Purpose and scope of this statement

MVC & Partners SA places the utmost importance on the rights of its clients by understanding how important these are to them. MVC & Partners Ltd. as the data controller, complying with the requirements of the Federal Data Protection Act (DPA), provides information regarding the collection and use of personal data of its clients.

MVC & Partners Ltd. is a company headquartered and operating in Switzerland, subject to the Federal Data Protection Act (DPA). It does not offer and does not actively offer its services outside Switzerland and does not monitor its clients or other individuals within the borders of the European Union. The EU Data Protection Regulation 2016/679 (RGPD/GDPR) is therefore not applicable to MVC & Partners SA.

Definitions

In this document we mean:

Personal data: any information concerning an identified or identifiable natural person;

Data subject: the natural person whose personal data are being processed;

Processing means any operation concerning personal data, regardless of the means and procedures used, namely the collection, recording, storage, use, modification, communication, storage, deletion and destruction of data;

Communication: the transmission of personal data or making them accessible;

Data controller: the one who, individually or together with others, determines the purpose and means of processing;

Processor: one who processes personal data on behalf of the data controller

For what purposes and with respect to what legal bases are your data processed?

Your personal data are processed by MVC & Partners SA, as part of its normal business operations, in order to provide you with the requested service, fulfill contractual obligations, comply with legal obligations, respond to requests or enforcement actions, protect its own rights and interests or those of other clients or third parties, as well as to detect any malicious or fraudulent activities.

Data are processed to provide the services provided by MVC & Partners SA in the context of the execution of contracts with its clients or pre-contractual measures.

In addition, MVC & Partners AG is subject to legal obligations and regulatory requirements, e.g., under the Federal Law on Financial Institutions (FFI), the Federal Law on Financial Services (FFS), the Federal Law on Combating Money Laundering and Terrorist Financing (AMLA), FINMA ordinances and circulars, tax laws, and supervisory authorities (e.g., FINMA), and is required to process personal data in compliance with these obligations.

The purposes of data processing include identifying and managing financial, regulatory and reputational risks, preventing and detecting fraud and money laundering, and fulfilling control and reporting obligations under tax laws.

What personal data is processed by MVC & Partners SA?

To achieve the purposes set forth in the preceding paragraph, MVC & Partners SA processes personal data obtained from its clients as part of its business relationship and, where necessary, personal data obtainable from freely accessible public sources (e.g., business and association registries, press articles, Internet sites) and from specialized third-party databases.

Where can your data be transferred to?

MVC & Partners Ltd. processes your personal data in Switzerland and entrusts the data exclusively to processing partners based in Switzerland who carry out data processing in Switzerland.

Exceptionally, data could be transmitted to foreign states for which the Federal Council has found that legislation is in place to ensure adequate data protection.

Why are you obliged to provide us with your data?

MVC & Partners SA only requires data that are essential for the establishment and maintenance of the business relationship. Without such data, the company generally cannot be able to enter into or execute a contract for the provision of its services.

The personal data requested are necessary for the purpose of initiating, executing a business relationship and fulfilling related contractual obligations, as well as fulfilling legal obligations.

How long do we use and keep your data?

MVC & Partners SA retains your personal data only for as long as necessary to comply with its contractual and legal obligations, as well as to ensure its rights and interests, in accordance with the principles of proportionality and necessity set forth in the data protection legislation. When these needs cease, MVC & Partners SA will delete your data.

Who can learn about your data?

Within MVC & Partners SA, each organizational unit and each external data processor will have access to your personal data, which it needs in order to comply with its contractual and legal obligations, as well as to protect its own legitimate interests.

Your personal data may also be disclosed to third parties such as lenders acting on your behalf or agencies providing rating services on client financial, regulatory and reputational risk, and to financial sector regulators (e.g., FINMA), to the judicial authorities in case of need or requests received from them, and to third parties providing audit, consulting, legal, accounting or insurance services.

In relation to the purposes described above, the processing of personal data is carried out by manual or technological means with logic strictly related to the purposes just mentioned, organized and structured to ensure the security and confidentiality of data. MVC & Partners SA, takes technical and organizational measures to ensure the confidentiality, integrity and availability of personal data.

What are your rights?

Every data subject has the right of access to his or her data and where permitted by law, the right to rectification, the right to erasure, the right to restriction of processing, the right to object to processing, and, where applicable, the right to data portability.

Who can you contact for more information?

Should you wish to ask questions about data processing or submit requests to exercise your rights, you may contact us by writing to the e-mail address:
compliance@mvcpartners.swiss
.

Data controller

MVC & PARTNERS SA

Corso San Gottardo 49
P.O. Box 1744
CH-6830 Chiasso
T: +41 (0) 91 985 98 00
F: +41 (0) 91 985 98 01

This document may be changed at any time without notice.