Schroders Group Privacy Policy - Switzerland

“Client” means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Schroders.

“Schroders”, “we” or “us” means each of Schroder Investment Management (Switzerland) AG with its registered office at Central 2, CH-8001 Zurich, Switzerland and Schroder & Co Bank AG, with its registered office at Central 2, 8001 Zurich, Switzerland, and Schroders Capital Management (Switzerland) AG, with its registered office at Affolternstrasse 56, 8050 Zürich, Switzerland.
These entities and any of their subsidiaries or affiliates, details of which can be found on the Schroders website, together are referred to as the “Schroders Group”.

“Schroders Websites” means the websites operated by Schroders.

“Schroders Products and Services” means the products and services that we offer to our Clients, including through our related support, mobile or cloud-based services.

“Personal Data” means any information relating to an identified or identifiable natural person.

“You” means each person to whom this notice is addressed, who may be:

(a) a Client or prospective Client of ours, or a person related to a Client or prospective Client;

(b) a visitor to the Schroders website; or

(c) an employee, director, officer or representative of another organisation with which we have a business relationship or otherwise interact with.

(1.1) Schroders collects and uses certain Personal Data. Schroders is responsible for ensuring that it uses that Personal Data in compliance with applicable data protection laws. The controller for the processing of Personal Data in relation with this Privacy Policy is the respective Schroder entity (see above) with which you discuss or enter into a contract, communicate, or otherwise interact with, unless we inform you otherwise.

(1.2) At Schroders, we respect your privacy and we are committed to keeping your Personal Data secure.

(1.3) This Privacy Policy is directed to individuals whose Personal Data we process in relation with our commercial activities and with related activities. This includes Clients and prospective Clients as well as their representatives, agents or appointees, and employees, directors, officers and representatives of other organisations with which we have a business relationship or otherwise interact with. This Privacy Policy is also addressed to visitors to our websites.

(2.1) Schroders collects Personal Data about you in the following ways and circumstances:

a) Personal Data that we receive in the course of providing products or services to you. This Personal Data may be provided directly by you, but we may also collect it from other parties, for example from providers of ‘know your client’ and anti-money laundering services, which we sometimes use to help us meet our legal obligations.

b) Personal Data that we receive as part of your interest in our products or services. This Personal Data is usually provided by you and includes enquiries and other activities you perform while visiting our premises, participating in events we host and using Schroders Websites. It may also include Personal Data about individuals who are related to our Clients or prospective Clients. It may also include Personal Data about individuals who are related to you.

c) Personal Data that we receive through the use of Schroders Websites. Details of how we handle such Personal Data are set out in paragraph 10 of this Privacy Policy.

d) Personal Data that we collect, receive or generate in other scenarios, for example if we work or interact with a company or authority you work for, or if you communicate with us or if we communicate with you, or if we are involved in administrative or judicial proceedings.

We may combine the Personal Data about you that we collect directly from you with information collected from or about you in other contexts, such as from Schroders Websites or obtained from third parties.

(3.1) Many of the products or services we offer and our activities require us to obtain and process Personal Data, such as:

• Information that you provide to Schroders.  This includes information about you that you provide to us. The nature of our relationship with you will determine the categories of Personal Data that we might ask for or that you will provide to us. Such information may include:
• basic Personal Data such as first name; family name; national insurance number; email address; phone number; address (including city postcode and country); occupation and job title; bank details; ID documentation; date of birth; life events and family information; and
• sensitive Personal Data, which may be included in information we process about your nationality, place of birth, health related information, disability status, or details of political affiliations, or records of criminal offences and court proceedings; and
• any other Personal Data that you choose to share with us.

Relating to the provision of product and services to you, we also process Personal Data that you provide to us about any individual on whose behalf you act (or who works with a company on whose behalf you act) or who is otherwise related to you, for example investment beneficiaries, beneficial owners, family members, representatives, attorneys, co-workers, etc. By providing us with their Personal Data, you confirm that this Personal Data is accurate and that you have provided these persons with the information set out in this Privacy Policy, and we may assume that you are authorised to make such disclosure.

• Information that we collect from you or generate about you. This may include:
• Personal Data that we may receive or generate as a record of our relationship with our Clients and prospective Clients, including information relating to the negotiation of contract and any other information required or used for performing a contract, including your contact history; and
• any Personal Data that you provide to us or that we generate when we communicate with you, or you with us, including your contact details and the metadata of the communication, and including records of telephone and email communications, which we may monitor and process in order to resolve complaints, improve our service and comply with our legal and regulatory requirements; and
• any Personal Data that we obtain in relation to your use of Schroders Websites (but this will be limited to the situations where users make themselves known by establishing a secure, authenticated session).

• Information we obtain from other sources. Some of this Personal Data may be sensitive and may include:
• information from public and restricted-access sources, including third party agencies such as credit reference agencies, fraud prevention agencies, law enforcement agencies, official databases, registers and records such as such as commercial registers, criminal registers and bankruptcy registers, and other publicly accessible sources (e.g. internet); and
• information provided to us by independent financial advisors (IFAs), other professional advisers, product providers, event organisers, other agents and/or representatives, industry databases and other business intelligence tools that Schroders subscribes to; and
• information obtained from sanctions checking and background screening service providers; and
• information obtained in relation with administrative or judicial proceedings which we are involved in.

(3.2) You are not obliged or required to disclose Personal Data to us except in individual cases. For example, if you wish to enter into contracts with us or use our products or services, you are required to provide Personal Data to us, and when you use a Schroders Website, processing technical data cannot be avoided.

(4.1)   Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to allow Clients and prospective Clients to use and access Schroders Products and Services;
• to assess Client and prospective Client applications or contracts for Schroders Products and Services;
• to set up / on-board prospective Clients to use Schroders Products and Services;
• to keep our records up to date;
• to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
• to protect our premises from unauthorised access or use, or any unlawful activity;
• to administer or maintain IT systems in order to uphold standards of service;
• for ongoing review and improvement of the information provided on Schroders Websites to make them user friendly and prevent potential disruptions or cyber attacks;
• to understand feedback on Schroders Products and Services and to help provide more information on the use of those products and services quickly and easily;
• to communicate with and better understand the interests of Clients and prospective Clients in order to provide services or targeted information about Schroders and other Schroders Products and Services;
• to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests and learn more about our Clients and prospective Clients in order to develop, improve and manage the products and services we can offer;
• to maintain customer relationship management systems;
• for marketing and promotional purposes;
• for the management, operation and administration of our business;
• to prevent and investigate claims or suspicions of illegitimate or unlawful activities;
• to establish, exercise and defend our legal rights and to participate in administrative or judicial proceedings;
• for risk management purposes and as part of our corporate governance, including business organisation and development;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing your Personal Data.

(4.2)  When we use your Personal Data, we comply with applicable law. The law allows or requires us to process your Personal Data for a variety of reasons. These include instances where:

• we are performing our contractual obligations;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
• we have obtained your consent;
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
• allowing us to effectively and efficiently manage and administer the operation of our business;
• maintaining compliance with internal policies and procedures;
• enabling quick and easy access to information on Schroders Products and Services and offering effective, up to date security solutions for mobile devices and IT systems.

(4.3) Within Schroders, your Personal Data is accessed only by personnel of Schroders that have a need to access it for the purposes described in this Privacy Policy.

(5.1) We may share your Personal Data within the Schroders Group for the purposes described above.

(5.2) We may also share your Personal Data outside of the Schroders Group as further described below:

• with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
• with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);
• with third party agents and contractors for the purposes of them providing services both to us (for example, Schroders’ accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) and to you. These third parties will be subject to appropriate data protection obligations;
• with any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
• where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;
• with regulators, auditors and authorities, to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and other disclosure requirements);
• with courts and other persons involved in administrative or legal proceedings; and
• with a prospective buyer for due diligence purposes if we sell or contemplate selling any part of our business or assets.

(6.1) Schroders is a global business with Clients and operations around the world. As a result, we collect and transfer Personal Data within companies part of the Schroders Group, and from time to time to our third party service providers, on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

(6.2)  Where we transfer your Personal Data to another country we take appropriate measures to ensure that it will be protected and transferred in a manner consistent with legal requirements, for example in one of the following ways:

• the country to which we send your Personal Data offers an adequate level of protection for Personal Data;
• the recipient is subject to a legally recognised set of rules to ensure data protection;
• the recipient signed up to a contract based on the “standard contractual clauses” approved by the European Commission and recognised by the Swiss Data Protection and Information Commissioner (an example can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).

 (6.3) We may also transfer your Personal Data otherwise, where the law explicitly permits such a transfer, for example where the transfer is necessary for the establishment, exercise or defence of legal claims.

(6.4) You can obtain more details of the protection given to your Personal Data when it is transferred outside Switzerland by contacting us as described in paragraph 12 below.

(7.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value.

We operate and maintain physical, electronic and procedural safeguards to ensure an appropriate level of security for your Personal Data, and we restrict access only to authorised personnel. The effectiveness of these safeguards is periodically tested.

We also have appropriate controls and mechanisms in place to detect, respond and recover in case of adverse events.

(8.1) The period of time for which we keep your Personal Data will be determined by the following criteria:

• the purpose for which we are using it (as further described in this Privacy Policy at paragraph 4.1) – we will need to keep the data for as long as is necessary for that purpose.
• our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data. For example, we must keep accounting records for 10 years from the end of a business year, and may be required to keep other records under tax regulation for up to 20 years.

(9.1) Where we process your Personal Data, you may have the following rights, and in most cases you may exercise them free of charge:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;

• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to certain types of Personal Data;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection supervisory authority if you think that any of your rights have been infringed by us. (9.2).

You can exercise your rights by contacting us using the details provided at paragraph 12 below.  

(10.1) If you use a Schroders Website, we may collect technical information, for example through the use of cookies. The type of information collected varies by category of cookies as explained in our Cookie Notice. As detailed in our Cookie Notice, we provide you with the opportunity to selectively accept certain categories of cookies in your Web browser through our Cookie Manager Application. If you accept tracking cookies and make your identity known during a secure (logged-on) browsing session on one of our Web Sites, we will be able to combine the information we collect about your usage of our Web Sites during that session with other information we know about you, such as any searches you conduct on our Web Sites or information you request during your web session. We will use this combined information to assess the appeal and usefulness of the information and tools offered on our Web Sites as well as to identify Schroders products and services that may be of interest to you.

We also collect anonymous information related to browsing habits of users through other categories of cookies with the purpose of managing and improving our Website.

If you use a Schroders Website to communicate with us or apply for or use a Product or Service, please see above information about how we process Personal Data in relation with these activities.

(10.2) If you use a Schroders Website and follow a link from it to another website (including a website operated by Schroders), different privacy policies may apply. Prior to submitting any Personal Data to a website you should read the privacy policy applicable to that website

(11.1)  Any changes we make to our Privacy Policy in the future will be posted on this website and where appropriate, notified to you by email or other appropriate means. Please check back frequently to see any updates or changes to our Privacy Policy.

(12.1)  If you have any questions or concerns about Schroders’ handling of your Personal Data, or about this Privacy Policy, or how to exercise any of your rights, please contact us at the address below.

Schroder Investment Management (Switzerland) AG

Central 2

CH-8001 Zurich

Switzerland

Email: info-sim@schroders.com

Schroder & Co Bank AG
Central 2
CH-8001 Zurich

Switzerland
Email: complaintsCH@schroders.com

To exercise your right to withdraw consent to receive electronic marketing communications at any time, please follow “unsubscribe” instructions found in such marketing materials.

If you raise a concern or exercise your rights, we may:

• request additional details from you regarding your concerns and Personal Data limited to what is necessary for the purpose of authenticating you;
• engage or consult with other parties in order to investigate and resolve your issue (and these parties will receive and process information about you); and/or
• keep records of your request and any resolution of your issue,

in each case in accordance with our data protection and other legal obligations.