Privacy Policy

1. General

This data protection declaration provides information on how we process personal data. “Personal data” is deemed to include all information referring to an identified or identifiable natural or legal person. The term “processing” applies to any handling of personal data, irrespective of the means or methods used, in particular the gathering, storage, use, alteration, publication, archiving, deleting or destruction of personal data. Further regulations exist for specific types of data processing, e.g. as part of the conclusion of contracts. These are available in the relevant contracts.

2. Data Security

In accordance with the applicable legislation, in particular professional ethics and the Data Protection Act, we undertake to protect personal data and personal privacy. For this purpose, we implement various technical and organisational security measures (e.g. access restriction, firewalls, personalised passwords, as well as encryption and authentication technology, staff training, etc.).

3. Categories of Personal Data

We process the following categories of personal data. The amount of personal data processed is always kept to a minimum. Customer data, such as:

• Master data and listing data (e.g. name, address, nationality, date of birth, account information, security account, transactions and contracts concluded, information on third parties affected by any data processing, such as spouses, authorised representatives and advisers).

• Transaction or instruction and risk management data (e.g. information on the beneficiaries of credit transfers, the beneficiary bank, the amount of credit transfers, the risk and investment profile, information on investment products.

• Technical data, (e.g. transaction number, IP addresses, internal and external identifiers, access records).

• Marketing data (e.g. preferences, requirements).

Visitor and Prospect Data (e.g., our visitors or visitors to our website), such as:

• Master data and listing data (e.g. name, address, date of birth)

• Technical data (e.g. IP addresses, internal and external identifiers, recording of access).

• Marketing data (e.g. preferences, requirements).

Supplier data, such as:

• Master data and listing data (e.g. name, address, date of birth, information on transactions and contracts concluded).

• Technical data, (e.g. IP addresses, internal and external identifiers, access records).

4. Source of Personal Data

For the fulfilment of the purposes set out under Fig. 5, we may collect personal data from the following sources:

• Personal data given to us, e.g. when initiating business relationships, as part of the drawing up of contracts or the use of products and services.

• Personal data accrued as part of the use of products or services and passed to us by the technical infrastructure or through working processes.

• Personal data from third-party sources, e.g. from official bodies or sanctions lists of the UNO or the EU.

5. Purpose of the Processing

We may process personal data for the provision of our own services as well as for our own, or legally permissible purposes. In particular, the following must be considered here:

• The conclusion and fulfilment of contracts, the execution, processing and administration of products and services (e.g. invoices, investments).

• Monitoring and management of risks (e.g. investment profile, combating money laundering, limits, utilisation figures, market risks).

• Planning, business decisions (e.g. development or new, or evaluation of existing products and services).

• Marketing, communication, information on services offered and review of the same (e.g. advertising in print and online, customer / interested parties or other events, determination of future customer requirements).

• Fulfilment of statutory or regulatory information or reporting obligations to courts and official bodies, fulfilment of official instructions (e.g. reporting obligations to FINMA and foreign supervisory authorities, directives of public prosecutors in connection with money laundering and the financing of terrorism.

• Safeguarding our interests and securing our claims, e.g. in the case of claims against us, or claims by us against third parties.

6. Notification to Third Parties, Categories of Recipients

We pass customer data to third parties under the following circumstances:

• For outsourcing in accordance with Fig. 7 and for the purpose of comprehensive customer support to other service providers.

• To carry out instructions, i.e. when using products or services (e.g. to MAC Financial Group AG as part of compliance reviews).

• Because of statutory obligations, for reasons of statutory justification or official instructions, e.g. to courts, supervisory authorities, tax authorities or other third parties.

• Where necessary for the safeguarding of our legitimate interests, e.g. in the case of legal action threatened or initiated by customers against us, in public statements, to safeguard our claims against customers or third parties, for debt collection, etc.

• With the consent of the person affected to other third parties.

In particular when using certain products or services, under certain circumstances, personal data must also be made known to third parties in states where there is no appropriate level of date protection (e.g USA). If transfer to such a country is necessary, we take suitable precautions to continue to protect personal data appropriately.

7. Outsourcing of Business Segments or Services (Outsourcing)

The service providers that process personal data on our behalf for such purposes (“order processors”) are carefully selected. Wherever possible we appoint order processors that are based in Switzerland. The order processors are authorised under certain circumstances to have certain services fulfilled by third parties. The order processors may only process personal data in the way we ourselves do and are contractually bound to ensure the confidentiality and security of the data.

8. Automated Decision Making in Individual Cases, Including Profiling

We reserve the right if need be to carry out automated processing of customer data in the future, in particular to identify important personal characteristics of the customer, to predict developments and to produce customer profiles. This in particular for the checking and further development of offers and the optimisation of service provision. Henceforward, customer profiles can also lead to automated individual decisions if need be (e.g. automated acceptance and implementation of customer instructions in the CRM system). We ensure that a contact person is available if a person affected by an automated decision wishes to make comment and that such opportunity for comment is provided for by law.

9 Duration of Retention

The duration of retention of personal data depends on the purpose of the data processing in question and/or statutory storage obligations that can be five, ten or more years dependent upon the applicable legal basis.

10. Rights of Persons Affected

Anyone can request information from us as to whether personal data about him are being processed. There is a right to objection, limitation of the processing and, where applicable, a right to data portability. Erroneous data can be corrected. Deletion of the personal data can be requested in such cases, provided there are no statutory or regulatory provisions (e.g. statutory retention obligations for business-relevant data) or technical obstacles that prevent it. A consequence of the deletion of data may be that we may no longer be able to deliver certain services. Where applicable, there is the right of appeal to a competent authority. Where we process personal data based on consent, this consent can be withdrawn at any time. To assist us to answer your enquiries, we would ask for appropriately clear communication. We will check and answer your concerns within a reasonable period.

11. Contact

We are responsible for the processing of your personal data. Enquiries can be forwarded to the following address:

MAC Financial Group AG
Stegstrasse 26
8808 Pfäffikon
pricing@mac-fg.com