Compass Asset Management SA (hereinafter “Compass”) is a company with many years of experience in international finance (asset management, investment funds, trading and bond brokering, estate and succession planning and risk management).
Processing of personal data to which Compass may become privy is carried out in compliance with the Federal Law on Data Protection (LPD), and takes into account the principles of correctness, lawfulness, transparency and all limitations aimed at the storage, minimisation and accuracy of data, i.e. while respecting the protection of personal integrity and confidentiality of all sensitive personal information.
This Privacy Policy is understood to be for the website www.compass-am.com (hereinafter the “Website”).
The Data Controller is Compass Asset Management SA.
To request further information about the processing of your personal data or to exercise your rights, you can contact us:
| by writing to: | Compass Asset Management SA Via Calprino 186900 – Lugano Paradiso Switzerland |
| by writing to the email address: | compliance@compass-am.com. |
What is personal data and what is processed
Personal data is information that directly or indirectly identifies or can identify a natural person and can provide information about his or her characteristics, habits, personal relationships, etc. The following is considered personal data, including but not limited to: first name, last name, address or other contact details, an identification number or an online identifier.
Processing is any operation performed with or without the aid of automated processes and applied to personal data. Processing includes, but is not limited to: the collection, recording, organisation, storage, modification, consultation, erasure or destruction of data.
What personal data is being processed
- Browsing data
During normal operation, the computer systems and software procedures responsible for the operation of the Website acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but may by its very nature enable the User to be identified through processing and association with data held by third parties. This data includes: the IP addresses or domain names of the computers used by the User who connects to the Website; the URI addresses of the resources requested (Uniform Resource Identifier); the time of the request; and finally, other parameters relating to the User’s operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Platform to control its correct functioning, to identify anomalies and/or abuses and is deleted immediately after processing. The data could be used to ascertain liability in the event of possible computer offences against Compass or third parties.
- Data provided by the User via the “Info” page
The User’s data is collected by Compass following the sending by the User of a contact email and/or request for information containing any personal data that the User will voluntarily transmit in the text of the “Message” to be sent, or following telephone contact by the User.
Purpose of processing
Your personal data will be processed for the following purposes:
- Respond to the request forwarded by the User to Compass;
- Fulfil the pre-contractual, contractual, administrative and tax obligations arising from the relationship that may be established between the User and Compass;
- Send the User service-related communications/notifications;
- Fulfil the obligations established by law, current regulations, practice and requirements of the competent authority;
- Exercise by Compass of its rights (both in and out of court);
Legal basis for the processing of User’s data
Each processing is justified by one of the following legal assumptions:
- Such processing is necessary for the execution of the contract between the parties. The provision of personal data is optional in this case but failure to provide it means that it is impossible to conclude the contract and perform the service requested;
- Processing is necessary for compliance with a legal obligation. In this case, the provision of data is mandatory and failure to provide it will result in it being impossible to conclude the contract and to perform the requested service;
- Processing is necessary for the pursuit of the legitimate interests of the Controller, provided that the interests or fundamental rights and freedoms of the User that require the protection of personal data do not prevail. In this case, the provision of data is optional.
- Processing is only possible where the User has consented to certain specific purposes. In such cases the provision of data is optional, and the User may revoke the consent previously given at any time.
To whom might the data be disclosed
In the context of Compass’s activity and for the purposes specified above, User personal data may be shared with:
- Duly appointed data processors providing specific processing or ancillary services on behalf of Compass; the User may at any time request an up-to-date list of data processors;
- Autonomous Data Controllers to whom the data may be communicated pursuant to provisions of law or orders of the Authorities;
- Persons authorised by Compass to process personal data necessary for the performance of activities strictly related to the provision of services and who have entered into an appropriate legal and contractual obligation of confidentiality (e.g. Compass employees and/or contractors).
Compass does not intend to sell or otherwise disclose your personal data to third parties.
Where the data is stored
All personal data is stored electronically on servers located in Switzerland.
How long the data is stored
Your personal data is kept in compliance with the confidentiality and regulations in force for a maximum period of 10 years from the end of the contractual relationship. Any CV submitted by the User as candidates will be retained for a maximum period of 2 years after they have been submitted.
In any case, Compass may retain the User’s personal data for the period of time provided for and permitted by Swiss law to protect its own interests.
What are the rights of the User?
At any time, you can request confirmation as to whether or not your personal data is being processed and you have the right to:
- request access to the data to obtain information on the purposes pursued with the processing, the recipients to whom the data may be disclosed, the duration of the processing (where possible) and any consequences of processing based on profiling;
- request the correction of personal data if it is inaccurate or incomplete;
- request the erasure of data if is no longer needed by Compass for the purposes of the planned processing;
- request that data processing be restricted, in the cases provided for by law;
- request the transfer of data to another Data Controller in a commonly used format that can be read by a computer device, in the cases provided for by law;
- object to the processing of your data and, specifically, have the right to object to decisions concerning you, if based solely on automated processing of your data, including profiling;
To exercise their rights, the User may use the contact details provided in paragraph 1 or access the website of the Federal Data Protection and Transparency Officer http://www.edoeb.admin.ch
Automated Decision Making
You are not subject to decisions based on automated processing.
Cookies
Cookies are text rows which act as computer markers sent from a server (in this case, the one on the Website) to a user’s device (usually to the Internet browser) when they access a given page of a website; cookies are automatically stored by the user’s browser and retransmitted to the server that generated them each time the user accesses the same Internet page. In this way, for example, cookies allow and/or facilitate access to certain Internet pages in order to improve the user’s browsing experience (i.e. they allow the storage of pages visited and other specific information, etc.), or in some cases they allow profiling activities. Therefore, for a facilitated and complete use of the Website, it is useful if, the first time you access the Website, you express your preferences regarding the placement of cookies.
Characteristics and purposes of cookies
Our Site uses the following categories of cookies:
“Necessary Cookies” (known as Technical cookies): These are necessary to enable the User to browse the Website and use its functionalities. In particular, they enable functions without which it would not be possible to use the Website fully, since their presence enables basic functions such as page navigation and access to the protected areas of the Website.
“Session Cookies” are active cookies for the relevant session only, which allow you to temporarily store the information needed to navigate from page to page and avoid having to re-enter it.
The User’s consent is not required for the use of Necessary Cookies (“Technical”).
Amendments
Compass reserves the right to amend or simply update the content of this Privacy Policy, in part or in full, including as a result of changes in the applicable legislation. These changes will be binding as soon as they are published on the Site. If you continue to access or use the service after such posting you will be deemed to have expressly accepted these changes. Compass therefore invites the User to visit this section regularly to gain knowledge of the most recent and updated version of the Privacy Policy so that it can always be updated on the data collected and the use that Compass makes of it.
15 February 2023