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Privacy policy

1. General


This privacy policy provides information on how G7NESIS processes personal data. Personal data" means all information relating to an identified or identifiable natural or legal person. Processing" means any handling of personal data, regardless of the means and procedures used, in particular the acquisition, storage, use, modification, disclosure, archiving, deletion or destruction of personal data.

For certain data processing, e.g. in the context of concluding contracts with G7NESIS or in connection with G7NESIS websites, there are further regulations (such as terms of use). These are available in the corresponding contracts or on the corresponding websites. In addition, the General Terms and Conditions (GTC) contain general information on data protection, in particular in connection with the performance of contracts in banking.


2. Data Protection


G7NESIS is committed to protecting personal data and privacy in accordance with the applicable laws, in particular bank client confidentiality and data protection law. To this end, G7NESIS takes various technical and organisational security measures (e.g. access restrictions, firewalls, personalised passwords as well as encryption and authentication technologies, training of employees, etc.).


3. Categories of Personal Data


G7NESIS processes the following categories of personal data. We always process as little personal data as possible. Data of the partners of G7NESIS, such as:

  • Master and inventory data (e.g. name, address, nationality, date of birth, professional background)
  • Technical data (e.g. business numbers, IP addresses, internal and external identifiers, records of access).
  • Marketing data (e.g. preferences, needs)

Bank customer data, such as:

  • Master and inventory data (e.g. name, address, nationality, date of birth, tax number, information regarding account, custody account, concluded transactions and contracts, information on third parties affected by data processing, such as spouses, authorised representatives and advisors).
  • Transaction or order and risk management data (e.g. details of beneficiaries of transfers, beneficiary bank, amount of transfers, risk and investment profile, details of investment products).
  • Technical data (e.g. business numbers, IP addresses, internal and external identifiers, records of access).
  • Marketing data (e.g. preferences, needs)

Visitor and prospect data (e.g. visitors to G7NESIS or G7NESIS websites), such as:

  • Master and inventory data (e.g. name, address, date of birth)
  • Technical data (e.g. IP addresses, internal and external identifiers, access records)
  • Marketing data (e.g. preferences, needs)

Supplier data, such as:

  • Master data and inventory data (e.g. name, address, date of birth, information on concluded transactions and contracts)
  • Technical data (e.g. IP addresses, internal and external identifiers, access records)


4. Origin of Personal Data


G7NESIS may collect personal data from the following sources in order to fulfil the purposes set out in section 5:

  • Personal data provided to G7NESIS, e.g. when opening a business relationship, in the context of the execution of contracts, the use of products and services or on websites.
  • Personal data that accrue in the context of the use of products or services and are transmitted to G7NESIS through the technical infrastructure or through processes based on the division of labour, e.g. in payment transactions, securities trading, eBanking, websites or on the occasion of cooperation with other financial or IT service providers, marketplaces and stock exchanges.
  • Personal data from third-party sources, e.g. authorities or sanctions lists of the UN and the EU.


5. Purposes of Processing 


G7NESIS may process personal data for the provision of its own services and for its own purposes or those provided for by law. In particular, the following should be considered:

  • Conclusion and fulfilment of contracts, execution, processing and administration of products and services (e.g. accounting, tax returns, commercial register entries and mutations, invoices, account openings, payments, financing, financial planning, investments, pension provision, insurance, consolidation).
  • Monitoring and controlling risks (e.g. investment profiles, anti-money laundering, limits, utilisation figures, market, credit or operational risks).
  • Statistics, planning, business decisions (e.g. development of new or assessment of existing services, products, processes, technologies).
  • Marketing, communicating, informing about and reviewing the service offering (e.g. print and online advertising, customer, prospect or other occasions, identifying future customer needs, assessing a customer, market or product potential).
  • Fulfilment of statutory or regulatory obligations to provide information or to report to courts and authorities, fulfilment of official orders (e.g. reporting duties
  • vis-à-vis FINMA and foreign supervisory authorities, automatic exchange of information with foreign tax authorities, orders issued by public prosecutors in connection with money laundering and terrorist financing).
  • Safeguarding the interests and securing the claims of G7NESIS, e.g. in the event of claims against G7NESIS or claims of G7NESIS against third parties.


6. Disclosure to Third Parties, Categories of Recipients 


G7NESIS discloses customer data to the following third parties in the following cases:

  • For outsourcing in accordance with Clause 7 and for the purpose of comprehensive customer care to other service providers.
  • For order execution, i.e. when products or services are used, e.g. to service providers, stock exchanges or marketplaces, reports of stock exchange transactions to (international) trade repositories.
  • Due to legal obligations, legal justification or official orders, e.g. to courts, supervisory authorities, tax authorities or other third parties.
  • To the extent necessary to protect the legitimate interests of G7NESIS, e.g. in the event of legal action threatened or initiated by customers against G7NESIS, in the event of public statements, to secure claims of G7NESIS against customers or third parties, in the event of collection of claims of G7NESIS, etc., G7NESIS shall not be liable for any damages arising from such actions.
  • With the consent of the data subjects to other third parties.


Particularly when using certain products or services of G7NESIS, personal data may also have to be disclosed to third parties in countries where there is no adequate level of data protection (e.g. USA). If a transfer to such a country is necessary, G7NESIS will, if possible, take appropriate precautions to continue to protect personal data adequately.


7. Outsourcing of Business Areas or Services (outsourcing)


G7NESIS outsources certain business areas and services in whole or in part to third parties (such as
Account management including payment transactions, custody account management, preparation of consolidation reports, fund limit checks, definition of fund limit rules, opening of securities, updating of restriction rules, IT systems, etc.). The service providers who process personal data on behalf of G7NESIS for this purpose (so-called order processors) are carefully selected. Whenever possible, G7NESIS uses order processors domiciled in Switzerland. The order processors may be entitled to have certain services (e.g. electronic data processing, securities settlement, etc.) provided by third parties.
The commissioned processors may only process personal data received in the same way as G7NESIS itself and are contractually obliged to guarantee confidentiality, bank client secrecy and the security of the data.

Outsourcing by G7NESIS are carried out in accordance with the Circular Outsourcing Banks of the Swiss Financial Market Supervisory Authority (FINMA) as amended from time to time.


8. Automated Decisions in Individual Cases Including Profiling


G7NESIS reserves the right to process customer data automatically in the future, if necessary, in particular in order to identify essential personal characteristics of the customer, to predict developments and to create customer profiles. This serves in particular to review and further develop offers and to optimise the provision of services.

In future, customer profiles may also lead to automated individual decisions (e.g. automated acceptance and execution of customer orders in e-banking). G7NESIS ensures that a contact person is available if a data subject wishes to comment on an automated individual decision and such a possibility to comment is provided for by law.


9. Use of websites and cookie policy


When a person visits G7NESIS websites, the web server automatically records details of their visit (e.g. the website from which the visit is made, the IP address of the person visiting the site, the date of the visit, etc.).
of the visitor, the content of the website that is accessed, including the date and duration of the visit). Such tracking data serve to optimise the websites and provide information on how the visitor informs himself about and uses the products, services and offers of the. As a rule, however, they do not 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. by filling in a registration form or message field for newsletters, etc., G7NESIS may use this data in addition to the purposes stated under point 5, in particular for the following:

  • for customer and user administration;
  • to inform the visitor about services and products;
  • for marketing purposes (e.g. sending newsletters);
  • for the technical "hosting" and further development of the G7NESIS websites.

When visiting websites, the visitor's data is transported via the internet, i.e. an open network accessible to everyone. Data transmitted via electronic media (including e-mail) cannot be effectively protected against access by third parties. This entails the risks that the data is disclosed or its content is changed, that the identity of the sender (e.g. e-mail) as well as the content of the message is faked or manipulated in some other way by unauthorised persons, that viruses are released, that technical transmission errors, delays or interruptions occur, that data is transferred uncontrolled abroad, where possibly lower data protection requirements apply than in Switzerland, etc. The risk is that the sender's identity is faked or manipulated in some other way by unauthorised persons.

By using the websites, visitors confirm their express consent to this privacy policy and the risks mentioned.

In addition, by using the G7NESIS website, a visitor agrees to the use of cookies. Cookies are small files that are stored on the computer

of the visitor are stored 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 time of visits to individual website areas and help to design tailored, useful and user-friendly websites. The visitor can decide against the use of cookies at any time by deleting the cookies set by the G7NESIS website. Deletion is possible via the settings in the visitor's internet browser.

Occasionally, Cottonfielf uses third party components (such as plug-ins) to enhance the user experience and online advertising campaigns. These components may also use cookies for similar purposes. Neither these third parties nor G7NESIS have access to the data collected by the other via cookies. Finally, G7NESIS also uses cookies as part of G7NESIS' advertising on third party websites with which G7NESIS has marketing relationships. Where third parties collect anonymised information about the use of G7NESISf websites and other websites, G7NESIS may use this anonymised data to improve the effectiveness of its advertising.

This title of this privacy policy only applies to data that G7NESIS receives as a result of the use of G7NESIS websites. It is not applicable to third party websites, even if the visitor reaches them via links on a G7NESIS website. G7NESIS has no influence on the content and data protection practices of third party websites and cannot accept any responsibility for them.


10. Duration of Storage


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


11. Rights of the Data Subjects


Anyone can request information from G7NESIS as to whether personal data about him or her are processed. There is a right of objection, restriction of processing and, where applicable, the right to data portability. Incorrect data can be corrected. Furthermore, the deletion of personal data can be requested, unless legal or regulatory provisions (e.g. legal retention obligations of business-relevant data) or technical hurdles prevent this. The deletion of data may result in G7NESIS no longer being able to provide certain services. In addition, where applicable, there is a right of appeal to a competent authority. Where G7NESIS processes personal data on the basis of consent, this consent may be revoked at any time.

In order to assist G7NESIS in responding to your request, please provide us with an appropriate, understandable communication. We will review and respond to the concerns within a reasonable period of time.


12. Contact


G7NESIS is responsible for processing your personal data. 
The contact details of G7NESIS are as follows:

G7NESIS FAMILY OFFICE AG
G7NESIS ASSET MANAGEMENT AG

+41 (0) 44 442 07 77
hello@G7NESIS.com

Klausstrasse 19
8008 Zurich
Switzerland