Savex Capital AG is an independent manager of collective assets authorized and regulated by the Swiss Financial Market Supervisory Authority (FINMA).

Savex Capital AG (hereafter “the Company”, “we”, “us” or “our”) is committed to protecting the privacy and security of the personal information that is provided to us or collected by us during the course of our business. We store and process personal information in accordance with the Swiss Data Protection Act and to the extent applicable the EU General Data Protection Regulation.

This privacy policy explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information.

We may provide you with additional privacy notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this privacy policy.

1. Who is responsible for your personal information?
Savex Capital AG, Dianastrasse 5, 8002 Zürich is responsible for your personal information provided to us or collected by us during the course of our business.

2. How we collect and use your personal information?
We collect and process your personal information as follows:

2.1 Business development and business acceptance
We collect personal information about prospective clients, their representatives and beneficial owners as well as other business contacts as part of business development initiatives and our business acceptance process. The type of personal information we may collect includes name, contact details (such as your address, email address and telephone numbers), nationality, business interests, employment history and interactions with us.

We obtain this information directly from you, from other business contacts, or from publicly available open sources.

We may use your personal information to maintain and develop our business relationship with you, identify products or services you may be interested in, to pursue certain business development initiatives, send you publications and marketing communications and invite you to events.

Where we need to collect information required for our engagement and you fail to provide that information when requested, we may not be able to start working with you.

2.2 Core business activities of the Company
In the course of our business activities, we collect and process personal information about clients, related persons and other persons as well as their respective representatives and employees. The type of personal information that we may collect includes name and contact details (such as your address, email address and telephone numbers), nationality, business interests, employment history and positions held as well as information of all kind from correspondence, contacts and interactions with us. We will also process information of all kind that is revealed to us in the course of our products and services or collected by us. This information may include special categories of sensitive data.

We collect personal information directly from you, from our clients or other persons to a matter and their respective representatives and employees. We may receive or collect personal information from third persons such as your employer, other organisations that you have dealings with or related to, regulators or government agencies. We may also collect personal information from publicly available sources.

We may use this information to provide financial services, to run our firm’s business (e.g. carry out administrative or operational processes), monitor and analyse our business or to improve our services and products.

If you or the organisation for which you are acting are a client and you fail to provide information that we require when requested, we may not be able to provide our products and services and continue our business relations.

2.3 Recruitment
If you apply for a job or a recruiting event at the Company, you may need to provide personal information including special categories of personal information. With your application, you expressly consent to our use of this information. We will use this information to consider your application. We may also use this information to carry out checks to verify the information you provided (including references, background, identity, suitability, excerpts from the debt enforcements register and criminal record checks).

Where we need to collect information required for your employment and you fail to provide that information when requested, we may not be able to further consider your employment.

2.4 Alumni
If you are a former employee of the Company, we will collect personal information such as your name, contact details (such as your address, email address and telephone numbers), information about your employment with us and thereafter as well as any other information we may have received from you.

This information is used to keep in touch with you.

2.5 Other contacts
Further, we collect and process information about you if you offer or provide products or services to us, if we evaluate your products or services, and generally when you request information from us or provide information to us.

3. Our basis for processing your personal information
We will only use your personal information if and to the extent that applicable law allows. We will therefore process your personal information if:

• it is necessary for the performance of a contract with you or the organisation you work for;
• it is necessary in connection with a legal obligation;
• you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your information with us; or
• if we or a third party have a legitimate interest which is not overridden by your interests or your rights and freedoms.

4. How and why we may share your personal information
We may share your personal information collected in the course of providing financial services with third persons (such as advisors, authorities and other persons) in Switzerland, the EU or other countries if required or useful for providing our products and services. Further, we may share your personal information with third persons where:

• you have consented to us doing so (where necessary) or the organisation that you work for has obtained your consent for us to do so (where necessary);
• we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements); or
• it is necessary in connection with legal proceedings or in order to exercise or defend legal rights.

We use third who provide products and services on our behalf and may share your information with them, for example, banks, insurance companies or a technology suppliers who may have access to your personal information when providing software support.

5. How we protect your personal information
We have put in place appropriate security measures to hold your personal information securely in electronic and physical form to protect it from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. Our premises are access controlled and surveyed by video recording where required and our electronic databases require logins and password authentication.

Our employees and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

6. How long we keep your personal data
We will retain your personal information for as long as is necessary for the purpose for which it was collected. We will further retain your personal information to comply with legal and regulatory obligations, for as long as claims could be brought against us and for as long as legitimate interest, including data security requires.

7. Your rights
You have rights that you can exercise under certain circumstances in relation to the personal information that we hold. These rights are to:

• request access to your personal information and certain information in relation to its processing;
• request rectification of your personal information;
• request the erasure of your personal information;
• request that we restrict the processing of your personal information; and
• object to the processing of your personal information.

If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

We may refuse to provide access if the relevant data protection legislation or other legislation allows or obliges us to do so, in which case we will provide reasons for our decision as required by the law.

If you would like to exercise these rights, please contact us at:

Savex Capital AG
Dianastrasse 5
8002 Zürich
info@savexcapital.com
+41 44 552 91 50

You will not, in general, have to pay a fee to exercise any of your individual rights. However, we may charge a fee for access if the relevant data protection legislation allows us to do so, in which case we will inform you as required by the law.

If you feel we have not handled your query or concern to your satisfaction you can contact the competent data protection authority, in Switzerland the Federal Data Protection and Information Commissioner.

We reserve the right to update and change this privacy policy from time to time in order to reflect any changes to the way in which we process your personal information or changing legal requirements. Any changes we may make to our privacy policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our privacy policy.

Zürich, 23.05.2019