Privacy Policy

Introduction

Asset Street SA ("Asset Street", "we", "us", or "our") is committed to protecting the privacy and personal data of its clients, website visitors, and business contacts. This Privacy Policy explains how we collect, use, store, share, and protect personal data in accordance with the Swiss Federal Act on Data Protection (nFADP), which entered into force on 1 September 2023, and other applicable data protection laws.

Please read this policy carefully. By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

Who We Are

The data controller responsible for your personal data is:

Personal Data We Collect

Depending on your relationship with us, we may collect and process the following categories of personal data:

Identification & Contact Data

• Full name, date of birth, nationality, country of residence
• Postal address, email address, telephone number
• Passport, identity card, or other official identification documents

Financial & Investment Data

• Financial situation, assets, liabilities, income, and source of wealth
• Investment objectives, risk tolerance, and investment experience
• Portfolio holdings, transaction history, and account information
• Tax identification numbers and residency information

KYC & Compliance Data

• Due diligence documentation required under the Anti-Money Laundering Act (AMLA)
• Beneficial ownership information
• Politically Exposed Person (PEP) and sanctions screening results

Website & Technical Data

• IP address, browser type and version, operating system
• Pages visited, time spent on site, referring URLs
• Cookie identifiers (see our Cookie Policy for further details)

Communication Data

• Emails, letters, and records of telephone conversations
• Enquiry forms and contact requests submitted via our website

How We Use Your Personal Data

We process your personal data only for specified, explicit, and legitimate purposes. The primary purposes and legal bases for our processing are:

• Provision of financial services: To fulfil our contractual obligations to you as a client, including portfolio management, investment advisory, and related services.
• Regulatory compliance: To comply with our obligations under FinSA, FinIA, AMLA, and other applicable Swiss financial market laws, including client identification, KYC, and reporting obligations.
• Legitimate interests: To manage and develop our business, maintain records, prevent fraud, and protect the security of our systems and client data.
• Consent: For marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.
• Legal obligations: Where we are required by law or regulatory authority to process or disclose your data.

Sharing Your Personal Data

We do not sell your personal data. We may share your data with the following categories of recipients, only to the extent necessary for the purposes described in this policy:

• Custodian banks and brokers: Your data is shared with your chosen custody bank or brokerage partner for account opening, transaction processing, and regulatory compliance purposes.
• Regulatory authorities: FINMA, SO-FIT, MROS (Money Laundering Reporting Office Switzerland), and other competent authorities as required by law.
• Professional advisors: Legal counsel, auditors, and compliance consultants engaged by Asset Street SA, subject to confidentiality obligations.
• IT and service providers: Third-party providers of technology, cloud storage, and business services, subject to data processing agreements.
• Ombudsman: Swiss Arbitration Centre (Ombuds-FIN), in the event of a client complaint.

Where personal data is transferred outside of Switzerland, we ensure appropriate safeguards are in place in accordance with Art. 16 nFADP.

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal and regulatory retention requirements:

• Client records and KYC documentation: Minimum 10 years following the end of the business relationship, as required by AMLA Art. 7.
• Transaction and accounting records: 10 years, as required by Swiss accounting law.
• Correspondence: 10 years from the date of the last communication relating to a matter.
• Website and technical data: Up to 13 months, in accordance with standard analytics retention periods.
• Enquiry and contact data (non-clients): Up to 2 years from the last contact.

Your Rights

Under the nFADP, you have the following rights in relation to your personal data:

• Right of access (Art. 25 nFADP): You have the right to request a copy of the personal data we hold about you.
• Right to rectification: You have the right to request that inaccurate or incomplete data be corrected.
• Right to erasure: You may request deletion of your personal data, subject to applicable legal retention requirements.
• Right to restriction of processing: You may request that we restrict processing of your data in certain circumstances.
• Right to data portability: You may request that your data be provided in a structured, machine-readable format.
• Right to object: You may object to processing based on our legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please submit a written request to info@assetstreet.ch. We will respond within 30 days. In complex cases, this period may be extended by a further 60 days, of which you will be notified.

Security

Asset Street SA implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures are reviewed and updated regularly in line with industry best practices and regulatory guidance.

Please note that no method of transmission over the internet is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. Material changes will be communicated to existing clients directly. The current version is always available on our website. The date at the top of this page indicates when the policy was last updated.

Contact Us

For any questions, requests, or complaints relating to this Privacy Policy or our data processing activities, please contact us at: