Data Protection Declaration

1. What is this privacy policy about?

Holinger Asset Management AG (hereinafter also "we", "us") obtains and processes personal data[1] , which concerns you or also other persons (so-called "third parties"). In this privacy policy, we describe what we do with your data when you use [] (hereinafter "website")[2], obtain our services or products, otherwise deal with us under a contract, communicate with us or otherwise deal with us.

If you transmit or disclose data to us about other persons, such as family members, we assume that you are authorised to do so, and that this data is correct. By submitting data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.

2. Who is responsible for processing your data?

We are responsible for the data processing described in this privacy policy. You can contact us for your data protection concerns and to exercise your rights pursuant to para. Fehler! Verweisquelle konnte nicht gefunden werden. as follows:

Netgen Switzerland AG
Seestrasse 356

3. What data do we process?

We process different categories of data about you. The main categories are as follows:

  • Master and portfolio data such as name, address, date of birth, contract number and duration, documents to establish the customer's identity, information on the account, custody account, concluded transactions or on third parties such as life partners, authorised representatives and advisors who are also affected by data processing.
  • Residence for tax purposes and any other documents and information relevant for tax purposes.
  • Transaction or order and risk management data such as beneficiary details, mandate details where applicable, details of your assets, investment products, risk and investment profile, fraud.
  • Records of telephone calls between you and us, if applicable.
  • Marketing data such as needs, wants, preferences.
  • Technical data, such as internal and external identifiers, business numbers, IP addresses, records of access or changes.

 4. For what purposes do we process your data?

We process your data for the following purposes (in addition to those we notify you of separately):

  • Communication with you
  • Contract conclusion/processing with you, your employer and customers
  • Operation of the infrastructure, website, app
  • Marketing (e.g. mailings, with unsubscribe link/option, occasions), relationship management
  • Market analyses, planning, development of products & services, R&D
  • Compliance (adherence to laws, industry standards, directives etc.)
  • Legal procedures, investigations
  • Safeguarding security, access control
  • Management, Risk Management
  • Corporate transactions (e.g. M&A)
  • Media relations, PR, publications
  • Shareholder Services, Investor Relations
  • Training, instruction, further education
  • Fighting crime and fraud

5. On what basis do we process your data?

Depending on the products and services we may provide to you or the purpose for which the personal data is processed, the data processing is based on the following:

  • Entering into, concluding or performing a contract or business relationship with you or for the performance of our obligations under such contract or business relationship.
  • To safeguard our legitimate interests, e.g. statistics, planning or product development, business decisions; monitoring and controlling risks, business auditing; marketing, market research, comprehensive support, advice and information on the range of services, preparation and provision of tailor-made services - insofar as no objection has been made; safeguarding our interests and securing the claims of our company, customers and employees.
  • To fulfil legal or regulatory obligations of our company or the performance of tasks in the public interest.
  • Based on your consent.

6. Do we use online tracking and online advertising techniques?

We use various techniques on our website which enable us and third parties engaged by us to recognise you when you use our website and, in some circumstances, to track you across multiple visits. We inform you about this in this section.

In essence, this is so that we can distinguish accesses by you (via your system) from accesses by other users, so that we can ensure the functionality of the website and carry out evaluations and personalisations. In doing so, we do not want to infer your identity, even if we can do so insofar as we or third parties engaged by us can identify you through a combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of the third parties) assigning you or your browser a specific identification number (so-called "cookie").

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can therefore be "tracked" (traced). If we integrate offers from an advertising contractor or provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in individual cases.

We use such techniques on our website and allow certain third parties to do so as well. You can programme your browser to block or deceive certain cookies or alternative techniques, or to delete existing cookies. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword "data protection") or on the websites of the third parties that we list below.

A distinction is made between the following cookies (techniques with comparable functions such as fingerprinting are included here):

Necessary cookies: Some cookies are necessary for the website to function as such or for certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary ("session cookies"). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one session (i.e. one visit to the website) if you use this function (e.g. language selected, consent given, the function for automatic login etc.). These cookies have an expiry date of up to 3 months.

Performance cookies: In order to optimise our website and corresponding offers and to better adapt them to the needs of users, we use cookies to record and analyse the use of our website, possibly even beyond the session. We do this through the use of third-party analytics services. We have listed these below. Before we use such cookies, we ask for your consent. You can revoke this at any time via the cookie settings here []. Performance cookies also have an expiry date of up to 3 months. Details can be found on the websites of the third-party providers.

Marketing cookies: We and our advertising partners have an interest in targeting advertising, i.e. displaying it only to those we want to target. We have listed our advertising partners below. For this purpose, we and our advertising partners - if you consent - also use cookies that can be used to record the content accessed or contracts concluded. This allows us and our advertising partners to display advertisements that we think you may be interested in on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiry date of between a few days and [12] months depending on the situation. If you consent to the use of these cookies, you will be shown appropriate advertising. If you do not consent to these cookies, you will not see less advertising, but simply any other advertising.

In addition to marketing cookies, we use other techniques to control online advertising on other websites and thereby reduce wastage. For example, we can transmit the email addresses of our users, customers and other persons to whom we want to display advertising to the operators of advertising platforms (e.g. social media). If these persons are registered there with the same e-mail address (which the advertising platforms determine through a comparison), the operators show the advertising placed by us to these persons in a targeted manner. The operators do not receive personal e-mail addresses of persons who are not already known. In the case of known email addresses, however, they learn that these persons are in contact with us and which content they have accessed.

We may also integrate further third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (e.g. by clicking a button), the corresponding providers can determine that you are on our website. If you have an account with the social media provider, they can assign this information to you and thus track your use of online offers. These social media providers process this data on their own responsibility.

We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set on your computer for advertising purposes):

Google Analytics: Google Ireland (based in Ireland) is the provider of the "Google Analytics" service and acts as our order processor. Google Ireland relies on Google LLC (based in the USA) as its processor (both "Google"). Google uses performance cookies (see above) to track the behaviour of visitors to our website (duration, frequency of pages viewed, geographical origin of access, etc.) and compiles reports for us on the use of our website on this basis. We have configured the service in such a way that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the USA and thus cannot be traced. We have switched off the "Data sharing" and "Signals" settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these individuals. If you consent to the use of Google Analytics, you explicitly agree to such processing, which also includes the transfer of personal data (in particular usage data for the website and app, device information and individual IDs) to the USA and other countries. Information on the data protection of Google Analytics can be found here and if you have a Google account, you can find further details on processing by Google here

7. Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests, we also transfer your personal data to third parties, in particular to the following categories of recipients:

  • Service providers (who process your data partly on our behalf, e.g. IT providers, partly on their own responsibility, e.g. banks)
  • Authorities at home and, if applicable, abroad
  • Business partners such as suppliers,
  • Customers, marketing and project partners
  • Third parties who collect data about you via website/app (see list on the website)

8. Does your personal data also end up abroad?

Yes, this is possible, to the EEA, but exceptionally to any country in the world (conceivable especially for online services that we use). If this is a country without sufficient data protection, we conclude contracts (so-called EU SCC), but may also rely on consent or transfer data abroad on a case-by-case basis, because it is necessary for the processing of a contract, where it concerns data published by you or it is necessary for legal proceedings abroad. 

9. How long do we process your data?

The duration of the storage of personal data is determined by legal retention obligations or the purpose of the respective data processing. As a rule, we store personal data for the duration of the business relationship or the duration of the contract and then for a further five, ten or more years (depending on the applicable legal basis). 

10. How do we protect your data?

We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect against the risks of loss, accidental alteration, unauthorised disclosure or access.

11. What rights do you have?

You have the right to information, correction, deletion, restriction, objection and - if applicable - the right to data portability. Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority. If you wish to exercise the above rights against us), please contact us in writing, at our premises or, unless otherwise stated or agreed, by e-mail. You will find our contact details in para. Fehler! Verweisquelle konnte nicht gefunden werden.. In order for us to be able to exclude misuse, we must identify you (e.g. with a copy of your ID card, unless otherwise possible).

12. Can this privacy policy be changed?

This privacy policy does not form part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated: 21.08.2023

[1] Your personal data is any information that relates to you and can identify you directly or indirectly (e.g. via the internet) (e.g. name, email address, telephone number, picture, depending on your profile.

[2] If you surf our website, for example, your IP address, your browser type, the address from which you were referred are automatically communicated.

To make this website run properly and to improve your experience, we use cookies. For more detailed information, please check our Cookie Policy.

  • Necessary cookies enable core functionality. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.