Privacy Policy

1. Privacy policy

This privacy policy is to inform you about how we process your personal data. We process your personal data when you visit our website or use our apps, enter into a customer relationship or other type of contractual relationship with us and/or purchase services and products from or apply to work for us or otherwise deal with us.

We will inform you in good time about additional processing activities not mentioned in this data protection declaration.

The processing of your personal data is subject to the Swiss Data Protection Act and, where applicable, the EU General Data Protection Regulation (“GDPR”).

2. Our company

The company listed below is responsible for your data processing unless otherwise communicated:

PMW Asset Management AG
Fraumünsterstrasse 15
8001 Zürich

If you have any concerns about data protection or wish to exercise your rights, please contact the office listed below:

PMW Asset Management AG
Management Board
Fraumünsterstrasse 15
8001 Zürich
info@pmw-am.ch

3. Processing of personal data

Personal data 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.

We process personal data that we receive from you or from third parties. Where permitted and appropriate, we then obtain personal data ourselves, e.g. from publicly accessible sources such as the Internet, newspapers and reports.

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.

4. Data processing

Visitors to our website
We process personal data when you visit our website www.pmw-assetmanagement.ch.

In particular, we process the following data:

Technical data, such as the IP address, browser used, operating system, cookies
Minutes etc.
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 section 11.
Customers
We process personal data that we receive during (initiating) a client relationship. We receive the data directly from you while providing our services 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, the debt collection register, or other government information, confirmations, etc.
Data 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 or 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 we obtain in the context of further clarifications (e.g. creditworthiness information, personal data in media reports, etc.).

5. Purpose of processing
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, such as:

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 including conducting investigations

For communication with you, such as:

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 www.pmw-assetmanagement.ch, incl. authentication when visiting the customer area. For further information, please refer to section 11.

For other purposes, such as safeguarding our legitimate interests and 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.

6. Data transfer and data transmission abroad

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 addresses, 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.

7. Profiling & automated individual decision

We may carry out automated processing of personal data. This consists of using your data to evaluate certain personal aspects relating to you, to analyse or predict aspects relating to your work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location. Where necessary, we will obtain explicit consent to do so.

Our decision may be based on an automated individual case decision, i.e., an automated processing that involves a legal consequence for you or significantly affects you. Insofar as data processing is based on an automated individual case decision, you have the right to comment on this and to have the decision reviewed by a natural person.

8. Information, correction, cancellation, and restriction

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 2 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.

9. Duration of the retention of personal data

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).

10. Data security

In order to ensure the confidentiality, integrity, availability and traceability of the data we store and process, we take extensive technical and organisational security precautions in our area of responsibility, which are regularly reviewed and adapted to technological progress.

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

11. Use of our website

Visiting our website or our app (hereinafter referred to as website, internet presence, etc.) generally leads to data processing.

When visiting the website, log files are stored, which contain the following information in particular:

the name of the retrieved file
the time (date and time) of your retrieval
the volume of data transferred
a message about successful retrieval
Your web browser, operating system and the requesting domain
the IP address

This data is evaluated exclusively for the purpose of improving our services and generally does not allow any conclusions to be drawn about your person.

If you wish to make use of services offered by us on our website, it is necessary for you to provide further data. This is the data that is required for the respective processing.

By using our website and any further services based on it, you expressly consent to the associated processing of your personal data.

Data use
We use the information we collect about you to provide the products and services we offer, to answer your questions, and to operate and improve our websites and applications. We also use your personal data to provide you with a comprehensive service via our website. For further purposes, please see section 5.

We will not disclose your personal data submitted online to third parties unless it serves one of the purposes listed in section 5 or, where necessary, you have given your express prior consent. Data may be passed on to the recipients listed in section 6.

User profiles
As a matter of principle, we do not create personal user profiles. In connection with the retrieval of the information you requested, data is only stored on our servers in anonymised form for the provision of our various services or for evaluation purposes. General information is logged, for example, when or which content from our offer is called up or which pages are visited most frequently.

Use of cookies
We use so-called “cookies”. Cookies are small text files that are sent to your browser by our web server when you visit our website and are stored on your computer for later retrieval. By using our website, you agree to the use of cookies.

The cookies used serve in particular to determine the frequency of use and the number of users of our websites and to continue to identify your computer during a visit to our website when switching from one of our websites to another of our websites and to be able to determine the end of your visit. This way, we learn which section of our web pages and which other web pages our users have visited. However, this usage data does not allow any conclusions to be drawn about the user. All of this anonymised usage data is not combined with your personal data and is deleted immediately after the end of the statistical evaluation.

When you visit our website, cookies are permanently stored on your computer. This serves to optimise the user-friendliness and the easy and fast access to the web pages. Most browsers are preset to accept cookies automatically. However, you can deactivate the storage of cookies or set your browser to notify you before cookies are stored.

You can also prevent the installation of cookies by making the appropriate settings in your browser software. However, we would like to point out that in this case, you may not be able to use our website’s functions to their full extent.

Contact form
If you make use of the possibility to send us enquiries (general or specific offer enquiry) via our contact form, we will ask you for your first and last name, your company and your e-mail address or telephone number. Furthermore, you can enter your individual message to us in the message field.

It is your free decision whether you share this data with us. Currently, all transmissions are encrypted to prevent third parties from reading them.

Newsletter
In order to be able to register for our e-mail newsletter service, we require, in addition to your consent, at least your e-mail address to which the newsletter is to be sent. Any further information is voluntary and will be used to address you personally, personalise the newsletter’s content, and clarify queries regarding the e-mail address. It is your free decision whether you provide us with this data. However, we cannot send you our newsletter without this information.

When you register for the newsletter, your e-mail address will be used for our own advertising purposes until you unsubscribe from the newsletter. To unsubscribe, you can use the link at the end of the newsletter to cancel.

Hyperlinks to external websites
Our website contains hyperlinks to the websites of other providers. When you activate these hyperlinks, you will be forwarded directly from our website to the other provider’s website. You will recognise this by the change of URL, among other things. We cannot accept any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with data protection regulations. Please inform yourself directly about the handling of your personal data by these companies on these websites.

Google Maps
Furthermore, Google Maps, a map service of Google Inc. (“Google”), is integrated into this website. Google Maps uses so-called “cookies”, text files that are stored on your computer if you use the map function on our website.

When you click the link, a direct connection is established between your browser and the Google server. Google thereby receives the information that you have visited our site with your IP address. If you click on the Google Maps link while you are logged into your Google account, Google can associate your visit to our site with your user account.

We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Google. Details on data collection (purpose, scope, further processing, use), as well as your rights and setting options, can be found in Google’s privacy policy.

Further plug-ins from other service providers

The following plug-ins of other service providers are integrated, which forward the following data to the following countries:

12. Changes

This privacy policy may be amended at any time without prior notice. The version published on our website or sent to you by other means shall apply, insofar as it is more recent. Unless otherwise agreed, the privacy policy does not form part of any contract concluded with you.

Update date: 05.04.2024