1 Who this privacy notice applies to and what it covers

This privacy notice applies to AA-Partners Ltd. with offices at Waldmannstrasse 8, 8001 Zurich/ Switzerland.

We are committed to protecting your personal data and processing your information in an open and transparent manner. This privacy notice sets out how we will collect, process, store and protect information about you when: (i) providing services to you or our clients; (ii) you use "our Website"; or (iii) performing any other activities that form part of the operation of our business.

When we refer to "our Website" or "this Website" in this policy we mean the specific webpages of AA-Partners Ltd.

In this privacy notice, your information is sometimes called "personal data". We may also sometimes collectively refer to processing, collecting, protecting and storing your personal data as "processing" such personal data.

2 What information we collect

We may collect, record and use information about you and our client in physical and electronic form and will hold, use and otherwise process the data as set out in this notice.

In the course of providing services to you or our client and performing due diligence checks in connection with our services (or communicating with you regarding possible services we might provide), we may collect or obtain personal data about you. We may also collect personal data from you when you use this Website.

We may collect or obtain such data because you give it to us (for example in a form on our Website), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available. The legal grounds for processing your data are set out under ‘The legal grounds we use for processing personal data’.

We may also collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience when you use this Website and ensure that it is functioning effectively, we (or our service providers) may use cookies and Web beacons which may collect personal data.

The personal data that we may collect or obtain may include: (i) your name, gender, age and date of birth; (ii) your contact information, such as your address and contact details (including your email and mobile telephone number); (iii) country of residence; (iv) employment and education details (for example, the organization you work for, your job title and your education details); (v) government identifiers (for example your personal public service number, passport number, driver’s license); (vi) your IP address, your browser type and language, your access times; complaint details; (vii) details of how you use our products and services.

If you fail to provide us with this information, or you object to us processing such information (see ‘Your rights’ below) the consequences are that we may be prevented from processing your instructions or continuing to provide all or some of our services to you or our client.

3 How we use information about you

We collect and process information about you and/or your business to enable us to provide our services to you and in order to meet our legal or regulatory obligations. In addition, some of your personal data may be used for other business purposes.

We will use your personal data to provide you or our clients or other third parties with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, other third parties, our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services. Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies.

We may also use your personal data for the purposes of, or in connection with: (i) applicable legal, regulatory or professional requirements; (ii) requests and communications from competent authorities; (iii) client account opening and other administrative purposes; (iv) financial accounting, invoicing and risk analysis purposes; (v) client and prospect relationship purposes, which may involve: (a) sending you insights, opinions, updates, reports on topical issues or details of our products and services that we think might be of interest to you; (b) contacting you to receive feedback on services; and (c) contacting you to invite you to events, seminars, briefings; (vi) recruitment and business development purposes (for example testimonials from a client's employees may be used as part of our recruitment and business development materials with that employee's permission); (vii) services we receive from our professional advisors, such as lawyers, accountants and consultants; or (viii) protecting our rights and those of our clients.

In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website: (i) to manage and improve our Website; (ii) to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you; or (iii) to manage and respond to any request you submit through our Website.

4 The legal grounds we use for processing personal data

In order to process your personal data we rely on one or more of the following lawful grounds: (i) you have explicitly agreed to us processing your information for a specific reason; (ii) the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you; (iii) the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or (iv) the processing is necessary for the purposes of a legitimate interest pursued by us, which might be: (a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed; (b) to prevent fraud; (c) to protect our business interests; (d) to ensure that complaints are investigated; (e) to evaluate, develop or improve our services or products;  or (f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data in order to ensure we meet our 'know your client' and 'anti-money laundering' obligations (or other legal obligations imposed on us); (iii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iv) the processing is necessary for the establishment, exercise or defense of legal claims or (v) you have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

5 Sharing your personal data

In connection with one or more of the purposes outlined in the "How we use information about you" section above, we may disclose details about you to the following recipients, or categories of recipients: (i) third parties that provide services to us; (ii) competent authorities (including courts and authorities regulating us); (iii) your employer and/or their respective your advisers; (iv) any other person or organization after a restructure, sale or acquisition; (v) credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the "How we use information about you" section above.

6 Transferring your personal data

Information about you in our possession may be transferred to other countries (which may include countries outside the European Economic Area ("EEA")), such as jurisdictions in which and through which transactions are effected; jurisdictions linked to your engagement with us; jurisdictions from which you regularly receive or transmit information; or jurisdictions where our third parties conduct their activities.

You understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

7 Protection of your personal data

We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

8 How long we keep your information for

We will only keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.

9 Your rights

You have various rights in relation to your personal data. In particular, you have a right to: (i) obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you; (ii) be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed); (iii) ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete; (iv) ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data; (v) receive a copy of the personal data concerning you in a structured, commonly used and  machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent  or a contract); (vi) ask us to stop sending you marketing messages at any time by following the unsubscribe instructions in our communications or contacting us in the way set out in the ‘Right to complain’ section below; (vii) object to our processing of your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavor to respond within a reasonable period of time.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change using the contact details set out in the ‘Right to complain’ section below.

10 Sending you marketing information

We may use your information from time to time to inform you by letter, telephone, email and other electronic methods, about similar products and services (including those of third parties) which may be of interest to you. You may, at any time, request a change to your marketing preferences by following the instructions in communications from us or contacting us in the way described in the section ‘Right to complain’ below.

11 Right to complain

If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about privacy issues, or you wish to raise a complaint about how we are using your information you can contact us in the following ways: (i) write to AA-Partners Ltd., Waldmannstrasse 8, 8001 Zurich/ Switzerland; or (ii) send an email to info(at)aa-partners.ch.

12 Changes to this privacy notice

We may modify or amend this privacy notice from time to time. Therefore, we encourage you to periodically review this notice to be informed about how we are protecting your information.