PRIVACY POLICY
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Media owner and publisher of the website
EBG Investment Solutions AG
Bellerivestrasse 29
8008 Zurich, Switzerland
E-mail: info@ebg-is.com
Media owner and publisher of the website
ZENN Web Solutions Ltd.
Leiria, Portugal
mail: info@zenn.pt
disclaimer
Persons who access the information on the website of EBG Investment Solutions AG agree to the following terms and conditions. Any special agreement relating to individual services or products of EBG Investment Solutions AG supplements these terms and conditions. However, in the event of a dispute, the provisions of such special agreements shall prevail.
copyright
The contents of this website and its subsites are protected by copyright. Downloading or saving the applications or programs contained on the website as well as the (complete or partial) reproduction, transmission, modification or linking of the contents of the website is only permitted with the express and written consent of EBG Investment Solutions AG. However, printing, downloading or saving individual pages or parts of this website is permitted, but only within the framework of the provisions of Swiss copyright law and only if copyright notices or other legally protected designations are neither removed nor changed.
NO OFFER, NO OBLIGATION
Information published on the EBG Investment Solutions AG website does not constitute a solicitation, offer, or recommendation to buy or sell any product, to effect any transaction, or to perform any service. EBG Investment Solutions AG takes the greatest possible care in researching the information published on its website and in selecting the sources of information used. Nevertheless, EBG Investment Solutions AG cannot assume any liability for the accuracy, completeness, timeliness or permanent availability of the information or information sources provided.
If there are links on the EBG Investment Solutions AG website leading to the website of third parties, these are completely outside the responsibility of EBG Investment Solutions AG. Accordingly, EBG Investment Solutions AG accepts no responsibility for the accuracy, completeness and legality of the contents of such websites or for any offers and services contained therein.
REGIONAL LEGAL ACCESS RESTRICTIONS
The EBG Investment Solutions AG website is not directed at any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) the publication or availability of the EBG Investment Solutions AG website is prohibited. Persons in respect of whom such prohibition applies must not access the EBG Investment Solutions AG website.
By accessing the content of the Website, you agree to be bound by the Terms of Use. Access to the Website and the Terms of Use are governed by Swiss law. The exclusive place of jurisdiction is Zurich, Switzerland.
STORAGE OF REGISTRATION DATA
EBG Investment Solutions AG is in no case liable for losses or damages of any kind (including consequential or indirect damages or lost profits) that could arise from or in connection with access to the website, the calling, use or querying of its contents or with the links set up on the website to websites or URLs of other operators. This also applies if EBG Investment Solutions AG has been advised of the possibility of such damages.
Furthermore, EBG Investment Solutions AG disclaims any liability for any manipulation through the use of the computer system of the internet user by an unauthorized party. In this regard, EBG Investment Solutions AG expressly points out the risk of viruses and the possibility of targeted attacks by hackers. To combat viruses, we recommend the use of the latest browser versions and the installation and regular updating of an anti-virus program. As a rule, an e-mail from an unknown sender, as well as an unexpected attachment of an e-mail should not be opened.
data privacy statement
Duties of disclosure upon collection of personal data from the data subject in accordance with the European General Data Protection Regulation (EU GDPR) and The Swiss Federal Act on Data Protection (FADP) (W.08).
This privacy statement is issued by EBG Investment Solutions Ltd. (EBG). EBG is a professional participant in the finance sector subject to supervision in the markets and jurisdictions in which we operate. We recognize and respect your rights to privacy. We are providing this Privacy Statement to inform you about the type of information we collect from you, the purposes for which it is intended to be processed, the circumstances in which that information may be disclosed to third parties, and your rights according to data privacy laws.
1. Who is responsible for data processing and who can I contact?
The responsible entity is:
EBG Investment Solutions AG
Data Privacy Officer
Bellerivestrasse 29
8008 Zürich
Switzerland
You can contact our data privacy officer at:
EBG Investment Solutions AG
Data Privacy Officer
Bellerivestrasse 29
8008 Zürich
Switzerland
E-mail: compliance@ebg-is.com
2. Which sources and data do we use?
We collect and process personal data that we receive from customers and investors, and prospective clients in the context of our business relationships. We also process – to the extent needed to provide our services – personal data that we have reliably obtained from sources available to the public (e.g. commercial registers, the press, or the internet) or that are legitimately provided to us by other third parties (e.g. rating agencies and information services) and which may be processed.
We process the following categories of personal data:
a) Contact Data: information such as a person’s full name, maiden name, address, email address, telephone number.
b) Professional Data: Contact Data (as above) as well as information about a person’s employer and professional status (e.g. title, position, qualifications, and experience).
c) KYC (Know Your Customer) Data: Contact Data and Professional Data (as above) as well as date of birth, passport/photographic identification, financial situation (e.g. origin of assets), any criminal history data and any other information required to perform KYC and similar checks.
d) Communication Data: Contact Data (as above) as well as the subject matter, content, and associated metadata (e.g. timestamps, receipts, logs etc.) of communications.
e) Service Data: Contact Data (as above) as well as user profiles, classifications, financial data (e.g. bank account details) and other information required to provide the respective services.
f) Usage Data: technical data (such as IP address, operating system, type of device, time of access) that is collected automatically when accessing our website or internet-based services.
3. Why do we process your data and on what legal basis?
We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP):
a. To meet contractual obligations (article 6 para. 1(b) GDPR)
Data is processed in order to provide the agreed business and financial services to our clients or to carry out pre-contractual due diligence and other procedures. The purposes of data processing reflect the specific products and services which may include requirements analysis, advice, asset management and support, as well as carrying out transactions. Further details can be found in the relevant contract documents, terms and conditions.
b. Based on the balance of interests (article 6 para. 1(f) GDPR)
We may process data that goes beyond the actual fulfilment of contractual obligations to safeguard our legitimate interests or those of third parties (weighed against the interests of affected persons requiring protection of personal data) such as the following:
- consulting and exchange of data with agencies and information services as part of our due diligence, ongoing monitoring and other risk management procedures;
- adapting documentation and procedures to improve their relevance to investors;
- marketing or market research, to the extent there was no objection to such use;
- protecting and ensuring the integrity of our IT systems security and operations;
- protecting and ensuring physical security (e.g. in access controls, video surveillance);
- providing evidence to assert, exercise and defend legal claims in the case of legal disputes;
- preventing and investigating criminal activity;
- measuring and managing risks at EBG; and
- developing our business services, products, and processes.
c. Based on your consent (article 6 para. 1(a) GDPR)
To the extent that consent has been granted to us to process personal data for certain purposes (e.g. analysis of activities for marketing purposes), it forms the legal basis for such processing. Consent may be revoked at any time. This also applies to revoking consent given before application of the GDPR, i.e. before May 25, 2018. Please note that revocation of consent applies only to the future and does not affect the legality of any processing that took place prior to it being revoked.
d. Based on legal requirements (article 6 para. 1(c) GDPR) or in the public interest (article 6 para. 1(e) GDPR)
We are subject to numerous statutory obligations (e.g. FIDLEG, Collective Investment Schemes Act, Anti-Money Laundering Act, tax laws), regulatory directives (FINMA ordinances and circulars), and other external requirements and expectations. The purposes of data processing include our compliance with these requirements, verification of identity and age, prevention of fraud and
money-laundering and compliance with tax monitoring and reporting obligations, as well as the evaluation and management of risks.
4. Who receives my data?
The following paragraphs set out details of where we transfer client personal data to and the purpose of any such transfer.
a) Authorities within our company who need this data to meet our contractual and legal obligations are granted access to said data. Processors employed by us (Article 28 GDPR) may also receive data for these purposes. These are companies and contractors engaged in the activities of banking, financial services, IT services, logistics, printing services, telecommunications, advice and consulting as well as sales and marketing.
b) Data is only forwarded to recipients outside our company if legal provisions require this or the investors and the other affected persons have given their consent. Under these conditions, recipients of personal data may include:
- on request (e.g. as required to process a transaction as instructed);
- public authorities or law enforcement agencies if there is a legal or official obligation;
- other financial services institutions or comparable bodies to which we send personal data for performing the business relationship (depending on the contract: e.g. banks, brokers, managers, administrators, stock exchanges, sales offices assigned for an investment fund).
- The investment vehicle(s) and related bodies in which investors invest and for which EBG provides its services, and;
- Other data recipients that may include authorities to which we have consent to send data, or where we are released from confidentiality in respect of both the recipient and data involved.
EBG has adopted appropriate organizational and technical safeguards to protect personal data.
5. Is data sent to a third country or to an international organisation?
Data is only sent to third countries (countries outside Switzerland and the European Economic Area – EEA) if it is required to execute instructions (e.g. payment, investment and securities instructions), it is prescribed by law or the affected persons have given us their consent. We will inform them separately about the details if stipulated by law.
6. How long will my data be stored?
If required, we will process and store personal data for as long as it is necessary to fulfill our contractual and statutory obligations. It should be noted that our business relationship may last many years. We will normally retain records for a minimum of ten years from, for example, the time the business relationship comes to an end, to comply with regulatory and contractual requirements. Storage periods may however be extended further if there are particular reasons, and where affected by legal hold requirements or statutory limitation periods certain documents and data may require indefinite retention.
7. What data protection rights do I have?
8. Is there a duty to provide data?
Each affect person has the right of:
- access to information according to Article 8 FADP (Article 15 of the GDPR),
- rectification or erasure according to Article 5 FADP (Article 16/17 of the GDPR),
- restriction on processing according to Articles 12, 13, 15 FADP (Article 18 of the GDPR),
- objection to processing according to Article 4 FADP (Article 21 of the GDPR) (see appendix),
- data portability according to Article 20 of the GDPR, and
- appeal to a data protection supervisory authority (Article 77 of the GDPR).
Any consent granted to us for the processing of personal data may be revoked at any time. This also applies to revoking consent given to us before application of the GDPR, i.e. before May 25, 2018. Please note that revocation of consent applies only to the future and does not affect the legality of any processing that took place prior to it being revoked.
Only personal data that is required to establish, conduct and terminate a business relationship or which we are required to collect must be provided as part of our business relationship. Without this data, we will usually have to refuse to conclude the contract or execute the order or no longer be able to perform an existing contract and have to terminate it.
We are obligated according to the anti-money laundering regulations to identify our customers before establishing the business relationship, for example, with your identity card and at least collect information including the name, place of birth, date of birth, nationality and home address. In order to ensure that we meet this legal obligation, the necessary information and documents must be made available to us according to the applicable regulations for preventing money laundering and terrorism financing and to communicate changes that occur over the course of the business relationship without delay. If the necessary information and documents are not made available, we may not enter into or continue the business relationship.
9. To what extent is there an automated decision-making process?
In establishing and carrying out a business relationship, EBG generally does not use automated individual decision-making processes pursuant to Article 22 of the GDPR. If we deploy such processes in individual cases, we will communicate this separately and/or seek explicit consent where required.
10. To what extent will my data be used for profiling (scoring)?
Data may sometimes be processed in an automated manner to help identify certain personal characteristics or behaviors (profiling). For example, profiling may be used as follows:
- In accordance with legal and regulatory requirements, we are obliged to take measures to combat money laundering, terrorism financing, and criminal offenses that compromise assets. Automatic data analysis (particularly the automatic monitoring of cash transactions) may be used to help identify potentially suspicious activity. These measures are also for the protection of investors.
- We may use scoring in credit risk assessment. The technique typically assigns probabilities that clients will meet payment obligations based on data that may include professional data, financial circumstances, repayment history, and information from credit agencies. EBG currently does not use such scoring assessments.
11. Do you collect Biometric Data?
Biometric data is classified as sensitive personal data under the GDPR. Explicit consent will be requested in a separate process for any deployment of biometric identification for systems access.
website privacy policy
The use of our website is usually possible without providing personal data. As far as personal data (e.g. name, address or e-mail addresses) is collected on our website, this is always done on a voluntary basis, as far as possible. This data will not be passed on to third parties without your express consent.
We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible.
The use of contact data published within the scope of the imprint obligation by third parties for sending advertising and information material not expressly requested is hereby expressly prohibited. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, for example through spam mails.
GOOGLE ANALYTICS
This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymization is activated on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link to the plug-in.
EXTERNAL LINKS
Links to third-party content are provided as a service. Their operators are responsible for these contents, therefore we cannot assume any liability for these third-party contents.
ACTUALITY / DISCLAIMER
The website is constantly being updated, therefore information can be supplemented, removed or changed without prior notice. No liability is assumed for the correctness of the publications, data and links.
© COPYRIGHT
This website and all associated texts, graphics and other materials are protected by copyright. Any use without prior written consent is not permitted.
