Overview
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/ applications to job advertisements/other type of (contractual) relationsship with us). 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).
The scope of the processing of personal data depends on the purpose of the processing and is limited to the data that is required within the scope of our business relationship with you, for the provision of our services or for the provision of a functional website and our content and services, within the scope of an application process or if you have any other dealings with us.
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. Unless otherwise agreed, the privacy policy does not form part of any contract concluded with you.
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 remo.digiorgio@anrepa.ch
General information
I. Who is responsible for processing your data?
Responsible for processing your personal data is:
ANREPA Asset Management AG
Neuhofstrasse 12
6340 Baar
Switzerland
II. Who can you contact in respect of the processing of your data?
The enterprise Data Protection contact point of ANREPA can be contacted by post using the above-specified address.
In addition, you can contact the Data Protection contact point by e-mail: remo.digiorgio@anrepa.ch
The Data Protection contact point is available to answer all questions relating to data protection.
III. What does personal data and data processing mean?
“Personal data”[1] means all information relating to an identified or identifiable natural person.
“Data processing” means any handling of personal data, in particular the acquisition, storage, use, modification, disclosure, archiving, deletion or destruction of data.
When processing personal data, we observe the principles of data protection law. Where necessary, we process personal data only with your prior consent.
IV. Where does the personal data processed by ANREPA come from?
ANREPA processes all personal data that we received within the context of contractual relationships inc. business relationship with current and/or potential customers and/or is required to render our services and/or received in the context of an application process and/or require in the context of further cooperation or exchange and/or we have received when visiting our website and/or was provided by the respective person voluntarily.
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.
If you provide us with personal data of other persons, you must be authorised to do so, e.g. by obtaining permission from the data subject. The data must then be correct. Please also ensure that they have read and understood this privacy policy.
V. What types of personal data does ANREPA process?
Visitors to our website
We process personal data when you visit our website [https://deepresearchfund.ch/] or use our app.
In particular, we process the following data:
- Technical data, such as the IP address, browser used, operating system, cookies Minutes etc.
- Data related to the use of our contact form
- Data in connection with the registration for our customer area
- Data in connection with the sending of mailings and newsletters
Further information on visiting our website and the associated data processing is set out below in chapter “Your data while using the ANREPA website”.
Customers
We process personal data that we receive during (initiating) a client relationship. We receive the data directly from you while providing our services in [asset management] or partly through third parties, such as banks, asset managers, auditors or obtain them ourselves.
In particular, we process the following data:
- Master data (e.g. name, address, email address, telephone number, date of birth, gender, nationality, social media profiles, copies of IDs)
- Contractual data, i.e. the data we need to process the contractual relationship with you (e.g. type of contract, services, financial data, etc.)
- Data that we need to fulfil our due diligence investigations, e.g. data for identification or background checks
- Data on your preferences, e.g. based on the products and services you request
- Financial information
- Communication data
In the application procedure
As a matter of principle, we process the data that we receive from you or from third parties in the context of your application or obtain ourselves.
In particular, we process the following personal data:
- Master data (e.g. name, address, email address, telephone number, date of birth, gender, nationality, social media profiles, copies of IDs)
- Communication data
- Data from your CV
- Data from your references
- Information from reference persons
- Extract from the criminal record, extract from the debt collection register or other government information, confirmations, etc.
- Data that we obtain in the context of further clarifications (e.g. creditworthiness information, personal data in media reports, etc.).
It is possible that sensitive personal data will be processed. If your consent is required for this, we will inform you separately.
Business partners & other third parties
We process personal data that we receive as part of the (initiation of the) business relationship with you or with a business partner or in another context. We receive the data directly from you, from third parties or obtain it ourselves.
In particular, we process the following data:
- Master data (e.g. name, address, email address, telephone number, date of birth, gender, nationality, social media profiles, copies of IDs)
- Contractual data, i.e. the data we need to process the contractual relationship with you (e.g. type of contract, services, financial data, etc.)
- Communication data
- Data that we obtain in the context of further clarifications (e.g. creditworthiness information, personal data in media reports, etc.).
VI For what purposes does ANREPA process your personal data?
The purpose of processing, i.e. the way we process your personal data, depends on how you deal with us.
We process your data in particular for the following purposes:
We process data for the recording, administration and processing of customer, contractual and employment relationships, i.e. e.g.
- Provision of our services/offer of our products to you
- Fulfilment of contractual obligations
- When you apply for a job with us
- Fulfilment of our due diligence obligations, e.g. within the scope of “Know your customer” clarifications or in supply chain management
- Further development of services and products
- Marketing including the organisation of events Market and opinion research, statistical surveys, testing and optimisation of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition.
- Sending publications, information on events and for sending newsletters
- Media monitoring
- Assertion of legal and other claims and defence in connection with legal disputes and official proceedings
- Prevention and investigation of criminal offences and other misconduct incl. conducting investigations
For communication with you, i.e. e.g.
- Contact
- Exchange of information and response to requests
- Relationship management
- Assertion of your rights
Communication can take place using all common means of communication, e.g. by letter, via e-mail, via an app, by telephone via social media, via chat, via forms on our website, etc.
In connection with ensuring “compliance”, i.e. if laws and regulations, orders/recommendations etc. from authorities, internal regulations etc. must be complied with or within the scope of the due diligence clarifications carried out by us.
For operating the website https://deepresearchfund.ch/, incl. authentication when visiting the customer area. For further information, please refer to chapter “Your data while using the ANREPA website”.
For other purposes such as safeguarding our legitimate interests and our rights, to ensure the functioning of our business (incl. accounting, risk management, granting signatory powers, in the context of M&A transactions, to ensure operational security and to clarify facts/misconduct, for training and educational purposes etc.
VII. 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 or to fulfil the purposes of the data processing.
We may share your data with third party recipients where necessary based on your consent or if they need your data to fulfil our contractual and legal obligations or to carry out their respective tasks. We may then share your data to protect our legitimate interests.
In particular, the recipients listed below may receive your data:
- Third parties such as consultants, marketing companies, translation agencies or providers of IT services who process your data as well as other external service providers and bodies such as banks, asset managers, insurance companies, auditors, associations
- Our contractual partners incl. our customers, i.e. possibly your employer
- Public bodies and authorities (e.g. FINMA, tax authorities) in the event of a legal or supervisory obligation or quality controls
- Third parties who have access to the personal data processed in the course of visiting our website
- Other third parties, such as alternative delivery addressees, recipients of payments and services, third parties in the context of M&A transactions, lawyers, industry organisations, etc.
The recipients of your data may in turn involve third parties. We restrict the processing by some selected third parties, e.g. contractually. For other third parties, this is not always possible (e.g. public bodies and authorities as well as financial intermediaries)
The recipients of your data may be located in Switzerland and Europe but in exceptional cases may be located in any other country in the world.
If the data recipient is located in a country without adequate legal data protection and is not already subject to a recognised set of rules to ensure data protection, corresponding additional protective measures will be necessary, e.g. through contractually agreed specific data protection clauses. However, exceptions to this rule (e.g. in direct connection with the conclusion or performance of a contract, legal proceedings abroad, overriding public or private interest or your consent) may occur.
VIII. Which rights do you have in relation to your personal data?
You have the right to request information about which of your data we process. You can also request that your personal data be corrected, blocked or deleted.
In addition, you have the option of receiving certain personal data relating to you in a structured, common and machine-readable format and transmitting it yourself or through us to another person responsible.
If our data processing is based on your consent, you have the right to revoke this consent.
Finally, you have the right to assert your claims through legal channels and/or to file a complaint with the competent authority. Such an authority may be based in Switzerland or abroad.
For the rights asserted, please contact the specialist office listed under point II in writing. Please note that under certain circumstances your rights may not be enforceable or may be restricted. Should this be the case, we will inform you accordingly.
IX. How will your personal data be protected?
When processing data, the applicable legal and regulatory provisions and the applicable internal instructions, rules, guidelines and processes for the processing of personal data must be complied with. All technical and organisational security measures taken to protect personal data must also be complied with.
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.
In particular, the following measures were taken:
- Access restrictions and controls
- Data backups
- IT network and security solutions
- Encryption of data carriers and transmissions
- Directives
- Trainings
- Controls
X. How long will your personal data be saved?
In principle, personal data is only retained until the purpose of the processing has been achieved; personal data is not deleted if we are obliged to retain it due to a legal or regulatory requirement, orders e.g. from authorities or a contractual agreement.
Likewise, deviating retention obligations are possible insofar as claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or there is an overriding interest on our part in retention (e.g. for evidence and documentation purposes).
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 anonymized form, i.e. without enabling the user to be identified, for statistical purposes and in order to improve the website.
Saving is performed for reasons of data security, in order to ensure the stability and operating reliability of the system. This is performed exclusively to optimise the website in terms of user-friendliness and to provide useful information about our services.
II. Will a web analysis be conducted on the basis of the visitor and utilisation data?
ANREPA analyses the use of the website with the web analysis tool “Google Analytics” (http://support.google.com/analytics/answer/6004245?hl=de; https://www.google.com/policies/privacy/). “Google Analytics”, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94.043 USA, is deployed to evaluate use of the website. Google Analytics uses cookies (see below) that are saved on your computer. The information these contain about the website and internet use of the user can be processed and evaluated by Google.
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?
The ANREPA website uses cookies to structure the service in a user-friendly manner. Cookies are small text files that are saved on the data carrier of the user (laptop, tablet, smartphone etc.) and exchange certain settings and data with the ANREPA system via the browser.
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.
If you do not want this to happen, you may use browser settings to inform you about the use of cookies, enabling you to permit this on a case-by-case basis. Deactivation of cookies may, however, mean that you are unable to use all of the functions of the website.
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.
[1] The terms personal data, personal information and data are used interchangeably in this privacy statement.