Processing of Personal Data
In order to comply with the legal provisions applicable, in particular as a part of the client
segmentation process and its compliance with anti-money laundering laws, the Company collects
and processes information from and on its clients and prospective clients about their personal and
The Company not only processes personal data obtained from its clients, but also processes
personal data collected through publicly available sources and private sector data providers
focusing on data relevant in the field of financial services. In this context, the Company may also
process particularly sensitive personal data on its clients, individuals representing them, on
controlling persons and beneficial owners of assets under management as well as personal data on
family members and other individuals having personal and commercial ties with our clients. If the
client refuses to disclose information requested by the Company, we may not be able to provide
specific services, may not be allowed to enter into a business relationship or must terminate the
The Company must not and will not delete this information upon or shortly after termination of a
business relation but will keep this data stored as required by applicable legislation.
The Company may and will share personal data with third parties in the framework of the
outsourcing of business activities to the extent required, as well as with other financial services
providers, which also render services to the client in question. [Such outsourcing and business
partners may be located in other countries where we deem the degree of data protection being of
an adequate level.]
The Company, its directors and employees as well as all of its outsourcing partners and agents are
subject to professional secrecy obligations pursuant to the Financial Institutions Act.
The Company maintains adequate internal guidelines and compliance programs for the processing
of personal data.