GDPR policy

Our Policy

NOVALISfinance Personal Data Policy

What data does NF use and for what purpose?

The personal data NF collects and processes are related to the business relationship established between the Client and NF. Most of the personal data comes from the Client, some from the Bank where the assets managed by NF are located (hereafter “the Bank”).

Despite being a Swiss company based in Montreux, NF processes personal data of Clients in accordance with the provisions of the European GDPR, the majority of its Clients being domiciled in countries members of the European Union.

These personal data may include:

1) Information given by the Client

• Contact details such as name, first name, postal address and address of residence, date and place of birth, nationality;

• Information given to NF by filling forms requested for the opening of a business relationship with NF;

• Information given to the Bank by filling forms requested for the opening of a business relationship with the Bank, copies of which are filed at NF for regulatory reasons when NF is entitled by contract with the Client to manage the assets located at the Bank;

• Information concerning the Client’s identity as given by passport or ID card which include a photograph and requested by law for identification purposes.

2) Information gathered or generated by NF and the Bank and shared

• Client relationship data, securities and payment transactions gathered through the services rendered and products held;

• Information about the Client’s financial situation such as personal wealth and income;

• Information collected in order to comply with anti-money laundering regulations;

• Information collected for risk management purposes such as Client due diligence, Client risk profile, information to assess Client’s understanding of investment policies and products, tax data;

• Information produced through all conversations held between the Client and NF such as meetings, phone calls, exchange of letters and mails, in order to keep track of all conversations with the Client.

Which third parties does or might NF transfer personal data to and on what purpose?

NF does not use personal data for marketing purposes and campaigns. NF does not sell personal data to third parties. It may only transfer personal data in the following cases:

• To the Bank holding the Client’s assets for the fulfilment of contractual obligations such as performing banking transactions and financial services on behalf of the Client and in accordance with the management agreement signed between NF and the Client;

• To duly registered and authorised auditing companies in Switzerland for audit purposes requested by law such as compliance with anti-money laundering regulations, company accounting;

• To legal advisers in case of asserting claims and mounting a defence in the event of legal disputes;

• To Swiss regulatory and legal authorities in order to prevent or solve crime as required by law.

Who receives and processes personal data within NF?

All employees of NF in accordance to their assigned tasks, as well as members of the Board for reporting purposes.

How long will personal data be stored?

NF will process and store personal data of Clients as long as it is necessary in order to fulfil NF’s regulatory and statutory obligations and to comply with records retention periods under Swiss commercial and tax laws.

If the personal data are no longer required by these obligations, they are regularly deleted.

What are your data protection rights?

You may access to your personal data, rectify it, erase it, restrict its processing or object it and this at any time by contacting your personal asset manager or NF data protection officer, at NOVALISfinance SA, rue de l’Eglise-Catholique 1, CH-1820 Montreux, phone +41 21 963 75 00.

How is personal data kept secure?

NF has taken internal technical and organisational measures to keep personal data of Clients safe and secure. NF requires its employees, board members and any third parties who carry on work on its behalf as mentioned above to protect personal data and take all appropriate measures for a safe keeping, use and transfer of personal data.

Amendments to this Privacy Policy

Our Personal Data Policy has been updated 2018-05-25. We reserve the right to amend or supplement this Policy at any time at our discretion. Please consult this Personal Data Policy regularly.

Montreux, 2018-06-15