Your privacy is very important to us. This notice (“Privacy Notice”) is provided by SEOM Management AG (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

How we collect information about you

We may collect personal data about you through:

• information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
• information that we obtain in relation to any transactions between you and us; or
• the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

Why we collect information about you

We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

What are the consequences of failing to provide your personal information?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting.

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

The types of personal data we may collect and use

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials.

Do we use automated decision-making processes?

No.

Do we share your personal information with third parties?

We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

• our affiliates or other entities that are part of our group or with our clients;
• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
• our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
• service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
• credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
• any person, as directed by you; or
• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

For how long do we keep your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

What are your rights?

You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

• to request access to your information;
• to request rectification of inaccurate or incomplete information;
• to request erasure of your information (a “right to be forgotten”);
• to restrict the processing of your information in certain circumstances;
• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing     activities);
• where relevant, to request the portability of your information;
• where you have given consent to the processing of your data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority.

How to contact us

If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Compliance Officer by compliance@spectrum-eo.com or by writing to SEO Management AG Zurcherstrasse 156, 8645 Rapperswil-Jona, Switzerland.

Complaining to FDPIC

You have the right to complain to the Federal Data Protection and Information Commissioner (FDPIC) . Further information is available from the FDPIC’s website.

Cookies and third party technology

Use of Cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

If you leave a comment on our website, you may opt-in to saving your name, email address and website in cookies. This is a convenience feature so that when you write another comment, you don’t have to retype all those data. These cookies are stored for one year. If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies.

This cookie contains no personal data and is discarded if you close your browser.

When you log in, we will set some cookies to remember your login information and viewing options. Login cookies expire after two days and display options cookies after one year. If you select „Keep me signed in“ (Angemeldet bleiben) when you log in, your login will be maintained for two weeks. Logging out of your account will delete the login cookies.

Use of script libraries (Google Webfonts)

In order to display our content correctly and graphically appealing across browsers, we use „Google Web Fonts“ from Google LLC 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”) to display fonts. Google’s applicable privacy policy can be found here: https://www.google.com/policies/privacy/

Use of Google Maps

On this website we use Google Maps, operated by Google. This enables us to show you interactive maps directly on the website and enables you to conveniently use Google’s map function.

Use of embedded content from other websites

Articles on this website may contain embedded content (e.g. videos, images, articles etc.). Embedded content from other websites behaves exactly as if the visitor had visited the other website.

These websites may collect information about you, use cookies, embed additional third party tracking services, and record your interaction with that embedded content, including your interaction with the embedded content if you have an account and are logged in to this website.

Use of Social Plugins

Social media plugins are used on our websites. Information, which may also include personal data, may be sent to the service operator via these plugins and may be used by them. We prevent the unconscious and unwanted collection and transmission of data to the service provider with a 2-click solution. In order to activate a desired social plugin, it must first be activated by clicking on the corresponding switch. The collection of information and its transmission to the service provider is only triggered by this activation of the plugin. We do not collect any personal data ourselves using the social plugins or their use.

We have no influence on which data an activated plugin records and how these are used by the provider. Currently, it must be assumed that a direct connection to the provider’s services will be established and at least the IP address and device-related information will be recorded and used. There is also the possibility that the service providers will try to save cookies on the computer used. Which specific data is recorded and how it is used can be found in the data protection information of the respective service provider. If you are logged in to Facebook at the same time, Facebook can identify you as a visitor to a specific page.

SSL encryption

In order to protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g. SSL) over HTTPS.