NHP Asset Management AG Claridenstrasse 20, 8002 Zürich, Switzerland info@nhpag.ch +41 43 443 80 90

Privacy Notice

General information

This privacy policy provides information about how NHP Asset Management AG (“NHP”) processes personal data.

Responsibility for data processing

NHP is responsible for processing your personal data. Enquiries can be sent to the following address:

NHP Asset Management AG

Claridenstrasse 20

8002 Zurich

Email: info@nhpag.ch

Applicable Data Protection Law

This privacy policy complies with the requirements of the Swiss Federal Act on Data Protection (FADP, in particular Articles 25, 31, and 32) and the European Union’s General Data Protection Regulation (GDPR, in particular Articles 6, 15 ff.). It applies to all persons whose personal data is processed by NHP, regardless of their nationality or place of residence.

Terms

“Personal data” refers to all information relating to an identified or identifiable natural or legal person. “Processing” refers to any handling of personal data, regardless of the means and procedures used, in particular the collection, storage, use, modification, disclosure, archiving, deletion, or destruction of personal data.

Categories of Personal Data

NHP processes the following categories of personal data depending on the business relationship or use of our website. As little personal data as possible is always processed.

Customer data, such as:

  • Master and inventory data (e.g., name, address, nationality, date of birth, information regarding accounts, securities accounts, concluded transactions and contracts, information about third parties who are also affected by data processing, such as spouses, authorized representatives, and advisors);
  • Contract and transaction data or order and risk management data (e.g., details of the beneficiaries of transfers, beneficiary bank, amount of transfers, risk and investment profile, details of investment products);
  • Communication data (e.g., email, telephone, correspondence);
  • Marketing and preference data (e.g., interests, feedback, newsletter subscriptions);
  • Technical data when visiting our website (e.g., IP address, browser type, device information, access time, cookies).

Origin of Personal Data

NHP receives data

  • directly from you (e.g. in connection with the performance of a contract, inquiries, online forms);
  • from the use of our website and electronic services;
  • from third parties (e.g. from authorities, public registers, sanctions lists).

Purpose of Processing

NHP processes personal data for the purpose of providing its own services and for its own or legally prescribed purposes. In particular, this involves the following purposes:

  • Concluding and fulfilling contracts, implementing, processing, and managing products and services (e.g., invoices, investments);
  • Monitoring and controlling risks (e.g., investment profiles, anti-money laundering, limits, utilization ratios, market risks);
  • Planning, business decisions (e.g., development of new services and products or evaluation of existing ones);
  • Marketing, communication, information about the range of services and review thereof (e.g., advertising in print and online, customer, prospect, or other events, identification of future customer needs);
  • Compliance with legal or regulatory disclosure, information, or reporting obligations to courts, authorities, auditing companies, compliance with official orders (e.g., reporting obligations to FINMA and foreign supervisory authorities, orders from public prosecutors in connection with money laundering and terrorist financing);
  • Protecting our interests and securing our claims, e.g., in the event of claims against us or claims by us against third parties.

Disclosure to Third Parties, Categories of Recipients

NHP discloses customer data to third parties in the following cases if this is necessary to fulfil the purpose or is required by law:

  • for outsourcing and for the purpose of comprehensive customer service to other service providers (e.g., IT providers, compliance partners);
  • for order execution, i.e. when using products or services;
  • due to legal obligations, legal justifications or official orders (e.g. courts, supervisory authorities, tax authorities);
  • to the extent necessary to protect our legitimate interests, e.g. in the event of legal action threatened or initiated against us by customers, in the event of public statements, to secure our claims against customers or third parties, in the collection of receivables, etc.;
  • with your consent to other third parties.

Outsourcing of Services

NHP outsources certain services in whole or in part to third parties (in particular legal and compliance).

The service providers who process personal data on our behalf for this purpose (known as processors) are carefully selected. Wherever possible, processors domiciled in Switzerland are used. Under certain circumstances, processors may be entitled to have certain services performed by third parties.

Processors may only process personal data received in the same way as NHP itself and are contractually obliged to ensure the confidentiality and security of the data.

Data Transfer to Third Countries

The recipients of personal data may also be located abroad. If a recipient is located in a country without adequate data protection, NHP undertakes to comply with adequate data protection by concluding appropriate clauses. Otherwise, NHP will rely on legal exceptions for the transfer, such as your consent or the fact that the disclosure is directly related to the conclusion or execution of a contract between you and NHP.

Duration of Storage

The duration of the storage of personal data depends on the purpose of the respective data processing and/or legal retention obligations, which may be five, ten, or more years, depending on the applicable legal basis.

Use of our Website

Our website uses cookies and similar technologies to facilitate use, evaluate statistics, and improve marketing measures. When a person visits our website, the web server automatically records details of the visit (e.g., the website from which the visit originates, the visitor’s IP address, the content of the website accessed, including the date and duration of the visit). Such tracking data is used to optimize the websites visited and provides information about how visitors find out about and use the services and offers. However, it does not usually allow any conclusions to be drawn about the identity of the visitor. In this respect, no personal data is processed. However, if the visitor provides personal data, e.g. via our contact form, NHP may use this data in addition to the purposes mentioned above, in particular for the following:

  • for customer and user administration;
  • to inform the visitor about services and offers;
  • for marketing purposes (e.g. sending newsletters);
  • for technical “hosting” and further development of the website.

When visiting websites, visitor data is transported via the Internet, which is an open network accessible to everyone. Data transmitted via electronic media (including email) cannot be effectively protected against access by third parties. This entails, among other things, the risk that the data may be disclosed or its content altered, that the identity of the sender (e.g., email) and the content of the message may be spoofed or otherwise manipulated by unauthorized persons, that viruses may be released, that technical transmission errors, delays or interruptions, that data may be transferred abroad in an uncontrolled manner, where data protection requirements may be lower than in Switzerland, etc. By using the websites, visitors confirm their express agreement with this privacy policy and the risks mentioned.

In addition, by using the NHP website, visitors agree to the use of cookies. Cookies are small files that are stored on the visitor’s computer in order to track the corresponding website visit and navigation between different pages and/or to save settings (e.g., selected language). Cookies are used to collect statistical data on the frequency and timing of visits to individual website areas and help to design customized, useful, and user-friendly websites. Visitors can opt out of the use of cookies at any time by deleting the cookies set by the website.

NHP may use third-party components (such as plug-ins) to improve the user experience or online advertising campaigns. These components may also use cookies for similar purposes. Neither these third parties nor the jointly responsible parties have access to the data collected by the other party through cookies. This section of this privacy policy applies only to data that NHP receives based on the use of its website. It does not apply to third-party websites, even if the visitor accesses them via links on an NHP website. NHP has no influence on the content and data protection practices of third-party websites and therefore cannot accept any responsibility for them.

Profiling

NHP does not carry out automated individual decision-making or profiling within the meaning of Art. 22 GDPR.

Data Security

NHP is committed to protecting personal data and privacy in accordance with applicable laws. To this end, it takes various technical and organizational security measures (e.g., access restrictions, firewalls, personalized passwords, encryption and authentication technologies, etc.) to protect your data from loss, misuse, unauthorized access, or alteration.

Rights of Data Subjects

Any person may request information from NHP as to whether personal data concerning them is being processed (Art. 25 FADP, Art. 15 GDPR). There is a right to object (Art. 21 GDPR), to restrict processing (Art. 18 GDPR) and, where applicable, a right to data portability (Art. 20 GDPR). Incorrect data can be corrected (Art. 32 FADP, Art. 16 GDPR). In addition, where applicable, there is a right to lodge a complaint with a competent authority (Art. 77 GDPR). Finally, the deletion of personal data may be requested, provided that this does not conflict with legal or regulatory requirements (e.g., legal retention obligations for business-related data) or technical obstacles (Art. 32 FADP, Art. 17 GDPR). However, the deletion of data may result in NHP no longer being able to provide certain services. Where we process personal data on the basis of consent, this consent may be revoked at any time.

Organizations, Companies, etc. Mentioned

Organizations and companies are mentioned by name or described in this privacy policy. As certain adjustments may be necessary in the future due to legal, regulatory, and/or organizational changes, it goes without saying that successor organizations are also covered by this policy.

Changes to this Privacy Policy

NHP reserves the right to amend this privacy policy as necessary, for example in the event of legal or technical changes. The current version is published on our website.