Privacy Policy

At Vectra Advisors AG (“Vectra Advisors”, “we”, “us”, “our”, “ours”), we are committed to protecting the privacy and confidentiality of your personal data. We strictly comply with the applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and Switzerland’s Federal Act on Data Protection (FADP). This Privacy Policy outlines the types of personal data we collect, the purposes for which we process it, the legal grounds for processing, data security measures, data sharing practices, data storage and transfers, data retention periods, your rights regarding your personal data and how to get in touch regarding privacy issues, and changes to this Privacy Policy.

1. Accepting collection and processing of your personal data

By using our websites or its services/tools, you accept that Vectra Advisors may collect and process your personal data. You acknowledge that you have read, understood, and agree to this Privacy Policy. Your consent for data processing is given in particular through browsing through our website(s), consenting to cookie use, or providing data for community/registration. Vectra Advisors may use this data within the limit provided by applicable laws and this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please refrain from using our website(s).

2. Types of Personal Data We Collect/Process

The main source of personal data processing is the information received directly from our clients during our client relationships. Additionally, we may obtain data from business partners or other involved parties when appropriate and permissible. We may also gather data from publicly accessible sources like online media publications or public registers, or receive it from our clients, their employees or their contractual partners, government bodies and other third parties, such as counterparties and business partners. We may collect and process various categories of personal data from third parties, including but not limited to the following:

  • Name, contact details (email address, phone number, address)
  • Identification information (such as government-issued ID or passport)
  • Professional information (such as job title, company name)
  • References for applications
  • Information obtained from the government bodies
  • Information shared by people around you (e.g. friends and family, advisors)
  • Information needed for agency acts (e.g. references, your address for deliveries, powers of attorney)
  • Payment and creditworthiness information (credit/debit card details/debt collection information)
  • Any other personal data you voluntarily provide to us during consultations or through the website. When you visit our website, we may collect both personally identifiable information (PII) and non-personally identifiable information (non-PII) from you. PII includes but is not limited to your name, email address, and contact details. Non-PII includes technical information such as your IP address, browser type, and usage patterns. Please refer to our Cookie Policy for further information regarding the cookies we employ and for guidance on how to control and remove cookies.
3. Purposes of Processing

The data we collect serves primarily to establish and manage contracts with our clients and business partners. This is particularly crucial for providing our services to our clients and obtaining products and services from suppliers and subcontractors, including foreign and domestic lawyers, accountants, tax advisors and experts. Additionally, we process data to meet domestic and foreign legal requirements. If you are an employee of one of our clients or business partners, your personal data may be subject to this processing.

Furthermore, in compliance with applicable laws and where appropriate, we may process your personal data and that of third parties based on legitimate interests. These interests may include the following purposes:

  • Providing our services
  • Verifying your identity
  • Processing payments for our Services
  • Complying with legal and regulatory obligations
  • Managing and improving our website, applications, platforms and services
  • Market research, market monitoring, advertising and marketing (including organizing events) Sending promotional materials and newsletters (if you have provided your consent; if you receive our advertisements and wish to opt-out, you can do so at any time, and we will add you to our blacklist to exclude you from further advertising mailings)
  • Preventing and investigating criminal offenses and other misconduct, including conducting internal investigations and fraud analysis
  • Protecting our rights, property and safety, and these of certain third parties, e.g. our other clients
  • Recruiting 

If you have provided us with your consent to process your personal data for specific purposes, we will process your data based on that consent, unless there is an alternative legal basis that applies. This consent will remain valid until withdrawn, and you have the right to withdraw your consent at any time. However, please note that any data processed prior to the withdrawal will remain unaffected.

4. Collection of Personal Data

We collect personal data through the following means:

  • Information you provide through our website, forms, or during consultations
  • Information obtained during phone or email communications
  • Data collected through cookies and similar technologies on our website (please refer to our Cookie Policy)
5. Personal Data Security Measures

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, or alteration. We restrict access to your personal data to only those employees or third parties who need it to perform their duties.

6. Data Sharing and Transfers

In the course of of providing our services and in connection with our business activities, we may share your personal data with various categories of third parties both domestically and internationally such as:

  • Our team members and consultants involved in providing legal services 
  • Third-party service providers assisting us in carrying out our business activities (e.g., payment processors, IT support, other suppliers and subcontractors)
  • Third parties involved in the context of the client’s matter (external tax advisors, accountants, banks, mediators, business consultants etc) 
  • Law enforcement, courts, regulatory authorities, when required by law or to protect our legal rights
  • Insurance providers, business partners, counterparties, and other third parties

Such disclosures may occur in Switzerland, EU/EEA, the United States, or other countries for the purposes mentioned above and where appropriate. Additionally, we may be obligated to disclose your personal information to comply with legal or regulatory obligations.

We conduct thorough due diligence on third-party contractors and ensure through contractual agreements that sub-contractors process personal data appropriately, in compliance with our legal and regulatory obligations. Additionally, we may engage external data controllers, such as lawyers, accountants, or other third-party experts, when appropriate to deliver our services.

When transferring data to a country outside EU/EEA/Switzerland that lacks adequate legal data protection, we take measures to ensure a sufficient level of protection. This includes utilizing data transfer agreements, such as the standard contractual clauses approved by the European Commission. Alternatively, we may rely on specific legal exceptions, such as consent, contractual obligations, mandate processing, the pursuit of legal claims, overriding public interests, the publication of personal data, or the necessity to protect the data subjects’ integrity.

If you wish to obtain a copy of our data transfer agreements, please feel free to get in touch with us. We reserve the right to redact copies of certain information for data protection reasons, confidentiality concerns, or to produce excerpts instead.

7. Google Analytics and Other Third-Party Services

We use Google Analytics and Mailchimp on our website which allow us to measure and evaluate the use of our website (without identifying individuals). These are services provided by third parties, which may be located in any country (in the case of Google Analytics, Google LLC is based in the US but Google Ireland Ltd. is the data controller for customers based in the EU and Switzerland). The data produced through Google Analytics cookies regarding your website(s) usage, including your IP address, might be transmitted to and stored on Google servers located beyond your country of residence. Google employs this data to assess your website(s) engagement, produce activity reports for publishers, and furnish additional services linked to website activity and internet utilization. Google may share this information with third parties as required by law or when third parties process this data on Google’s behalf, such as the website’s publisher. Google will not amalgamate your IP address with other data within its possession. For more information, visit https://policies.google.com/?hl=en). Permanent cookies, which are placed by the service provider, are also used for this purpose. Although such service providers do not receive personal data from us (and do not retain any IP addresses), they may track your use of the website, combine this information with data from other websites you have visited, which are also tracked by service providers, and use this information for their own purposes (e.g. to manage advertising). If you have registered with the service provider concerned, the service provider will also know your identity. The service provider concerned will then be responsible for processing your personal data in accordance with the applicable data protection provisions. Service providers only provide information on how a particular website is used (but not any personal details).

We also use plugins from social networks such as Facebook, Twitter, YouTube, Google+, LinkedIn on our websites. This will be evident to you, as the relevant symbol will typically be displayed. We have configured these elements to be disabled by default. If you enable these (by clicking on them), the social network operators may register that you are on our website and where you are on our website and may use this information for their own purposes. The operator concerned will then be responsible for processing your personal data in accordance with the applicable data protection provisions. We will not receive any information regarding you from the operator concerned.

8. Data Retention

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. As soon as the personal data collected by us is no longer required for these purposes, they will be deleted or anonymized as far as possible.

9. Rights of Customers Regarding Personal Data

You have the right of access, rectification, erasure, limitation/restriction of processing, portability, objection, revocation of the declaration of consent under data protection law for the future and data transferability as far as provided by applicable the data protection law (e.g. where the GDPR is applicable).

To exercise any of these rights, please contact us using the details provided in section 10 below.

In addition, you have the right to submit a complaint with the supervisory authority. Switzerland’s competent data protection authority is the Federal Data Protection and Information Commissioner.

10. Contact Regarding Privacy Issues

If you have any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact us at: 

Vectra Advisors AG
Seehofstrasse 4
8008 Zurich
Switzerland
privacy@vectra-advisors.com
+41 (0) 44 523 73 23 

11. Changes to This Privacy Policy

We reserve the right to periodically update and amend this Privacy Policy in response to alterations in our data processing procedures or legal obligations. Any modifications will be made available on our website, and we recommend that you periodically review this Privacy Policy for any changes.

Last Updated: 15.06.2023