Privacy notice and data protection
Version: January 2019
Alpina Capital AG (hereinafter referred to as the Company) respects your privacy and is committed to protecting your personal data. This privacy notice (the “Privacy Notice”) relates to all personal data that you provide to the Company in the context of your use of the Company`s Website (regardless of where you visit the site from).
This Privacy Notice provides you with information on how the Company collects and processes your personal data.
By using this website and services provided by the Company, you consent to the data practices described in this Privacy Notice.
Collection of your personal data
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The Company collects, uses, stores and transfers different kinds of personally identifiable information which can be grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes home or work address, email address and telephone numbers.
Financial Data includes bank account details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, your interests, preferences and favorites.
Usage Data includes information about how you use our website, services.
Marketing and Communications Data includes your preferences in receiving marketing from your communication preferences.
The Company can also collects anonymous information, which is not unique to you and does not directly or indirectly reveal your identity.
The Company may collect or obtain personal data directly from you (for example by completing a form on the Company`s Website or attending one of our events or by going through our recruitment process) or indirectly because other people give that data to us (for example your employer or adviser or third party service providers that we use to help operate our business) or because it is publicly available.
The Company may also collect personal data from you because the Company combines personal data with other data made available to the Company. The Company may also infer personal data about you from the way you make use of the Company`s Website, for example, to improve your experience when you use the Company’s Website and ensure that it is functioning effectively, the Company (or its service providers) may use cookies (small text files stored in a user’s browser) which may collect personal data. Additional information on how the Company uses cookies and how you can control these can be found below.
The Company does not intentionally collect any particularly sensitive categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and, if collected, the Company does not use or disclose those sensitive personal data without your explicit consent.
The Company encourages you to review the privacy statements of websites you use to link to the Company so that you can understand how those websites collect, use and share your information. The Company is not responsible for the privacy statements or other content on websites outside of this Website.
Use of your personal data
Purpose for which the Company might use your personal data
The Company collects and uses your personal data for legitimate interests, such as to operate the Company`s Website. The Company also uses your personal data to inform you of products or services available from Company and its affiliates. The Company may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
Your personal data may also be processed for compliance with statutory and regulatory obligations of the Company or internal policy requirements and the order of a competent court, as well as (but not limited to) accounting, commercial communications, know-your-customer and anti-money laundering requirements, general management of the services or customer relationship purposes. The Company may also process your personal data for the purposes of Company’s legitimate interest to defend Company offices, IT infrastructure and also in connection with services the Company receive from professional advisors, such as lawyers and consultants or other service providers either to execute Company`s contractual obligations toward you or the Company’s clients or more generally for legitimate business interest personal data.
Change of purpose
The Company will only use your personal data for the purposes for which the Company collected it, unless the Company reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose.
If the Company needs to use your personal data for an unrelated purpose, the Company will notify you and will explain the legal basis which allows the Company to do so.
Please note that, in exceptional circumstances, the Company may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and for the purposes or in connection with the purposes set out above.
Transfer and disclosure of personal data
Your personal data may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including personal data, to Switzerland and process it there.
Your consent to this Privacy Notice followed by your submission of such information represents your agreement to that transfer.
The Company does not sell, rent or lease personal data collected from the Company’s Website to third parties. External business partners may, from time to time, contact you on behalf of the Company about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is transferred to the third party. In addition, the Company where necessary, may share data with trusted partners to help the Company perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal data except to provide these services to the Company, and they are contractually required to maintain the confidentiality of your information.
Company will disclose your personal data, without notice, only if required to do so by law or if such action is reasonably necessary to: (a) defend claims; (b) protect and defend the rights or property of the Company; and, (c) act under emergency circumstances to protect the personal safety of users of the Company, or the public.
As provided for under the applicable data protection laws and regulations, you are entitled to request access, correct or erase your personal data or restrict the processing of your personal data, as well as the right to data portability.
To exercise these rights, please contact the Company (see below).
You also have the right to lodge a complaint with the competent data protection authority, being in Luxembourg the Commission nationale pour la protection des données.
Data retention
The Company will only retain your personal data for as long as necessary to fulfil the purposes the Company collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Security of your personal data
The Company undertakes to process your personal data only for the defined purposes and to implement appropriate technical measures to protect and to keep it confidential. Your personal data will not be disclosed to any third party within or outside the European Union (including in countries that do not offer an adequate level of protection), other than other Company entities and/or third parties directly concerned by the defined purposes.
The Company secures your personal data from unauthorized access, use or disclosure. The Company secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.
In addition, the Company limit access to your personal data to those employees, agents, contractors and other third parties who require such information in order to fulfil a purpose. They will only process your personal data on the Company’s instructions and they are subject to a duty of confidentiality.
The Company has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach or suspected breach where Company is legally required to do so.
Changes to this privacy notice
The Company will occasionally update this Privacy Notice to reflect company and users’ feedback. The Company encourages you to periodically review this Privacy Notice to keep up to date in relation to how the Company is protecting your information.
Contact information
Alpina Capital AG
Weidstrasse 9B
6300 Zug
info@alpina.capital