Data Protection

Privacy policy – Information on data protection

ARTIS pertner AG takes the protection of your data very seriously. We treat your data confidentially and in accordance with the current data protection laws. This privacy statement describes how we process personal data and what rights you have with regard to the processing of your personal data.

Definitions

• «Activities» refers to all our activities, in particular asset management and the provision of reporting and consolidation services, as well as in the case of an application process or employment with ARTIS partner AG.
• «Data Protection Laws» includes, in particular, the Swiss Data Protection Act (DSG) and its ordinances, the EU General Data Protection Regulation (GDPR) and any other applicable data protection regulations.
• «Processing» or «Processing» has the meaning provided for in the respective applicable Data Protection Laws (under the DPA, this includes, in particular, obtaining, storing, retaining, using, modifying, disclosing, archiving, deleting or destroying data)
• «Personal Data» or «Personal Data» means any information relating to an identified or identifiable natural person or defined as such by the applicable Data Protection Laws.

Contact

Responsible for data processing is:

ARTIS partner AG
Bahnhofstrasse 29
6302 Zug
Switzerland

Phone: +41 41 711 62 62
E-mail: contact@artispartner.ch

If you have any questions or other concerns regarding the processing of your data, you can contact us at any time as indicated above.

What personal data we collect

In the course of our activities and to fulfill our contractual, regulatory and legal obligations, we collect the following personal data:

• Personal data and contact and identification data of clients and prospects (e.g. surname, first name, address, email address, telephone number, cell phone number, company name, date of birth, gender, marital status, nationality, passport, ID) and, in individual cases, particularly sensitive personal data, such as information relating to administrative and criminal convictions and offences (e.g. in the case of investigations under money laundering and sanctions regulations);
• Professional contact data of persons authorized to represent service providers and contractual partners (e.g., last name, first name, address, e-mail address, telephone number, cell phone number, function, absence information, gender, marital status);
• Private contact and identification data of employees and applicants (e.g. surname, first name, address, e-mail address, telephone number, cell phone number, date of birth, nationality, social security number, passport, ID);
• Personal and professional data of employees and applicants (e.g. data on spouses and children, marital status, photos of employees, CVs, diplomas, letters of reference, grades, evaluations, certificates, extracts from criminal records, extracts from debt collection registers, sanctions list queries, bank details).

Origin of personal data

We normally obtain personal data directly from you or your authorized representatives. Personal data is usually collected as follows:

• When you use our website;
• When you apply for a job at ARTIS partner AG and during your employment;
• On the occasion of meetings or communication with our employees or authorized representatives;
• On the occasion of professional contacts (e.g. events, presentations);
• Through publicly available sources (e.g., media, Internet, publicly available registers, sanctions addressee lists) and private compliance databases;
• From supervisory bodies and authorities (e.g. supervisory organization, FINMA, courts, public prosecutors‘ offices) in the course of their activities.

Purpose of processing

We will only use your personal data in the course of our activities and/or to fulfill our contractual, regulatory or legal obligations and to protect our own interests and those of our employees. Personal data will be used by us in particular for the following reasons:

• When communicating with you and in the course of our activities;
• To provide you with a continuous service;
• To comply with regulatory, legal or internal requirements.

Disclosure to third parties

Within ARTIS partner AG, those persons have access to your data who need it to fulfill our contractual, regulatory or legal obligations.

In order to provide you with the services you have requested and for the above purposes, your personal data may be disclosed to third parties.

We also take reasonable steps to ensure that our contracted third parties are bound by confidentiality and data protection obligations with respect to the protection of your personal data. These third parties may include:

• External service providers (e.g., accountants, IT service providers, compliance and risk management service providers);
• External consultants (e.g., attorneys and tax advisors).

To the extent necessary or due to our regulatory or legal obligations, your personal data may also be disclosed to other third parties (e.g. auditors, supervisory organization, FINMA, authorities and courts).

During the processing of personal data described above, in individual cases, personal data may be transferred to a country other than Switzerland, namely to countries in the European Economic Area («EEA») or the European Union («EU»), which have an adequate level of data protection set by the EU.

Data Security

We use reasonable efforts to protect your personal information from misuse, loss, alteration, unauthorized access, modification or disclosure. Access to and use of personal information is regulated internally to prevent misuse or unlawful disclosure of such information. We have limited access rights and use security procedures such as firewalls, anti-virus technology and password login to prevent unauthorized access.

Retention Period

We retain records containing personal information and store information only for as long as is necessary to provide you with continued service or to fulfill any of our contractual obligations, and longer if required by law. When personal data is no longer required by us, it will be destroyed or deleted to the extent that this is technically possible and legally permissible and can be ensured with a reasonable effort.

Right to information and access

It is possible to contact us by email or telephone to request access to your personal information. However, please note that we must verify your identity before we can grant you access to the information. There may be legal reasons that prevent us from granting access, particularly if doing so would compromise the privacy of others or breach confidentiality. If we deny access, we will notify you in writing of the reasons and give you an opportunity to appeal. There may be a cost for accessing this information, but there is no cost for making requests or corrections to your personal information.

Correction of personal data

We strive to keep your personal data accurate, complete, current and relevant. To this end, we ask that you notify us if your information changes. If you believe that the personal data we hold about you is inaccurate, incomplete or misleading, or if you wish it to be deleted, you can write to us at any time to request that it be amended or deleted. Our internal contact person for data protection issues will be happy to address your request.

Likewise, you have the right to restrict processing and may revoke your granted consent to processing at any time.

Use of our website

Because our website is connected to the Internet and the Internet is inherently insecure, we cannot guarantee that the transmission of any information or data you submit to us online will be secure. We also cannot guarantee that the information you submit will not be intercepted during transmission over the Internet. Therefore, any personal data or other information you transmit to us online is done so at your own risk.

Cookies

We may use «cookies» to better tailor our website to your needs (for example, we may use cookies to remember the personal preferences you provide) and to provide a more effective way to access various components of our website. If you choose to disable cookies, the functionality of our website may be affected. Cookies are small text files that are stored in the memory and on the hard drive of your computer, mobile device or tablet when you visit certain websites. They are used to enable websites to function or to provide information to the owners of a website or other third parties that receive data from that website. This information may relate to you, your preferences or your device and is mainly used to make the website work the way you expect it to. The information does not usually identify you directly, but it may provide you with a more personalized web experience.

Cookies help us provide customized services and information. We use cookies to generally tell us how and when pages on our websites are visited, what our users‘ technology preferences are, and whether our website is functioning properly. Depending on their purpose, some cookies only work for the duration of a single browser session, while others have a longer lifespan to ensure that they fulfill their longer-term purposes (as explained in more detail below). Please note that as long as a cookie‘s active life may be, you can delete cookies (and thus stop any further data collection), as described in more detail below.

If you are using a password-protected website, the website may use cookies or other technologies to authenticate you, store and recognize your configuration and user attributes, facilitate your navigation of the website, and customize its content so that the information provided matches that which is likely to be of greater interest to you.

In general, we use cookies on our website for the following purposes:

• Analytical purposes: analytical cookies allow us to recognize, measure and track visitors to the website. This helps us to improve and develop the way the website works, for example, by determining whether visitors to the website can easily find information, or by identifying aspects of the website that are of greatest interest to them.
• User Preferences: Some of the cookies on the Website are activated when visitors to our Websites make choices about their use of the Website. Our website then remembers the preferences of that user. This allows us to tailor aspects of the website to the individual user.
• General Terms of Use: We use cookies on the Website to record whether a Website visitor has seen this Privacy Policy or to provide consent, such as agreeing to certain terms of use on our Website. This helps improve the usability of the website – for example, it avoids repeatedly asking a user to agree to the same terms.
• Session management: the software that runs the website uses cookies for technical purposes that are necessary for the internal functioning of our servers. For example, we use cookies to distribute requests among multiple servers, authenticate users and determine which website features they can access, verify the origin of requests, track information about a user‘s session, and determine which options or pages need to be displayed in order for the website to function.
• Functional Purpose: Functional purpose cookies store information needed by our applications to process and operate. For example, if transactions or requests within an application involve multiple workflow steps, cookies are used to temporarily store the information from each stage to facilitate completion of the entire transaction or request.
• Advertising: Advertising cookies allow us (or third parties) to monitor the behavior of users of our website. This information is used to ensure that products and services highlighted to these individuals are targeted and relevant (e.g., through advertisements on our website or advertisements on third-party websites based on your experience with our website) or to monitor the effectiveness of these digital marketing campaigns. We also monitor whether ads displayed on our website are of interest to users and store this information to ensure that the ads seen by users of our website over time are appropriate.

We may share details about the general use of our website with third parties (e.g. to show business partners usage patterns). Information we share for this purpose does not include personally identifiable information that can identify you.

You can set your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Every browser is different, so please check your browser‘s «Help» menu to learn how to change your cookie settings. You can refuse our cookies at any time if your browser allows it, although in this case you may not be able to use certain features of our website.

On the website designed to be viewed with Adobe Flash Player, we may include content such as animations, videos, and tools. Local Flash memory (often referred to as «Flash cookies») may be used to enhance your user experience. Flash memory is stored on your device in a similar way to standard cookies, but is managed directly by your Flash software. If you wish to disable or delete information stored locally in Flash, please refer to your Flash software documentation at www.adobe.com. Please note that if you disable Flash cookies, some website features may not work.

When you visit our website, you may receive cookies that are set by third parties. The type of cookies and related data processing by these third parties is governed by the third party‘s privacy policy. We have no control over the setting of these third-party cookies. You may wish to browse the website of such third party provider for more information on the use of cookies and their management.

Complaints

If you have concerns about our protection of your personal information, please contact our internal privacy contact using the contact information above and provide details about the incident so that we can investigate.

We ask that you submit complaints about suspected data breaches in writing so that we may continue to contact you in connection with your complaint.

If you have contacted us and believe that we have not handled your matter properly, you may contact the relevant data protection authority, which in Switzerland is:

Federal Data Protection and Information Commissioner

https://www.edoeb.admin.ch/edoeb/de/home.html

Changes to this privacy policy

We reserve the right to change this Privacy Policy if we deem it necessary at a later date or if required by data protection laws. Any changes will be posted on the Site immediately and you will be deemed to have accepted any subsequent changes to this Privacy Policy when you first use the Site.

September 2023