected to our website (if applicable),
etc. We may analyze your use of our website with web analysis tools, including Google Analytics (with IP anonymization
activated). Further information on the use of data by Google and configuration options can be found here:
https://www.google.com/intl/en/policies/privacy/partners.
Purpose and legal basis: The processing regarding website use is based on our legitimate interest to operate and secure
our website and our Services, in particular for security reasons to ensure the stability and integrity of our systems (GDPR
6.1.1.f). In addition, we may perform basic web analysis based on our legitimate interest (GDPR 6.1.1.f) to optimize the
website regarding usability and to gain insights about the use of our website and Services. The collected data will not be
merged with other personal data or disclosed to third parties.
Cookies
Our Website doesn’t collect cookies.
3.3 Communication
We may be in contact with you by use of different channels, e.g. if you fill in contact or similar forms on our website, send
us e-mails or by using other electronic (or hardcopy) communication means, whereby Data may be exchanged
("Communication Data").
Categories of Data: If you fill in our contact forms, send us an e-mail or another form of electronic message (or a hardcopy
message, e.g. a letter), we may collect such information as your name, e-mail address (or other form of communication
identifier, e.g. messenger nickname), phone number, subject matter, message content, related metadata and any other
information you choose to disclose in your communication to us.
Purpose and legal basis: We use Communication Data to process your inquiry and any possible further questions you
might have in relation to the performance of our Services (GDPR 6.1.1.b) and any other related questions and matters
based on the content of your communication with us (GDPR 6.1.1.a). We may keep this data to document our
communication with you, for training purposes, for quality assurance, for follow-up inquiries (GDPR 6.1.1.f) and for
regulatory purposes (GDPR 6.1.1.c).
3.4 Services
When using our Services, you may be required to register, e.g. by opening an account or creating a login, and we
maycollect further Service related Data, including Contract Data (as defined in Section 3.5), in relation to the Services
(altogether "Service Data", including Registration Data and Usage Data as defined hereinafter).
Categories of Data: When registering for our Services, you may be required to open an account or create a login, for which
we may require such information as for example first name, last name, username, password, e-mail, etc. This may also
include further information we require from you in order to be able to provide you with the Services, e.g., depending on
the Service, such further information as address, phone number, date of birth, nationality, identity document details,
profession, role and function, financial details (such as income information, assets owned and tax status), customer
history, etc., including information from third parties and public sources (e.g. from fraud prevention or government
agencies, internet sites and government registries) ("Registration Data"). Furthermore, when using our Services, we may
process information relating to transactions (dates, currencies, branches, payer and payee details) and record calls, e-
mails, text messages, social media messages and other communications between you and us. We may also analyze your
use of our Services in order to get to know you better and tailor our Services to you, by collecting data about your behavior
and preferences, including supplementing such data with third-party information, including from public sources
(altogether "Usage Data").
Purpose and legal basis: In general, Service Data will be used to provide our Services to you (GDPR 6.1.1.b) and to comply
with the applicable legal requirements and our internal regulations, including for anti-money laundering and fraud
prevention purposes (GDPR 6.1.1.c and 6.1.1.f). We may also process Service Data to document our Service delivery, for
training purposes or for quality assurance as well as for market research to improve our Services and operations and for
product development, based on our legitimate interest (GDPR 6.1.1.f).
3.5 Contracts
If we enter into a contract with you, or into negotiations regarding such contract, we may collect Data in relation to the
conclusion and performance of such a contract ("Contract Data"). In general, we collect this Data from you or other
contractual partners and from third parties involved in the performance of the contract, but may also use Data from third-
party or public sources (for example fraud prevention agencies and government registries).
Categories of Data: Contract Data may include Registration Data, Service Data in general and such further information as
e.g. relating to the Services to be provided, to your preferences or to your feedback, etc.
Purpose and legal basis: We use Contract Data for the preparation, conclusion, performance and administration of our
contractual relationships and any questions or inquiries that might arise in that relation (GDPR 6.1.1.b). Such processing
may be required to comply with legal requirements and internal regulations, including Know Your Customer processes
(GDPR 6.1.1.c and 6.1.1.f). We may keep this Data to document our communication with you, for training purposes, for
quality assurance and for follow-up inquiries (GDPR 6.1.1.f).
3.6 Job Applications
We may process Data you provide to us in connection with an application for a job vacancy ("Application Data").
Categories of Data: Application Data may in particular include your contact information, information about your working
permit situation, your education and professional experience and any other information you choose to provide to us in
connection with your application.
Purpose and legal basis: We process Application Data for the assessment of your application and potential negotiation,
preparation, conclusion and performance of an employment contract with you (GDPR 6.1.1.b). In case no employment
contract is concluded, but you provide us with your consent to retain your application for further job vacancies, we may
do so based on your consent (GDPR 6.1.1.a).
4 Disclosure and Transfer of Data
We may disclose your Data to recipients as set out in Section 4.1, which may include cross-border data transfers as further
described in Section 4.2.
4.1 Categories of Recipients
We may make your Data available to the following recipients (in compliance with the applicable legal requirements):
- joint account holders of your account, your guarantor and any person with power of attorney over your affairs (where
applicable);
- external service providers (e.g. IT services providers, business information providers, asset managers, etc.);
- contractual partners (to the extent the disclosure results from such contracts, e.g. if you use our Services under a
contract that we have with your employer);
- competent authorities, including tax authorities and courts (in Switzerland and abroad, if we are legally obliged or
entitled to such disclosure or if it appears necessary to protect our interests);
- legal and professional advisors, including accountants and auditors;
- transaction partners and advisors (e.g. in relation to mergers, acquisitions or other business transactions involving
us or our group companies).
4.2 Cross-Border Transfer of Data
We may transfer your Data to countries within the EEA or to the UK and to the following countries outside of Switzerland
or the EEA/UK, provided that such countries provide for an adequate level of data protection according to the assessment
of the competent authority.
5 Storage Periods and Erasure
We process and retain Data for as long as our processing purposes, the legal retention periods and our legitimate interests
regarding documentation require it or for reasons of limited technical feasibility. Except in case of contrary legal or contractual
obligations, we will erase or anonymize your Data once the storage or processing period has expired. Regarding specific use/Data
categories, we will in general retain your Data as follows:
Website Use Data: Website Use Data will be processed for as long as required to enable the requested access and secure the
stability and integrity of the relevant systems.
Website Analysis Data: Website Analysis Data will be stored for as long as required to perform the analysis and will thereafter be
deleted or anonymized.
Communication Data: Communication Data will be deleted after responding to / completing your inquiry if and to the extent (a)
we are not legally obliged to retain such Data (e.g. for accounting or document retention purposes) and (b) we do not have an
overriding legitimate interest to retain such data for documentation, quality assurance or similar business purposes or for the
assessment or exercise of, or defense against, legal claims.
Service Data: We generally keep Service Data as long as you are accessing/receiving (or have the right to access/receive) our
Services, and such Data will be deleted after termination of your contract and/or deletion of your account if and to the extent (a)
we are not legally obliged to retain such Data (e.g. for accounting or document retention purposes) and (b) we do not have an
overriding legitimate interest to retain such data for documentation, quality assurance or similar business purposes or for the
assessment or exercise of, or defense against, legal claims.
Contract Data: We generally keep Contract Data for the duration of the statute of limitations duration regarding contractual
claims, as calculated from the end of the contractual relationship if and to the extent (a) we are not legally obliged to retain such
Data (e.g. for accounting or document retention purposes) for a longer period and (b) we do not have an overriding legitimate
interest to retain such Data for documentation, quality assurance or similar business purposes or for the assessment or exercise
of, or defense against, legal claims.
Application Data: We generally keep Application Data for the duration of the application process and 3 months thereafter, unless
you ask or allow us to retain your application for a longer time. We may retain Application Data for longer for the assessment or
exercise of, or defense against, legal claims.
6 Your Rights as Affected Data Subject
You have the right to request information about your Data we process and further rights regarding such data processing. In
particular, you have – or may have, depending on the circumstances – the right to:
- Information, i.e. to ask us whether we are processing Data about you, and if so, to provide you with further information
related thereto.
- Correction, i.e. to ask us to correct or complement your Data if it is incorrect or incomplete.
- Deletion, i.e. to delete your Data (to the extent we are not under a legal obligation or have an overriding legitimate interest
to retain such Data).
- Object, i.e. right to object to the processing of your Data based on our legitimate interest (GDPR 6.1.1.f) by explaining your
particular reasons and specific circumstances on which your objection is based. Regarding cookies through which certain Data
may be collected, you can block the setting of such cookies at any time by changing the settings in your browser accordingly.
Please note that a deactivation of cookies may result in a limited user experience and you may not be able to use every
function of our website or Services or to access the Services in an appropriate manner altogether.
- Restrict processing, i.e. to ask us to temporarily restrict our processing of your Data.
- Data portability, i.e. to ask us to provide you in electronic form (to the extent technically feasible) the Data you have provided
to us.
- Withdraw your consent, i.e. to withdraw your consent if and to the extent you have previously given your consent to any
specific purpose of processing of your Data. This will not affect the lawfulness of any processing carried out before you have
withdrawn your consent (or any processing based on any legal basis other than your consent) and it may mean that we will
no longer be able to provide our Services to you.
In case you wish to exercise any of these rights, please contact us as specified in Section 1. Before responding to your request, we
may ask for proof of identity. This helps us to ensure that your Data is not disclosed to any unauthorized person.
7 Data Security
We have put appropriate technical and organizational security policies and procedures in place to protect your Data from loss,
misuse, alteration or destruction. We limit access to personal data in general.
8 Complaints / Regulatory Authority
If you believe that our processing of your Data contradicts the applicable data protection laws, you have the possibility to lodge a
complaint with the appropriate data protection authority.
The data protection authority for Partners Advisers SA is the Swiss Federal Data Protection and Information Commissioner (FDPIC),
Feldeggweg 1, 3003 Berne, Switzerland (https://www.edoeb.admin.ch). Based on your residence, you may have the possibility to
lodge a complaint with the appropriate data protection authority of your place of residence.
9 Changes to this Privacy Notice
This Privacy Notice does not form part of any contract with you and we may amend it at any time. The version published on our
website is the version that currently applies.
Last update: August 2023