REFERENCE CAPITAL SA (hereinafter the “Company” or “we”) takes your privacy seriously. This Privacy Notice explains the data regarding natural persons (“Personal Data”) we process, how we collect and process it and for what purpose. This Privacy Notice also gives an overview of the rights you may have in relation thereto. 

 

This Privacy Notice applies to you if you are a current, former or prospective client, the beneficial owner of such client or any natural person interrelated to such client (“Interrelated Person” such as a relative, officer, employee, counterparty or service provider).

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1. What types of Personal Data do we collect​

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For client, prospect or beneficial owner, we may collect: 

• Personal information (such as name, surname, date of birth, marital status, nationality, place and address of residence, ID documents, pictures);

• Contact details (such as telephone and e-mail address);

• Professional information (job title, work experience, directorship / positions in companies and professional networks and information related to company ownership);

• Tax domicile and other tax related information; 

• Financial information (such as information relating to your assets and transactions as well as the origin, source, extent and structure of wealth and properties); 

• Investment information (such as your investment objectives, your knowledge of and experience in investment matters); 

• Details of our interactions and communications with you; 

• Other information regarding you contained in our interactions and communications with our client or an Interrelated Person. 

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For Interrelated Person, we may collect:   

• Personal or professional information (such as name, surname, ID documents, place and address of residence/work, job title) 

• Contact details (such as telephone and e-mail address);

• Details of our interactions and communications with you.

• Other information regarding you contained in our interactions and communications with our client or an Interrelated Person.

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2. How do we collect Personal Data

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We collect your personal data through publicly available sources or through information communicated to us by you or third parties (such as an Interrelated Person). 

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3. For which purposes we process the Personal Data

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We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve such purpose. In particular, we process Personal Data for the following purposes: 

• To evaluate whether and how we may offer services that may be of interest to a client or prospect; 

• To onboard a client;    

• To manage our relationship with you as a client or with a client to whom you are interrelated; 

• To provide our services to you as a client or to a client to whom you are interrelated; 

• To carry out legal compliance checks, including anti-money laundering regulations and sanction country screening; 

• To meet our ongoing legal and compliance obligations and to conduct our activity in a prudent operational manner;

• To exercise our duties and/or rights vis-à-vis you or third parties.

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4. Who has access to Personal Data and with whom are they shared

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When providing our services to a client, we may have to transfer Personal Data to third parties acting on behalf of, providing services to, entering into a relationship with or otherwise involved with the client. Depending on the location of the third party and the way it processes personal data, this may result in a transfer of Personal Data abroad, including in countries which are not considered to provide an adequate level of data protection. Such transfer will occur only if it is necessary to provide our services to you or if you gave a specific consent. 

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In some instances, we also transfer or give access to Personal Data to suppliers and service providers, who are contractually bound to confidentiality, such as IT providers, insurers, auditors, legal advisors. When we do so, we take steps to ensure they meet our data security standards, so that your Personal Data remain secure. Your personal data will be transferred abroad when our suppliers and services providers are located or operate abroad. We only transfer your Personal Data abroad to countries, which are considered to provide an adequate level of data protection, or based on appropriate safeguards (e.g. standard contractual clauses approved by the Swiss Data Protection Commissioner) or based on an appropriate derogation. A list of countries in which your data may be disclosed (directly or through our suppliers and service providers) may be found in Section 8.

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If required, we may disclose Personal Data to administrative or judicial authorities or parties to proceedings, where we are required to do so by applicable law. We may also need to disclose Personal Data to establish, exercise or enforce legal rights, including ours and those of our employees or stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others. Depending on where proceedings take place, this may result in disclosure of Personal Data abroad, including in countries which are not considered to provide an adequate level of data protection. Such transfer will only occur if you gave a specific consent or if the disclosure is necessary to establish, exercise or enforce legal rights before the relevant authority. 

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5. How long we store your data

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We will retain Personal Data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal requirements. Usually, we will keep most Personal Data related to a client relationship for the duration of such client relationship and for the contractual statute of limitation period afterwards. 

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6. What are your rights and how to exercise them

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You may have a right to access, ask for correction, object, request erasure, request restriction on the processing of your Personal Data and/or withdraw your consent where you gave us your consent to process your Personal Data (without any effect on the lawfulness of any processing that took place prior to the withdrawal). 

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To exercise any of the rights you have regarding your Personal Data that we process, please send an email to investorrelations@referencecap.com or a letter to Boulevard Georges-Favon 18, 1204 Geneva, Switzerland detailing the content of your request and enclosing a copy of your passport or identity card to allow us to verify your identity. 

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7. Update to this Notice

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This Notice was created on 1st September 2023 and updated on June 19, 2024. We reserve the right to amend it from time to time. 

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8. List of Countries

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Any country of the European Union.