ANREPA Asset Management AG (hereinafter called “ANREPA”) places great importance on the protection of your personal data. We handle your data confidentially and in accordance with the statutory data protection regulations as well as this Privacy Notice. This Privacy Notice is intended to inform you about the processing by ANREPA of your personal data that is collected within the context of your relationship with ANREPA (business relationship/use of the website). In addition, this notice informs you about your rights pertaining to the processing of your data.
ANREPA processes the personal data in accordance with the statutory data protection regulations of Switzerland and as applicable the data protection regulations of Liechtenstein and the EU General Data Protection Regulation (GDPR).
Our processing of the personal data of our users is limited to the data that is required to render our services or to provide a properly functioning website as well as our content and services within the context of our business relationships. We collect only the personal data that is actually required to perform and settle our tasks and services or that you have made available to us voluntarily.
This Privacy Notice may be amended by ANREPA at any time and without prior notice, and shall come into force at the time of its publication.
If you have any questions arising out of this Privacy Notice, please do not hesitate to contact our Data Protection Officer, who can be reached under firstname.lastname@example.org
I. Who is responsible for processing your data?
The Data Controller responsible for processing your personal data is:
ANREPA Asset Management AG
II. Who can you contact in respect of the processing of your data?
The enterprise Data Protection contact person of ANREPA can be contacted by post using the above-specified address, for the attention of “the Data Protection Officer”.
In addition, you can contact the Data Protection contact person by e-mail: email@example.com
The Data Protection contact person is available to answer all questions relating to data protection.
III. What does personal data mean?
Personal data means details and information that relates directly or indirectly to a specific individual or could be linked to this individual, e.g. name, address, telephone number or date of birth.
IV. Where does the personal data processed by ANREPA come from?
ANREPA processes all personal data that we received within the context of the business relationship with current and/or potential customers and/or is required to render our services and/or was provided by the respective person voluntarily.
If this is necessary for the rendering of the services of ANREPA, ANREPA processes personal data that we received lawfully from you or other third parties (e.g. to fulfil legal agreements or with your consent). In addition, we also process personal data from sources in the public domain (e.g. Commercial register and register of associations, the media, the internet) that we receive on a regular basis and are entitled to process.
V. Who receives your data?
At ANREPA, only those persons have access to your data who need this to fulfil the contractual, statutory and regulatory obligations of ANREPA. Processors, service providers and vicarious agents commissioned by us may also receive access to data for the specified purposes if they are either subject to the same data protection provisions or likewise undertake to adhere to the corresponding data protection provisions of ANREPA and to comply with our written instructions pursuant to data protection legislation and regulations. The service providers and vicarious agents commissioned by us are, for example, companies in the fields of banking services, tax consultancy, legal consultancy, IT services, logistics, printing services, telecommunications, consultancy as well as sales and marketing or similar.
If data is transferred to recipients outside ANREPA, we may disclose information about you only if ANREPA is required by law to do so, if you have granted your consent, if ANREPA is authorised to transfer information and/or if processors, service providers and vicarious agents commissioned by ANREPA.
VI. Which rights do you have in relation to your personal data?
You are entitled to be informed about the personal data stored by ANREPA. If the respective statutory preconditions are met, you are entitled to correct, to erase, to restrict processing and to object to the processing. You also have the right to receive your provided personal data in a structured, accessible and machine-readable format. This includes the right to transmit this data to another data controller. Insofar as this is technically possible, you may also demand that ANREPA transfers the personal data directly to the other data controller.
You may also submit complaints to the competent supervisory authority.
VII. Will your personal data be transferred to any third party?
For specific technical data processing procedures ANREPA, uses the support of external service providers (for example tax consultants, banks, attorneys-at-law etc.) who receive your personal data to render these services. These service providers have been carefully selected and meet stringent data protection and data security standards. They are obliged to maintain strict confidentiality and process data only on behalf of and in accordance with the instructions of ANREPA.
Apart from the cases set out in this Data Protection Declaration, ANREPA transfers your data to third parties without your express consent only if ANREPA is obliged to do this by law or an official or court ruling.
VIII. Will your personal data be transferred to a third-party country or an international organisation?
Data is transferred to countries outside Switzerland, the EU or EEA respectively to so-called third-party countries only if this is necessary and/or required by law within the context of the services rendered by ANREPA (for example banks, domiciled in a third-party country) and/or to execute your orders (such as payment and securities orders) (for example on account of reporting obligations pursuant to tax laws) and/or if you have consented to this and/or in conjunction with the commissioned processing of data
If service providers are engaged in a third-party country, they will be contractually obliged to adhere to adequate standards of data protection.
IX. How will your personal data be protected?
All employees who access personal data must adhere to the internal instructions, rules, guidelines and processes for the processing of personal data, in order to protect this and to safeguard its confidentiality. They are also obliged to adhere to all technical and organisational security measures that are taken to protect personal data.
In addition, ANREPA has taken appropriate technical and organisational measures to protect personal data from unauthorised, accidental or unlawful destruction, amendment or disclosure and from unauthorised, accidental or unlawful loss, misuse or access as well as from all other unlawful forms of processing. When implementing these security measures, state-of-the-art technology, implementation costs as well as the risks associated with the processing and the nature of the personal data have been taken into account, whereby particular attention has been paid to sensitive data.
X. How long will your personal data be saved?
ANREPA processes and saves your personal data for as long as is necessary to fulfil our contractual and statutory obligations. In this conjunction it is important to note that our business relationship constitutes an ongoing obligation extending over several years.
Data that is no longer required to fulfil our contractual and statutory obligations is regularly erased, unless the continued processing thereof is required – for a limited period – e.g. for the following purposes:
Adherence to the retention periods pursuant to the applicable laws, such as for example the AML provisions of company law, civil law, tax law, etc.; Safeguarding all information of greater relevance, if a legal dispute may reasonably be expected, meaning that ANREPA may be obliged to retain documents for an indefinite period.
Your data while using the ANREPA website
I. When visiting the ANREPA website
When the ANREPA website is accessed, the ANREPA servers automatically save data about the accessing system. This includes:
- the browser type used,
- the browser version,
- the operating system used,
- the website from which the ANREPA website is being accessed,
- the clicked sub-pages of the ANREPA website,
- the date and time of the accessing,
- the internet protocol address (IP address),
- the internet service provider as well as data comparable with this data.
This data will be used by ANREPA to make the website accessible, to identify and to rectify possible technical problems that may arise, and to prevent as well as possibly to investigate misuse of the services provided by ANREPA.
In addition, this data will be used by ANREPA in anonymised form, i.e. without enabling the user to be identified, for statistical purposes and in order to improve the website.
II. Will a web analysis be conducted on the basis of the visitor and utilisation data?
The data collected by Google may possibly be transmitted by Google to states outside the EU and EEA, in particular to the USA. Google has, however, subjected itself to the Privacy Shield Framework. Further information about your rights in this relation is available under http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.
III. How are cookies used on the website?
As a rule, a cookie contains the name of the domain sending the cookie data, as well as information about the age of the cookie and an alphanumerical identifier. Cookies enable ANREPA to structure the website attractively for the user, and also facilitate the use thereof, for example by saving certain entries in such a way that they do not need to be repeatedly entered. The information saved in the cookies is not used to identify the user, and shall not be merged with other personal data that is saved about the user. The cookies remain saved until you, the user, delete them.
IV. How is data that is entered in a contact form processed?
If you complete a contact form, your details will be saved only to process your enquiry and possible further associated questions, and will be used only within the context of the enquiry. Your e-mail address will be deleted once your enquiry has been settled.
V. What happens if a newsletter is subscribed on the website?
If you subscribe to a newsletter, you permit us to process the personal data required for this purpose. To register for a newsletter, the user must enter his e-mail address and possibly his first name and last name. Further information may be provided on a voluntary basis. ANREPA uses the marketing platform “MailChimp” for this purpose (https://mailchimp/legal/privacy/).
The user is entitled to withdraw his consent at any time, without this affecting the lawful nature of the processing performed prior to the revocation. In this event he will no longer receive the newsletter.
The subscribed newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails in HTML format. On the basis of the embedded tracking pixel, ANREPA is able to identify whether and when the newsletter was opened by the recipient and which links in the newsletter were activated by the recipient. The data collected by the tracking pixel contained in the newsletters is saved and processed for statistical purposes in order to optimise the newsletter distribution and to tailor the content of future newsletters even closer to the interests of recipients.
VI. Do downloads from the website affect your data?
ANREPA does not demand that you provide any personal data in conjunction with downloading.
VII. Does ANREPA use web fonts, and does this affect your personal data?
This website uses so-called web fonts provided by „fonts.com“ (by Monotype) to ensure the consistent presentation of typefaces.
For this purpose, cookies are being used. The service provider is the US based company Monotype Imaging Holdings Inc., which is specialized in the design of digital font data.
Further information about type, range and purpose of the data processing is available in the “policy statement about privacy” of Monotype as well as on the page “Web Font Tracking” and the “privacy notice” of Monotype.