Data Protection

Data protection privacy policy
We, SunPartners SA are committed to respecting your privacy.

This Data Protection Privacy Policy applies to Clients and prospective Clients, service providers and potential service providers and all other business relationships of SunPartners SA. The Data Protection Privacy Notice explains how SunPartners SA as part of its business collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us in accordance with applicable data privacy laws and the General Data Protection Regulation (“GDPR”).

The term “Personal Data” as used in this Data Protection Privacy Notice means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute Personal Data, including name, date & country of birth, residential address, identification numbers, location data or online identifier. The kinds of Personal Data we may collect include your contact details (address, email, telephone number, etc.) and other information such as job title, professional experiences, financial information and investment profile. In most cases, we will collect the Personal Data directly from you but as well from other external sources, including any publicly available sources, information available through subscription services or information provided by other third parties. We will process your Personal Data if and to the extent applicable law provides us with lawful basis to do so and within the scope of our business lines.

  • Therefore, we will only process your Personal Data if either:
  • - You have not objected to us doing so (consent); or
  • - We need it to perform the mandate we have entered into with you (contract,); or
  • - We need it to comply with a legal or regulatory obligation (legal obligation);

We will use your Personal Data to deliver services to you and/or to work or act for you and only use them for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible and related with the original purpose. We may also use your Personal Data to inform you about it and our services or otherwise communicate with you. When using your Personal Data for the purposes and on the legal basis described above we reserve the right to disclose and share your Personal Data with other service providers (banks, credit card issuers, our fiduciary, IT Provider, etc.) that we work with. Please note that we may as well use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with public/governmental administrations, courts, competent authorities (e.g., financial supervisory, tax authorities, MROS, etc.) or financial market actors (e.g., custodian banks, brokers, exchanges and registers) or our auditors and legal advisors, and within the frame of judicial or regulatory proceedings, court orders or other legal process .

We may need to request specific information from you to help us confirm your identity and ensure your right of access Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data are not disclosed to any person who has no right to receive it. Therefore, it is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, it may preclude us from pursuing a Business Relationship with you and/or from rendering our services to you and/or we may not be able to accept an engagement from you, and/or to provide all or some of our services, to enter into a contract with you.

For the purposes described above, from time-to-time, we may have to transfer your Personal Data from the European Economic Area (EEA) to a third party outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. In such cases we respect the EU laws and other applicable laws and regulations on data protection.

  • You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
  • - Request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • - Request rectification and/or erasure of your Personal Data subject to applicable retention period;
  • - Request the restriction of processing of your Personal Data;
  • - Object to the processing of your Personal Data unless we have compelling legitimate grounds to do so.

You also have the right to make a complaint to SunPartners and in the absence of a satisfactory resolution of the matter contact at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues or, as the case may be, any other competent supervisory authority of an EU member state.

In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Data Protection Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights in manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

SunPartners SA reserves the right to update this Data Protection Privacy Notice at any time, and we will make an updated copy available on our website.

If you have any queries, questions, concerns or require any further information in relation to this Data Protection Privacy Notice or you wish to exercise any of your rights, please do not hesitate to contact us.

  • SunPartners SA
  • 7 rue des Battoirs
  • CH-1205 Geneva


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