1. Name and address of the controller
The controller within the meaning of European General Data Protection Regulation and Swiss Data Protection Act is:
QCAM Currency Asset Management AG
Phone.: +41 55 417 00 50
2. Name and address of the data protection officer
Data protection officer of the controller is:
Integritas Compliance AG
Phone.: +41 31 372 21 00
3. The Data collected about you
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
The following data may be collected:
– Name and uniform resource locater (URL) of the file that is accessed
– Date and time of the access
– Geographical location of the access
– Webpages where from the access took place (referrer URL)
– The name of the browser used and if applicable the operating system of your local computer as well as the name of your access provider
The above mentioned data is collected for statistical or demographic purposes (Aggregated Data). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage and number of users accessing our website and specific website features. Pursuant to point (f) of Article 6 (1) GDPR, the legal basis of our data processing, is our legitimate interest in keeping our website updated and relevant for the administration and development of our business. The collected data will not be used to draw conclusions concerning any individuals.
Furthermore we may use analytical tools if you visit our website. Please refer to paragraph 6 of this policy for further information.
On our website you have the possibility to subscribe to a newsletter for free. If you subscribe to this newsletter the data entered into the online subscription form will be submitted to us.
The following data will be collected:
– Surname and Name
– E-Mail address
– Telephone number
– Business address
– Date and time of the registration
We are not passing on any personal data in connection with the distribution of our newsletter. The sole purpose of the usage of data is the distribution of the newsletter.
The legal basis for the processing of personal data after the subscription to our newsletter is consent by the user, pursuant to point (a) of Article 6 (1) GDPR.
The collection of the mentioned data serves the purpose of delivering the newsletter and to minimize the risk of a misuse of the services used or of the E-Mail addresses used.
Subscription to the newsletter may be terminated at any time by the users. For this purpose, there is a corresponding link in every newsletter (E-mail).
These are small text files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not harm your device, do not contain viruses, trojans or other malicious software.
The legal basis for the processing of personal data using cookies is our legitimate interests to promote our business and inform our marketing strategy pursuant to point (f) of Article 6 (1) GDPR.
Most browsers accept cookies automatically. However, you can configure your browser in a manner that no cookies are stored on your computer or a note always appears before a new cookie is created. However, disabling cookies completely may limit the functionality of our website.
6. Google Analytics
This website uses Google Analytics, a web analysis service of Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA).
However, if IP anonymization is activated on this website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and Internet use.
Our legitimate interest in the data processing also lies in these purposes. The legal basis for the use of Google Analytics is point (f) of Article 6 (1) GDPR.
The data sent by us and linked to cookies, user-identifiers (e.g. User-IDs) or advertising-identifiers is automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.
Further information on data use by Google, possible settings and objections can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads).
7. Duration of the data storage
Unless specifically stated, we store personal information only for as long as necessary to fulfill the purposes for which it was intended.
In some cases, Swiss law envisages the retention of personal data. In these cases, the personal data will be stored by us only for these legal purposes, but not otherwise processed and deleted again after expiration of the statutory retention period.
8. Transfer and transmission of data abroad
Basically, we only use your personal data within our company.
If and insofar as we engage third parties with the performance of contracts and services (e.g. service providers, IT providers), the personal data will only be provided to these third parties to the extent that is required to perform the corresponding service.
In the event that we outsource certain parts of the data processing, we contractually oblige processors to use personal data only in accordance with the requirements of the European General Data Protection Regulation and the Swiss Data Protection Act and to safeguard the protection of the rights of the affected person.
A data transfer to places or persons outside the EU or Switzerland does not take place and is not planned. The only exception to this is as described in paragraph t 6 above.
9. Right by the data subject
Where we process your personal data you have the following rights:
9.1. Right of access
Pursuant to Article 15 GDPR, you have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed. In particular you have the right of access about the purpose of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data has been or will be disclosed, the envisaged period of storage, the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing, the right to lodge a complaint with a supervisory authority, the source of the personal data, if it is not collected from you and the existence of automated decision-making, including profiling, and if necessary meaningful information about the details.
9.2. Right to rectification
Pursuant to Article 16 GDPR, you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. You as data subject have the right to have your incomplete personal data completed.
9.3. Right of erasure
Pursuant to Article 17 GDPR, you have the right to obtain from us the erasure of your personal data. This right does not apply to the extent that processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims.
9.4. Right to restriction of processing
Pursuant to Article 18 GDPR, you have the right to the restriction of processing your personal data, if the accuracy of the personal data is contested by you or the processing is unlawful and you oppose the erasure of your personal data and request the restriction of your use instead or we no longer need the personal data for the purpose of the processing, but the data is required by you for the establishment, exercise or defence of legal claims or you have objected to processing pursuant to Article 21 (1) GDPR.
9.5. Right to data portability
Pursuant to Article 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
9.6. Right to object
Pursuant to Article 21 GDPR, you have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6 (1) GDPR.
9.7. Right of withdrawal of consent
Pursuant to Article 7 GDPR, you have the right to withdraw your consent any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
9.8. Right to lodge a complaint with a supervisory authority
Pursuant to Article 77 GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if the you consider that the processing of personal data relating to you infringe GDPR.
10. Data security
We take appropriate technical and organizational security measures to protect your personal data against unauthorized access and abuse pursuant to Article 32 GDPR. Our security measures are continuously monitored and improved (if necessary) in line with technological developments.