Data Protection and Privacy Statement of
VT Wealth Management AG
Version as of 31/08/2023
In this Data Protection and Privacy Statement, VT Wealth Management Ltd. (hereinafter referred to as VTWM, we or us) explains how we collect and otherwise process personal data. This is not an exhaustive description; other data protection regulations or general terms and conditions, conditions of participation and similar documents may regulate specific matters. Personal data is understood to be all information that relates to an identified or identifiable person.
This Data Protection and Privacy Statement is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR") as well as the Swiss Data Protection Act ("DPA"). However, whether and to what extent these laws are applicable depends on the individual case.
1 Data Protection Officer
The Data Protection Officer is responsible for the data processing activities we describe here. If you have any data protection concerns, you can communicate them to us at the following contact address:
VT Wealth Management AG
For the attention of Data Protection Officer
2 Purpose of Data Processing and Legal Basis
VT Wealth Management AG uses the data collected primarily to conclude and fulfill contracts or agreements with our customers and business partners, in particular in connection with the provision of financial services and the purchase of products and services from our suppliers and subcontractors, and to fulfill domestic and foreign legal obligations:
- In addition, in accordance with applicable law and where appropriate, we may process Personal Data for the following purposes that are in our (or, where applicable, a third party's) legitimate interest, such as:
- Providing and developing our products, services and websites, apps and other platforms on which we operate;
- Communicating with third parties and processing their requests (e.g. applications, media inquiries);
- Advertising and marketing (including the organization of events), unless you have objected to the use of your data for this purpose (if you are part of our customer base and receive advertising, you can object at any time and we will blacklist you against further advertising mailings)
- Assertion of legal claims and defense in legal disputes and official proceedings;
- Preventing and investigating criminal offenses and other misconduct;
- Ensuring our operations, including our IT, websites, apps and other applications;
- Acquiring and disposing of businesses, companies or parts of companies and other corporate transactions and the related transfer of personal data, as well as corporate governance measures and compliance with legal and regulatory obligations and internal regulations of the company.
Upon your consent to process your personal data for certain purposes (e.g. when registering to receive newsletters), we process your personal data within the scope of and on the basis of this consent, unless we have another legal basis if we need one. Consent given can be revoked at any time, but this does not affect the data processed before the revocation.
3 Collection and Processing of Personal Data
We primarily process personal data that we receive from our customers and other business partners, as well as from other individuals in the course of our business relationships with them, or that we collect from users in the operation of our websites, apps and other applications.
To the extent we are permitted to do so, we obtain certain personal data from publicly available sources (e.g. debtors' register, land register, commercial register, press, internet) or we obtain such information from affiliated companies of VT Wealth Management AG, from public authorities or other third parties (such as distribution partners, custodian banks, etc.). Apart from data provided to us directly by clients, the categories of data we receive about clients from third parties include, but are not limited to, information from public registers, data we receive in connection with administrative or judicial proceedings, information relating to the client's professional role and activities (e.g., for the conclusion and execution of contracts with your employer), personal data in correspondence and conversations with third parties, personal data provided to us by persons associated with the customer (family members, consultants, legal representatives, etc.) for the conclusion or execution of contracts with the customer or with the customer's cooperation (e.g. powers of attorney), data relating to legal requirements such as. e.g. for anti-money laundering purposes, bank data, information about the customer that can be found in the media or on the Internet (if specified in the individual case, e.g. in connection with job applications, media reports, marketing / sales, etc.), addresses and any interests and other socio-demographic data (for marketing purposes), data in connection with the use of our websites (e.g., IP address, MAC address of your smartphone or computer, information about devices and settings, cookies, date and time of your visit, pages and content accessed, applications used, referring website, localization data).
It is our policy that we store this data for 12 months after the end of the processing purpose. This period may be longer if this is necessary for evidentiary reasons or to fulfill legal or contractual requirements.
4 Cookies / Tracking and other relevant information about the use of our Website
We typically use "cookies" and similar technologies on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you are using when you visit our website. This allows us to recognize you when you return to this website, even if we do not know who you are. In addition to cookies that are only used during a session and deleted after your website visit ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser to reject cookies, store them for one session only, or otherwise delete them early. Most browsers are preset to accept cookies. We use persistent cookies to help us understand how you use our services and content, and to provide you with customized offers and advertising (which may also occur on other companies' websites; however, we do not tell them who you are, if we even know, because they only see that the same user is on their site who was on a particular page on ours). Some of the cookies are set by us, and some are set by contractors with whom we work. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.
We also include visible and invisible image elements in some of our newsletters and other marketing emails, where permitted, that allow us to determine if and when you have opened the email by retrieving them from our servers so that we can measure and better understand how you use our offers and tailor them to you here as well. You can block this in your email program; most are preset to do so.
Whenever you visit our website, your user-specific data (e.g. IP address, web browser, operating system) and technical data (e.g. URLs of accessed pages, execution of a search query) are collected and analyzed anonymously.
The aforementioned data is collected and processed for the purposes of system security and stability, error and performance analysis, and internal statistical purposes, and enables us to optimize our website.
When subscribing to our content or submitting a contact form/customer login, we process the data required to provide the requested service. Depending on the service, the following data may be processed: Email address, first name, last name, title, full address, subject and message.
Upon your consent to process your personal data for certain purposes (e.g. if you subscribe to a newsletter or make an inquiry), we process your personal data within the scope of and on the basis of this consent, unless we have another legal basis if we need one. Consent given can be revoked at any time; however, this does not affect the data processed until revocation.
It is our policy that we store technical data for 6 months.
Whenever you contact us via the contact form, by e-mail, telephone or chat, by letter or by other means of communication, we collect the data exchanged between you and us, including your contact details and the marginal data of the communication. If we record or listen to telephone conversations or video conferences, for example for training and quality assurance purposes, we will notify you. Such recordings may only be made and used in accordance with our internal policies and legal requirements.
In principle, we store this data for 12 months from the last exchange with you. This period may be longer if required for evidentiary reasons, to meet legal or contractual requirements, or for technical reasons. Emails in personal mailboxes and written correspondence are generally retained for at least 10 years. Recordings of (video) conferences are generally retained for 24 months. Chats, if available, are generally retained for 2 years.
Google Analytics and similar services
With the aim and intention of designing and continuously optimizing our website in line with requirements, we may use Google Analytics or similar services on our website. These are third-party services that may be located in any country in the world (in the case of Google Analytics Google Ireland Ltd (based in Ireland), Google Ireland uses Google LLC (based in the USA) as a subcontractor (both "Google"), https://www.google.com/. The cookies used by Google Analytics are stored on your computer and thus enable an analysis of your use of the website.
The use of Google Analytics is based on your consent to the tracking of your surfing behavior on our websites and their analytical evaluation.
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. These cookies may contain the following information, for example: IP address, number, date and time of visit, duration of visit, your access page from which you use the website (reference URL), pages visited on our website, browser type/version and operating system used. Google will use this information on our behalf because we have a legitimate interest in analyzing user behavior so that we can optimize the offer on our website as well as our advertising. Google uses this information to evaluate the use of our website, to compile reports on website activity and to provide us with other services related to the use of the website and internet usage. Likewise, pseudonymized usage profiles of the users can be created from the processed personal data.
We may have activated the IP anonymization function on this website (so-called IP masking). This means that your IP address is shortened by Google within member states of the European Union, in other contracting states of the Agreement on the European Economic Area and in Switzerland before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
Social Media Plug-Ins
VT Wealth Management AG may use so-called plug-ins from social networks such as Facebook, LinkedIn, YouTube, etc. on its websites. This is apparent to you in each case (typically via corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator according to its data protection regulations. We do not receive any information about you from him.
5 Disclosure of Data to Third Parties and Transfer of Data abroad
In the course of our business and in accordance with the purpose of data processing as explained herein, we may transfer data to third parties where such transfer is permitted and where we consider it appropriate for them to process the data on our behalf or, where applicable, for their own purposes. In particular, the following categories of recipients may be involved:
- Our service providers (e.g. risk management & compliance, IT provider, accounting, CRM system / PMS, etc.)
- Domestic and foreign authorities, official bodies and courts
- Other parties in potential or actual legal proceedings
Some recipients are located in Switzerland, others may be located in any country worldwide. In particular, you should expect that your data will be transferred to any country where VTWM is represented by subsidiaries, branches or other offices, as well as to other countries in Europe and the U.S. where our service providers are located (such as Microsoft, Salesforce.com, etc.).
If a recipient of any such data is located in a country without sufficient legal data protection, we oblige the recipient to comply with data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? ), unless the recipient is subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception. An exception may apply, for example, in the case of legal proceedings abroad, but also in cases where there is an overriding public interest or the performance of a contract requires the transfer, if you have consented or if the data has been provided by you in general and you have not objected to the processing.
6 Duration of Data Storage
All data, which includes personal data, will only be processed and stored for as long as is necessary to fulfill our contractual and legal obligations or the purposes otherwise pursued with the processing, in particular for the duration of the entire business relationship and beyond that due to legal retention obligations and documentation requirements. It is possible that personal data will be retained for the period during which claims can be asserted against our company and insofar as we are otherwise legally obligated to do so or if legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the aforementioned purposes, it will be deleted or anonymized as far as this is possible. For operational data (e.g. system logs, logs) shorter retention periods of 12 months or less apply.
7 Data Protection
VTWM has taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse. These measures include issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of passwords, data storage and transfer, pseudonymization and controls.
However, we cannot guarantee the security of data transmission on the Internet. In particular, when transmitting data by e-mail, there is a certain risk of access by third parties.
8 Rights of the Person concerned
Under applicable law, customers have the right to access, correct and delete their personal data, the right to restrict processing or to object to our data processing, in particular for direct marketing purposes, profiling for direct marketing purposes and other legitimate interests in processing, and the right to obtain certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to assert legal restrictions on our part, e.g. if we are obliged to retain or process certain data, have an overriding interest (insofar as we can rely on such interests) or need the data to assert claims.
We have already informed you of the possibility to object / revoke your consent at any time. Please also note that the exercise of these rights may conflict with your contractual obligations and this may result in consequences such as premature termination of the contract and may be associated with costs. Should this be the case, we will inform you in advance, unless this has already been contractually agreed.
In general, the exercise of these rights requires that you can prove your identity (e.g., by providing a copy of identification documents if your identity is not otherwise apparent or can be otherwise verified). To exercise these rights, please contact us using the details provided above.
In addition, every person concerned has the right to assert his or her rights in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html ).
9 Profiling and automated individual Decision Making
Personal data may be partially processed automatically in order to evaluate certain personal aspects (profiling). Profiling enables us in particular to better inform and advise you about products that may be relevant to you. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise to you as needed, including market and opinion research.
When initiating and conducting a business relationship, we do not generally use fully automated individual decision-making (such as pursuant to Article 22 DSGVO). Should we use such procedures in certain cases, we will inform you separately about this and inform you of your rights in this regard, insofar as this is required by law.
10 Third Party Data Protection and Privacy Statements
11 Changes and Amendments to the Data Protection and Privacy Statement
VTWM may from time to time and when needed adapt, supplement or otherwise change this data protection declaration at any time without prior notice and without stating reasons. The current version published on our website shall apply.