Privacy Policy

We at Wydler Asset Management AG take the protection of your data very serious. We treat your data confidentially and in accordance with current data protection laws. This privacy policy describes how we collect and process personal data and sets out your rights over your personal information.

Definitions

  • “Activities” refers to all our activities, in particular asset management and investment advisory, “Execution Only” and in the case of an application process or employment with Wydler Asset Management AG.
  • “Data Protection Laws” includes in particular the Swiss Data Protection Act (DSG) and its ordinances, the EU General Data Protection Regulation (GDPR) and any other applicable data protection regulations.
  • “Processing” has the meaning provided for in the respective applicable Data Protection Laws (under the DPA, this includes, in particular, obtaining, storing, retaining, using, modifying, disclosing, archiving, deleting or destroying data)
  • “Personal Data” means any information that relates to an identified or identifiable natural person or that is defined as such by the respective applicable Data Protection Laws

Contact

Responsible for data processing is:

Wydler Asset Management AG

Korporationsweg 13c

CH-8832 Wilen b. Wollerau

Telephone: +41 44 575 18 11

E-Mail: group@wydlerinvest.ch

If you have any questions or other concerns in connection with the processing of your data, please contact us.

The information we collect and how we use it

In the course of our activities and to fulfill our contractual, regulatory and legal obligations, we collect the following personal data:

  • Personal data and contact and identification data of clients and prospects (e.g. surname, first name, address, email address, telephone number, cell phone number, company name, date of birth, gender, marital status, nationality, passport, ID) and, in individual cases, particularly sensitive personal data, such as information relating to administrative and criminal convictions and offences (e.g. in the case of investigations under money laundering and sanctions regulations);
  • Professional contact data of authorized representatives of service providers and contractual partners as well as of interested investors (e.g. surname, first name, address, e-mail address, telephone number, cell phone number, function, absence information, gender, marital status);
  • Private contact and identification data of employees and applicants (e.g. surname, first name, address, e-mail address, telephone number, cell phone number, date of birth, nationality, social security number, passport, ID);
  • Personal and professional data of employees and applicants (e.g. data on spouses and children, marital status, photos of employees, CVs, diplomas, letters of reference, grades, evaluations, certificates, extracts from criminal records, extracts from debt collection registers, sanctions list queries, bank details).

Origin of personal data

We normally obtain personal data directly from you or your authorized representatives. The collection of personal data usually takes place as follows:

  • When you use our website;
  • When you apply for a job with Wydler Asset Management AG and during your employment;
  • On the occasion of meetings or communication with our employees or authorized representatives;
  • On the occasion of professional contacts (e.g. events, presentations);
  • When you sign up for our newsletter about our two funds, the Wydler Global Equity Fund and the Wydler Global Bond Fund, on our website;
  • Through publicly available sources (e.g., media, internet, publicly available registers, sanctions addressee lists);
  • From supervisory bodies and authorities (e.g. supervisory organization, FINMA, courts, public prosecutors) in the course of their activities.

Purpose of processing

We will only use your personal data in the course of our activities and/or to fulfill our contractual, regulatory or legal obligations and to protect our own interests and those of our employees. Personal data will be used by us in particular for the following reasons:

  • When communicating with you and in the course of our activities;
  • To provide you with an ongoing service (for example, to send you information or marketing materials that may be of interest to you);
  • To comply with regulatory, legal or internal requirements.

Please note that you may opt out of receiving marketing communications from us at any time. In this case, please contact us using the contact details above or choose the opt-out option provided in the marketing communication.

Disclosure to third parties

Within Wydler Asset Management AG, those persons have access to your data who need it to fulfill our contractual, regulatory or legal obligations. We do not sell your data to third parties.

In order to provide you with the services you have requested and for the above purposes, your personal data may be disclosed to third parties. 

We also take reasonable steps to ensure that our contracted third parties are bound by confidentiality and data protection obligations with respect to the protection of your personal data. These third parties may include: 

  • External service providers (e.g., accountants, IT service providers, compliance and risk management service providers);
  • External consultants (e.g., attorneys and tax advisors);

Where necessary or due to our regulatory or legal obligations, your personal data may also be disclosed to other third parties (e.g. auditors, supervisory organization, FINMA, authorities and courts).

In some cases, personal data may be transferred to a country outside Switzerland, namely to countries in the European Economic Area (“EEA”) or the European Union (“EU”) that have an adequate level of data protection set by the EU / with your consent to other countries without an adequate level of data protection.

Data security

It is important to us to protect your personal information from misuse, loss, alteration, unauthorized access, modification or disclosure. Access to and use of personal information is regulated internally to prevent misuse or unlawful disclosure of such information. We have limited access rights and use security procedures such as firewalls, anti-virus technology and password login to prevent unauthorized access. Data between your browser and our server is transmitted in encrypted form over a secure SSL connection.

Retention period

We retain records containing personal data and store information only for as long as is necessary to provide you with continued service or to fulfill any of our contractual obligations, but also longer if required by law. When personal data is no longer required by us, it will be destroyed or deleted as far as this is technically possible and legally permitted and can be ensured with a reasonable effort.

Right to information and access

You may contact us by email or telephone to request access to the personal information we hold on you. However, please note that we must verify your identity before we can grant you access to the information. There may be legal reasons that prevent us from granting access, particularly if doing so would compromise the privacy of others or breach confidentiality. If we deny access, we will notify you in writing of the reasons and give you an opportunity to appeal. There may be a cost to access this information, but there is no cost for requests or corrections to your personal information.

Correction of personal data

We strive to keep your personal information accurate, complete, accurate and relevant. To this end, we ask that you notify us if your information changes. If you believe that the personal data we hold on you is inaccurate, incomplete or misleading, or if you wish it to be deleted, you may write to us at any time to request that it be amended or deleted. Our dedicated privacy officer will arrange to correct or update the information.

Likewise, you have the right to restrict processing and may revoke your consent to processing at any time.

Use of our website

Well knowing that the internet is not a fully secure network, we cannot guarantee that the transmission of any information or data you transmit to us online will be safe. We also cannot guarantee that the information you submit will not be intercepted during transmission over the Internet. Therefore, any personal data or other information you transmit to us online is done so at your own risk.

Cookies

  1. We use cookies on our website. Cookies are small text files that your internet browser places and saves on your computer. When you re-visit our website, these cookies provide information to automatically recognize you. The information obtained in this way serves the purpose of optimising our web offers both technically and economically and of enabling you to access our website more easily and securely. When logging into our website, you are informed about the use of cookies and how you can object to, or prevent their storage (“opt-out”) by referring to our data protection declaration. Our website uses session cookies, persistent cookies and third-party cookies:
    • Session cookies: allow websites to recognize multiple use of an offer by the same user (e.g. if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information is used to optimize our offers and make it easier for you to access our site. When you close the browser or log out, the session cookies are deleted.
    • Persistent cookies: are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies at any time in the security settings of your browser.
    • Third-party cookies: You can configure your browser settings according to your preferences, e.g. you can refuse to accept third-party cookies or all cookies. However, please note that if you do so, you may not be able to use all the features of our website. Please read more about these cookies in the respective third-party privacy statements.
  2. objection and “opt-out”: you can object to the processing of your data by cookie technologies at any time. We would like to point out that this may result in a functional restrictions on our offers. You can generally prevent cookies from being stored on your hard drive by selecting “do not accept cookies” in your browser settings. You may object to the use of cookies from third parties for advertising purposes by setting up an “opt-out” instruction via the American website (https://optout.aboutads.info) or the European website (http://www.youronlinechoices.com/de/praferenzmanagement/).
  3. revocation: if you have given your consent to data processing by cookie technologies, you can revoke it at any time by deselecting (opt-out) in the cookie management tool.

Google Analytics

We use “Google Analytics”, a web analysis service of Google LLC, to analyse how visitors use our website. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Scope of the processing

The information collected by means of the cookies about your use of this website is usually transferred to a Google server in the USA and stored there.

We use the function User-ID. The User ID allows us to assign a unique, permanent ID to one or more sessions (and the activities within these sessions) and to analyze user behavior across devices.

We use the function ‘anonymizeIP’ (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP address will be shortened by Google within member states of the European Union or in other states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other data from Google.

During your website visit the following data is recorded:

  • the pages you call up, your “click path
  • Achievement of “website goals” (conversions, e.g. newsletter registrations, downloads, purchases)
  • Your user behavior (for example clicks, dwell time, bounce rates)
  • Your approximate location (region)
  • Your IP address (in abbreviated form)
  • technical information about your browser and the end devices you use (e.g. language settings, screen resolution)
  • Your internet provider
  • the referrer URL (via which website/advertising medium you came to this website)

Purposes of processing

Google will use this information on behalf of the operator of this website, to evaluate your use of the website and to compile reports on website activities. The reports provided by Google Analytics serve to analyze the performance of our website and the success of our marketing campaigns.

Recipient

The recipient of the data is

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

As a contract processor. For this purpose, we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google.

Transfer to third countries

A transfer of data to the USA cannot be excluded.

Storage period

The data sent by us and linked to cookies is automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

Furthermore you may prevent the data collection generated by the cookies in relation to your use of the website (including your IP address) to Google, and the processing of this data by Google, by

  1. not giving your consent to the setting of the cookie or
  2. downloading and installing the browser add-on to disable Google Analytics HERE.

You can also prevent the storage of cookies by setting your browser software accordingly. However, if you configure your browser to refuse all cookies, this may limit the functionality of this and other websites.

Existence of an automated decision making process

We do not use automatic decision making or profiling.

Legal basis and right of withdrawal

You can withdraw your consent at any time with effect for the future by calling up the cookie settings and changing your selection there.

Further information on the terms of use of Google Analytics and on data protection at Google can be found at https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=de.

Google ReCAPTCHA

  1. we have integrated on our website the anti-spam function “reCAPTCHA” from “Google” (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). By using “reCAPTCHA” in our forms, we can determine whether the input was made by a natural person (humans) or abusively by machine and automated processing (robots). When using the service, your IP address and any other data required for this purpose may be transmitted to Google servers in the USA.
  2. The purpose of processing this data is to avoid spam and misuse and at the same time helps us to optimize our website.
  3. you can find further information about Google ReCAPTCHA at https://www.google.com/recaptcha/ and in the Google privacy policy at https://policies.google.com/privacy.

Complaints

If you are unhappy with the way we have handled your personal data, you may contact us for assistance.

We ask that you submit complaints about suspected data breaches in writing so that we may continue to contact you in connection with your complaint.

If you have contacted us and believe that we have not handled your matter properly, you may contact the relevant data protection authority, which in Switzerland is:

Federal Data Protection and Information Commissioner

https://www.edoeb.admin.ch/edoeb/de/home.html

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy if we deem it necessary at a later date or if required by data protection laws.

By visiting www.wydlerinvest.ch you accept and consent to the practices outlined in this notice.