Rev. April 2019
FACTS
What does VSWA do with your personal information?
Why?
Investment advisers choose how they share your personal information. US federal law gives investors the right to limit some but not all sharing. US federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What information do we collect?
The types of personal information we collect and share depend on the products and services you have with us. This information can include (but is not limited to):
- Social Security number
- Name, address and nationality
- Family and marital status
- Investment objectives and experience, risk tolerance
- Financial and investment qualifications
- Income and account balances
- Trading and transaction history
When you are no longer our client, we continue to share your information as described in this notice.
How is your information used?
All investment advisers need to share investors’ personal information to run their everyday business. In the section below, we list reasons why investment advisers can share their investors’ personal information, the reasons VSWA chooses to share such information, and whether you can limit this sharing.
Reasons we can share your personal information |
Does VSWA share? |
Can you limit this sharing? |
| For our everyday business purposes – such as to process your transactions, to maintain and archive your account(s) and information, exchange information with your custodian, perform compliance functions and controls, respond to court orders or legal investigations or report to tax authorities | Yes | No |
| For our marketing purposes – To offer our products and services to you | No | We don't share |
| For joint marketing with other financial companies | No | We don't share |
| For our Affiliate, Bank Vontobel AG’s, everyday business purposes serving as your custodian and our service provider – information about your personal background for “Know Your Client” rules and Anti Money Laundering regulations, information about your transactions and tax information | Yes | No |
| For our affiliates‘ everyday business purposes – Information about your creditworthiness | No | We don't share |
| For our affiliates to market to you | No | We don't share |
| For our non-affiliates to market to you | No | We don't share |
Questions?
Call +41 44 287 8181
Who is providing this notice?
We are a Swiss-based investment adviser registered with the U.S. Securities and Exchange Commission (SEC).
How does VSWA protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with U.S. federal and Swiss law. These measures include computer safeguards and secured files and buildings.
How does VSWA collect my personal information?
We collect your personal information, for example, through:
- Account opening forms;
- Transactions within your account, including deposits and payments of funds, account balances, investments, and fees;
- Other information provided by you in writing, in person, by telephone, electronically or by any other means (including, discussions with our VSWA advisory staff); and
- Statements or records we receive from third party professionals that you have retained and authorized to provide information directly to us.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
- Sharing for our affiliates’ everyday business purposes – information about your creditworthiness;
- Affiliates from using your information to market to you; and
- Sharing for non-affiliates to market to you.
State laws and individual companies may give you additional rights to limit sharing.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies. For purposes of information sharing, VSWA’s Affiliates include only Bank Vontobel AG, who is currently serving as your custodian.
Non-affiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates include the broker-dealers who execute the transactions you have authorized, our external auditors and legal counsel.
Joint marketing
Joint marketing means a formal agreement between nonaffiliated financial companies that together market financial products or services to you. VSWA does not participate in any joint marketing with other financial companies but even if it did, it would not share any of your personal information in this regard.
Other important information
We reserve the right to change this Notice of Privacy Policy at any time. The examples contained within this Notice are illustrations and are not intended to be exclusive. This Notice complies with federal law and SEC regulations regarding privacy. VSWA also adheres to the data protection standards within Europe under the EU General Data Protection Regulation ( “GDPR”). VSWA’s GDPR Privacy Notice can be found at https://www.vontobeladvisors.com/de-int/legal-notice/gdpr/ and sets out information as to how and for what reasons VSWA collects, processes and stores your personal data, the legal basis on which this is done, what rights you have in this regard and what obligations VSWA has with regard to the processing of personal data. You may have also additional rights under other applicable laws, including in particular under state laws.