Privacy Notice - PG3 AG - Family Office

Privacy Policy

General Information

PG3 AG (“PG3”, “our”, “we”, or “us”) is a company registered in Switzerland, at Erlenweg 6, 6312 Steinhausen in Switzerland, with IDE number CHE-236.100.982, regulated as an Asset Manager by the Swiss Financial Markets Supervisory Authority (FINMA), and the controller in relation to the data processing under this Privacy Notice.
Our range of services and investment products is aimed at Swiss investors.
We process your personal data confidentially, in accordance with applicable law and this Privacy Notice, and the requirements of the Swiss Federal Act on Data Protection (“FADP”).
This Privacy Notice explains how we collect, store, and process personal data (data that directly or indirectly identifies you).

Categories of personal data

The nature of the personal data we collect depends on your relationship with PG3. We may process the following personal data (not an exhaustive list).

Contractual counterparties (potential or current clients, investment entities, lawyers, banks, financial intermediaries, and service providers, including individuals related to them):

basic personal data: name, job title, and business name;
identification data: personal identification data (name, surname, title, tax identification number) and information relating to investment entities;
identification data issued by public authorities and other registers: identity cards, passports, certificate of incorporation, articles of association, share registers;
contact information: email address, postal address, and telephone number;
financial data: identification number and bank account numbers, financial means / assets, financial transactions, beneficiary details;
other personal data disclosed in the context of the contract, or where required under contract, or applicable law;
information related to electronic interactions with us or our service providers (by email, phone or other forms of electronic communication); and
information you provide when you fill in forms, request or register to receive information from PG3, subject to your consent or any other requirements under applicable laws.

Interested persons communicating with PG3 and visitors (to our offices or website):

basic personal data: name, job title, and business name;
contact information: email address, postal address, and telephone number;
information to confirm your identity and for security and safety reasons when you visit our premises (checking your ID, CCTV video images in compliance with applicable laws);
authentication information such as login credentials, password or other authentication data;
online electronic information such as cookies information, IP address, engagement statistics, usage analytics, IT traffic and action traffic (including content accessed, shared, or downloaded), user login details, if you use our website. Please see our separate Cookies Notice;
information related to electronic interactions with us or our service providers (by email, phone or other forms of electronic communication); and
information you provide when you fill in forms, request or register to receive information from PG3, subject to your consent or any other requirements under applicable laws.

Job applicants:

basic personal data: name, job title, and business name;
contact information: email address, postal address, and telephone number;
other personal data disclosed in the context of your job application (CV, employment and education details), or where required under applicable law or regulations; and
information related to electronic interactions with us or our service providers (by email, phone or other forms of electronic communication).

Generally, sensitive personal data are not purposely processed by PG3, however in limited cases some sensitive personal data may be implied or obtained, for example, from information you provide in relation to meal/dietary preferences, or in support of disability of our visitors/guests. Any sensitive personal data we receive is processed in accordance with applicable law, including as applicable based on your consent or other lawful justification.

Origin of personal data

We collect personal data from the following sources:

personal data you disclose (e.g. when you communicate with us, apply for a job, visit our website or premises, or the course of a contractual arrangement with or related to you); and
personal data provided by third parties or from other sources including:
- when contractual counterparties provide your personal data, including in connection with investments or services related to you; and
- personal data obtained from public registers, authorities, sanction lists and other third parties or publicly available sources, in connection with the purposes of processing under this Privacy Notice.

Purposes of collection and processing of personal data

We process personal data only for specific purposes, primarily to provide our services in accordance with our contractual and legal obligations, and to:

communicate with you (including sending promotional or informational communications);
manage, administer, place and distribute financial products and investments, including all services related to these activities (including our website);
enter into, execute, and manage our contractual relationships, including verifying the identity of related individuals and entities, enter into pre-contractual discussions, and assess the services and suitability of potential contractual counterparties;
receive services in connection with our business, from our service providers and subcontractors;
ensure our compliance with applicable legal and regulatory obligations and industry standards (e.g., complying with our policies and legal requirements);
assess, develop, administer, support, and improve our services;
processing job applications;
take steps to protect the security, accuracy, and confidentiality of data and information held by us, and secure our IT systems, architecture, and networks including to detect and prevent cyber-security and similar threats;
manage our operations and business, including managing the operations, functions, resources, and the overall corporate governance of PG3;
enhance our knowledge of markets in general and analyse market data;
organize and hold online meetings, calls, and video conferences;
record audio or video of our interactions where required by applicable law and regulations (including financial regulations), or where permitted during our online events, meetings, and presentations;
secure our premises and property and ensure the safety of visitors and staff;
preserve our economic interests including by protecting ourselves against, detecting, and preventing fraud, misconduct, money laundering, bribery and corruption, theft of proprietary information, breach of confidence, other financial or business crimes, and other unlawful activity;
preserve our legal interests (e.g., managing mergers and acquisitions involving our company, enforcing or defending our legal rights); and
any other purposes imposed by applicable law and governmental authorities.

You are under no obligation to provide PG3 with personal data. However, if you fail to provide personal data when requested and where such personal data is necessary for us, for example, to provide you with services, you may be prevented from using the services. We will notify you if this is the case at the time.

Under the FADP, PG3’s lawful data processing does not require “a legal basis” (for example, as required by controllers subject to the EU GDPR). However, under the FADP we have additional or exceptional justifications for processing of certain personal data (for example sensitive personal data) and in certain circumstances, including that we or third parties may have an overriding interest for the processing in connection with the above purposes, or where necessary for compliance with legal and regulatory obligations as mentioned above.

Data transfer and categories of recipients

In the course of our activities and for the same purposes as those listed in this Privacy Notice, your personal data may be accessed by or transferred to the following categories of recipients to achieve such purposes: service providers (including subcontractors, and IT and cloud providers), professional advisors, auditors, and external lawyers, other counterparties including clients, business partners in connection with the provision of services, investment entities, banks, financial intermediaries, providers of due diligence, AML/KYC and similar checks.
Such recipients are obligated to protect the confidentiality and security of your personal data.
In limited circumstances, your personal data may be accessed by or transferred to law enforcement, regulatory bodies, or judicial authorities. This will occur only when legally required.
Your personal data may be processed by PG3 outside of Switzerland. For example, your personal data may be processed by a service provider in another country which may not have an appropriate level of data protection according to applicable privacy authorities.
We ensure that any transfer is made in accordance with applicable laws. For example, for transfers to a country deemed by a privacy authority to not offer the same level of protection, we ensure that the transfers are governed by appropriate safeguards, such as approved standard contractual clauses for such transfers.

How do we protect your personal data?

We implement technical and organizational measures to provide an appropriate level of security and confidentiality to your personal data. The purpose of these measures is to protect your personal data against accidental or unlawful destruction or alteration, accidental loss, and unauthorized disclosure or access.
While we take reasonable care to implement such measures, remember that the internet is inherently unsafe, and we cannot guarantee the security of your personal data when transmitted over the internet or email.

How long do we store your personal data?

We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected, to comply with legal or regulatory requirements (particularly retention obligations), or for the establishment or defense of legal claims.
Where it is not possible to remove your personal data from our systems (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

What are your rights and how can you exercise them?

You have rights in relation our processing of your personal data:

to obtain information about our collection and processing of your personal data;
to object to the processing or disclosure of your personal data;
to have your personal data rectified;
to have your personal data deleted;
to obtain a copy of your stored personal data in a standard electronic format, or to have it transferred to another entity; and
if your personal data is processed based on your consent, to withdraw your consent at any time.

These rights are subject to certain conditions or exceptions under law, including that in certain circumstances a data controller may refuse, restrict, or defer a request to exercise the above rights. To the extent permitted by applicable law, we reserve the right to charge an appropriate fee in connection with you exercising your rights.

You may exercise your rights at any time by using the details in the below Contact section.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal data requested, or to exercise any of your other rights. This is to ensure that personal data is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the personal data processed in relation to you, including, for example, the nature and location of your relationship with us.

Contact

If you have any questions about how your personal data is processed, this Privacy Notice or if you want to exercise the above rights, you may contact us by email at compliance@pg3.ch.

You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Changes to our Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. This Privacy Notice has an effective date as shown at the end of the document.

Version dated May 24, 2023