If you have any queries, comments or complaints regarding this Notice, just get in touch with us at firstname.lastname@example.org. The content of the website is managed by Symbiotics SA, a société anonyme incorporated and organized under the laws of Switzerland, having its office at Rue de la Synagogue 31, 1204 Geneva, Switzerland and registered in the Registre du commerce du canton de Genève under the federal number CH-660.2.263.004-0.
Last modified: 18th of February 2019
Symbiotics SA is committed to protecting and respecting your privacy. This Notice explains how your personal information is processed by Symbiotics, including any affiliates listed in the Data Controllers and Contact section below (hereinafter also collectively referred to as “us” or “we”).
This Notice concerns personal information relating to several categories of identified or identifiable natural persons that we may collect through any medium, including specifically in relation to the investment services we provide to you, via our partners and service providers, or through our website. This policy describes how you can access and make certain choices about how we use your personal information.
YOUR PERSONAL INFORMATION THAT WE MAY COLLECT
We may collect and process data in relation to the below listed information with respect to persons connected with the investment services we provide, our website, and our job applications. As well as collecting personal data from our clients (including potential clients), we may also process personal data about relevant persons connected with the investment services, for example 3rd party agents acting on behalf of prospective or existing investors, co-investors, their beneficial owners, contractors, etc.
We may collect this information from a number of sources, including directly from you, via our affiliates, delegates, partners, service providers, legal professional advisors, distributors, or third-party entities with whom we undertake due diligence checks upon you or publicly available sources. In doing so, we will ensure that the information we collect is proportionate to our stated purposes.
Where relevant, we may collect and process personal information related to persons associated with you. In such circumstances, it is your responsibility to ensure you have permission from that third-party for us to collect their information and you remain responsible for ensuring that the third-party understands how their information is being used.
In each case, we collect such information only insofar as is necessary or appropriate to fulfill the purpose of the person’s interaction with us, e.g. to provide the online products and/or services or individuals connected with our investment services. A person can always refuse to supply personal data, with the caveat that it may prevent such person from engaging in certain related activities with us.
Personal data that we may collect and process includes:
- Identification data, e.g., names, addresses, telephone numbers, email addresses, business contact information;
- Personal characteristics, e.g., date of birth, nationality;
- Profile Data, e.g., your username and password;
- Professional information, e.g., employment and job history, title, representation authorities;
- Identifiers issued by public bodies, e.g., passport, identification card, tax identification number;
- Financial information, e.g., financial and credit history information, bank details;
- Transaction/investment data, e.g., current and past investments, investment profile, investment preferences and invested amount, number and value of shares held, role in a transaction (seller/acquirer of shares), transaction details, tax details;
OUR LEGAL BASES AND PURPOSE FOR HOLDING YOUR PERSONAL INFORMATION
Unless specifically stated otherwise in a Privacy Notice provided to you, we use your personal information in the following ways and based upon the following lawful bases:
- In order to achieve our legitimate interests (this may include, among others, electronic communications between us; the provision of investment information to you; details in order for us to manage and improve our website; for us obtaining and recording details relating to your visit behavior on our website). In doing so, we ensure that:
- your rights and interests are considered and protected and there is a minimal privacy impact upon you;
- we are able to demonstrate that we use your data in a proportionate manner and you would not likely be surprised or likely to object to our usage;
- we can lawfully disclose personal data to third-parties where we can demonstrate that this disclosure is justified;
- Where we need to perform a contract that we are about to enter into or have entered into with you (this includes where you have asked us to do something before entering into a contract, for example to provide a quote);
- To comply with our legal or regulatory obligations (for instance, under relevant AML/CTF legislation);
- Based upon reasons of substantial public interest;
- Where your personal information is public information by your own actions;
- Where your personal information is public information by your own actions; and
- Explicit consent in very limited circumstance.
WHEN WE MAY DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your personal information with the following category of recipients, and based upon the legal bases and purposes set-out above:
- Our affiliates, including relevant third-party investment funds that we either manage or advise.
- Our partners and service providers, including service providers appointed by the third-party investment funds that we either manage or advise.
- Any law enforcement, court, regulator or other government authority in order for us to comply with a legal obligation laid down by EU or Swiss law. This includes the provision of information relating to any affiliate of Symbiotics.
- A prospective buyer of our business, including where we intend to sell part of our business or merge with another third-party.
HOW AND WHERE WE STORE YOUR PERSONAL INFORMATION
We store your physically-held and electronically-held personal information in our Swiss offices in secure locations and secure servers.
We take all reasonable steps to protect your personal information; however, where you choose to transmit your personal data to us via the internet, we do not guarantee the security of the personal information transmitted and therefore any transmission is at your own risk. When you enter sensitive information (such as investment information) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We may transfer your personal information to our affiliates, partners, or service providers that are based outside of Switzerland or the European Economic Area. In such circumstances, we will ensure that your personal information is adequately protected to European Commission approved standards. Transfers of this type will be restricted to limited, specific, and necessary situations.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
WHO CAN ACCESS TO YOUR PERSONAL INFORMATION
Your information may be disclosed, to the extent permitted by law, to its affiliates, and their agents and third-party service providers, to countries inside or outside Switzerland or the European Economic Area (EEA), to perform services for Symbiotics. Note that personal data is transferred outside the EEA on the safeguards of the GDPR and the DPA.
YOUR RIGHTS AS A DATA SUBJECT
In certain circumstances, in relation to your data, you have certain rights:
- The right to be informed
- The right of access,
- The right to rectification,
- The right to erasure,
- The right to restrict processing,
- The right to data portability,
- The right to object, and
- Rights in relation to automated decision making and profiling.
Further details of your rights can be found on the websites of many Data Protection Authorities (i.e. the ICO website), however, please note that your rights are subject to our overarching legal responsibilities. If you wish to exercise any of these rights, please contact the relevant data controller (listed below).
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We reserve the right to retain your personal information for as long as we reasonably believe it to be necessary in order to facilitate our legitimate interests, in order for us to comply with our legal or regulatory obligations, where based upon reasons of substantial public interest, or where your personal information remains public information by your own actions. Your personal data will not be retained for longer than necessary with regard to the purposes and compliance obligations contemplated in this notice, subject always to applicable legal minimum retention periods. For further information, please contact the relevant data controller (listed below).
OUR RESPONSIBILITIES WHEN WE MAKE CHANGES TO OUR PRIVACY NOTICE
We may make changes to our Privacy Notice at any time and may do so without expressly notifying you of these changes. However, should the legal bases or purpose for processing your personal information changes then we shall expressly notify you.
OUR DATA CONTROLLERS AND HOW TO CONTACT US
Questions or individual data requests relating to this Notice should be addressed to the relevant data controller. For the purpose of the data protection legislation, the relevant data controllers are:
- Symbiotics SA
Rue de la Synagogue 31, 1204 Geneva, Switzerland
+41 (0) 22 338 15 40
Responsible for group headquarters responsible for setting Group strategy. All asset management activities related to (Swiss) FINMA regulated activities.
- Symbiotics UK Ltd
Registered number: 08618323
6, Belvis Marks, London, England EC3A 7BA
+44 (0) 20 378 611 86
Responsible for advising on investments, arranging (bringing about) deals in investments, making arrangements with a view to transactions in investments activities related to (UK) FCA regulated activities.
- Symbiotics Netherlands BV
(Operating Plumseeds platform)
Meester Treublaan 7, 1097 DP Amsterdam, Netherlands
+31 (0) 20 240 9329
Responsible for provision of delegated online platform services related to Symbiotics’ investment products and services. Symbiotics SA’s GDPR Article 27 Representative in the EU.
Technologies such as cookies (a small piece of data sent from a website and stored on the user’s computer while the user is browsing), tags, and scripts are used by Symbiotics and our partners, including marketing partners affiliates, or analytics service providers (like Google Analytics) and business process service providers. These technologies are used in order to provide the services in a more individual way. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Cookies are typically deleted from your device once the browsing session is terminated. You can choose to block cookies that we may deliver to your device through settings on your web-browser; however, in doing so you may not be able to access or utilize all aspects of our website.