GeneralThis Privacy Policy sets out the provisions regarding the processing of Personal Data when you use the website (https://www.simplewealth.ch,
hereinafter referred to as “the Website”) as a visitor and/or client, and/or when you use the services (hereinafter referred to as “the Services”) provided by Simplewealth AG (CHE-324.715.255), registered office in Zurich, Switzerland (hereinafter referred to as “the Simplewealth”, or “We (we)”).Simplewealth carries out the processing of the data lawfully, proportionately and in good faith. We will not use or share your Personal Data with anyone except as described in this Privacy Policy.For the purposes of this Privacy Notice, Simplewealth shall comply with the applicable data protection laws of Switzerland (in particular, Federal Act on Data Protection (FDPA) and the Ordinance to the Federal Act on Data Protection) and, when offering its services to the clients in the European Union (EU), the laws and regulations of the EU, in particular the General Data Protection Regulation (GDPR).The term “processing means any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (Art. 4 Para. 1 No. 2 GDPR). Referring to “Personal Data” under this Privacy Policy, we mean any information through which we can identify you as an individual.By using this Website and/or the Services provided by Simplewealth, you agree to the processing, including collection and use of your Personal Data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use at (https://www.simplewealth.ch/terms)
.This Privacy Policy may be reviewed and amended. Therefore, Simplewealth recommends reading it on a regular basis.Data collectionWe collect Personal Data about you from:- you directly, when you enter the Website and/or provide Personal Data to us, including via this Website and/or when you use the Services provided by Simplewealth. This may include, for example, when you complete the online questionnaire, undertake steps to open a Simplewealth Account, complete the Asset Management Agreement or contact us (e.g. by telephone call or e-mail).- third parties where you have authorised them, or- publicly available and open sources.What Personal Data do we process? We process the following Personal Data to the extent available to us and following applicable law and regulation:- contact details. Your name, address, telephone number, e-mail address and any other contact details provided to us;- your company details. If you are the legal representative of the company;- your use of our Services. Information regarding your use of our Services, such as information related to your registration, agreements with Simplewealth or third parties (e.g. Interactive Brokers) related to the Services;- your communication data. Any information or any other data that we receive from communication with you via e-mail, chat, telephone or through our Website;- your financial details. Financial information disclosed to us which can be linked to you as a client such as bank account details, tax residency, tax ID number etc.;- video/audio call recordings. Telephone calls with Simplewealth may be recorded. Simplewealth may use video or online identification to comply with AMLA due diligence duties and is obliged to make an audio recording of such interviews or take pictures of you and your identification documents according to the FINMA Circular on Video and Online Identification 2016/7;- recordings of the public events. We may make sound and/or video recordings and photos during the events that we host or participate in. You are free to leave the event in case you have objections to such recording;- data collected automatically. We collect data automatically through your browser or device using cookies or other technologies when you access our Website(s);- any other Personal Data. This includes any Personal Data that you disclose in the course of your onboarding or during a contractual relationship with us.Simplewealth does not collect the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and does not process genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.Log DataWe may also collect information that your browser sends whenever you visit our Website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of this Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.Cookiesport.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US
Cookies are files with a small amount of data, which may include a unique anonymous identifier. Cookies are sent to your browser from a website and are stored on your computer’s hard drive.We use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of this Website and/or the Services, and your online experience may be limited.We also provide you with the option to select or deselect the cookies through the cookie banner that appears on the screen when entering the Website.Third-party services and toolsWe may use third-party services, such as (but not limited to):- Heap Analytics [https://heap.io/privacy];- Intercom [https://www.intercom.com/legal/privacy];- Zoho Analytics, Zoho CRM [https://www.zoho.com/privacy.html];- KYC and ID verification services of Passbase [https://passbasedeveloper.gitbook.io/website-policies/];- Services supplied by Google Inc. This includes the Google AdWords remarketing service and Google Mail.We also use the tool “Google Analytics” to collect information about your use of the Website. Google Analytics collects information such as how often the users access the Website, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Website and Services. We do not combine the data collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.You can opt out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: [http://www.google.com/settings/ads]. Google also recommends installing the Google Analytics Opt-out Browser Add-on – [https://tools.google.com/dlpage/gaoptout] - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: [http://www.google.com/policies/privacy/].The third-party services and tools may collect, monitor, and analyse information, including your Personal Data, to support our activities and increase our Services’ functionality. These third-party services may use cookies, or otherwise process your Personal Data, to help us analyse how our visitors and/or clients are using this Website and/or the Services. Simplewealth uses remarketing services to advertise on third-party websites to you after you visited this Website. We, and our third-party vendors, use cookies to inform, optimise and serve ads based on your past visits to this Website. These third parties have their own privacy policies addressing how they process Personal Data.Our Website may contain links to other sites, including social media buttons, that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for any third-party sites or services’ content, privacy policies, or practices. We are not responsible for the processing of Personal Data by the relevant third parties.We may also use social media companies’ analytics tools to review ours from time to time our social media communication. These tools can also be used to optimise advertising materials. If you want to disallow any social medial companies from tracking your behaviour on this Website, their website or on other web pages, please see their privacy policies and options.We may use your Personal Data to:- provide and improve the Services provided to you;- open an account on your behalf with Interactive Brokers. Once you have signed the Asset Management Agreement to become a client, we open an account for you with Interactive Brokers. This is the account in which we will manage your assets. Accordingly, any Personal Data provided to us at any time may also be disclosed to Interactive Brokers. This sharing of information may occur before you complete the Asset Management Agreement;- verify your identity (compliance and due diligence according to AMLA);- improve and customise this Website to individual users, particularly in your client area of this Website;- notify or contact you about the Services provided by Simplewealth and other information that we believe may be of interest to you (including the marketing of our Services);- respond to your queries, questions and complaints;- communicate with you. We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that we consider may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any e-mail we send.- protect and/or enforce our legal rights and interests, including defending any claim;- share your Personal Data with other persons if we have a good-faith belief that access, use, preservation or disclosure of that Personal Data is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental or regulatory body request; enforce or investigate potential violations of our Terms of Use or other contract provision (including the Asset Management Agreement), and/or detect, prevent, or otherwise address fraud, security or technical issues; allow us to provide better services to you, and for any other purpose authorised by you or by law.What is our legal basis for processing your Personal Data?Simplewealth processes your Personal Data according to the applicable data protection laws. The following describes the legal basis for processing your Personal Data:- acting upon your consent. You may withdraw consent at any time by sending us an e-mail;- performing the agreement to which you are a party, or if taking steps at your request before entering into an agreement;- complying with our legal obligation;- pursuing our legitimate (business) interests (or those of third parties), which include, but is not limited to:i. managing our CRM system and databases, and contacting you for marketing or other commercial purposes;ii. detecting fraud, preventing crimes, hacking, spamming etc.iii. protecting the integrity of our systems and ensuring optimal functioning and security of our Website;iv. measuring the effectiveness of our marketing and improving it;v. developing our business activities and improving the quality of our Services;vi. pursuing management, recordkeeping, training and learning purposes; andvii. managing business operations and facilitating corporate transactions.To whom do we share your Personal Data? Simplewealth is authorised to share your Personal Data with third parties that take part or help us in the provision of the Services, or in order to manage and develop our business activities, or when required by applicable law.In particular, Simplewealth may share your Personal Data with third parties such as:- service providers, who assist us in service provisions, such as third-party vendors, business partners, suppliers (e.g. IT service providers, KYC/AML service providers etc.) and analytics and search engine providers (e.g. Google Analytics);- third parties involved by the applicable legislation. Simplewealth may share and disclose Personal Data to third parties where this is required by law (tax authorities, regulatory bodies and organisations, governmental, judicial agencies etc.), or in case of an investigation, the regulatory requirement (e.g. from FINMA, VQF), judicial and enforcement proceeding, court order or another legal proceeding;- third parties in case of a hacking, cyberattack, spamming, fraud, if we believe that such action is necessary to protect the security or integrity of our Website and/or the Services;- third parties related to corporate transactions. Personal Data may be disclosed in case of a corporate transaction. If Simplewealth is involved in a merger, acquisition or asset sale, your Personal Data may be disclosed and transferred. We will provide notice to you before your Personal Data is transferred and becomes subject to a different privacy policy.We take all necessary steps to ensure that your Personal Data is shared and treated securely and in accordance with this Privacy Notice and the applicable legislation of Switzerland and the EU.Which rights do you have with respect to your Personal Data?Subject to certain exemptions and exceptions, you have certain rights in relation to the Personal Data processed by Simplewealth:- Information right. You have the right to be informed about the collection and use of Personal Data. Simplewealth informs the data subject about the data collection at the point of data collection by the mean of this Privacy Policy.- Right of the access. Upon your request, Simplewealth will give you access to your Personal Data by confirming whether Simplewealth is processing your Personal Data, on what legal basis, and will provide you with a copy of the Personal Data processed.- Correction right. You may at any time request to rectify inaccurate or incomplete Personal Data.- Deletion right. Under the certain circumstances provided by law, e.g. listed in the Art. 17 Para 1 GDPR, you may request to erase Personal Data.- Right to restrict processing. If one of the conditions listed in the Art. 18 Para 1 GDPR applies, you may restrict personal data processing.- Data portability right means that you may ask Simplewealth to provide a copy in a machine-readable format of the Personal Data that Simplewealth processes.- Right to complain. You may at any time contact Simplewealth with your concerns with regard to this Privacy Policy. You may also complain to an appropriate data privacy regulatory authority or supervisory authority, e.g. Federal Data Protection and Information Commissioner (FDPIC). A list of local data protection authorities in EEA countries is published here.- Right of revocation. You can at any time withdraw your consent for the processing of your Personal Data. Please note that a withdrawal of consent does not affect the lawfulness of any processing that has taken place prior to consent withdrawal and that we can only activate your request according to applicable law.- Right to object. You may object, on grounds relating to your particular situation, if the lawfulness of the data collection is based on the public interest or legitimate interests of the controller or third party.The above-mentioned rights are subject to some exemptions in case the public or Simplewealth’s legitimate interest is in question. Simplewealth shall check whether you are entitled to the exercised right and contact you within one month.How do we secure your Personal Data?Simplewealth takes reasonable steps to ensure that your Personal Data is properly secured using appropriate technical, physical, and organisational measures. The security of your Personal Data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.How long do we store your Personal Data?We store your Personal Data based on applicable law and regulation and as long as it is required to satisfy the purpose for which the data is processed (for example, for the time necessary for us to provide you with client service, answer queries or resolve technical problems) unless a longer period is required for purposes such as complying with retention obligations for record-keeping or commercial requirements.Changes to this Privacy PolicyWe may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our Website. Changes to this Privacy Policy are effective when they are posted. Please review this Privacy Policy periodically for any changes.Contact detailsYou can contact us via e-mail at [email protected] with any question, request or complaint with regard to this Privacy Policy or your Personal Data. We will respond and/or comply with your request consistent with applicable law and regulation and as soon as reasonably practicable.As part of your request, please indicate which Personal Data you would like to receive, have changed or removed from our database or what limitations you would like to put on our use of the data. Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or complete any transactions you began before requesting a change or deletion.Simplewealth AGAddress:Stockerstrasse 458002 ZurichSwitzerlandTel.: +41 44 51 52 59 3E-mail: [email protected]