Privacy Policy
Policy (2025)

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What types of personal data do we collect and what sources do we use?

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The personal data we process may include (i) personal details (e.g. name, place of birth, date of birth, citizenship, address, telephone numbers, email addresses, family details, other KYC information) (ii) identification data (e.g. copy of passport or identity card, social security number, tax identification number) (iii) tax information (e.g. tax domicile and other tax-related documents and information) (d) professional information about you (e.g. job title, job experience) (iv) financial information (e.g. financial and credit history information, transaction data, bank details) (v) your investment profile and investment preferences (vi) records of phone calls between you and Banque Thaler (vii) details of interactions with you and the products and services you use (viii) cookie information (e.g. cookies and similar technologies on websites and in emails) (please also see our Cookie Policy). We collect and receive personal data (i) directly from you (e.g. when you are contacting us or sending us contractual documents or forms) (ii) indirectly from third parties or publicly available sources (e.g. commercial register, sanctions lists, press, media, internet)

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For what purposes and on what legal bases do we process your personal data?

We process personal data in accordance with the Federal Act on Data Protection (ADP), and, to the extent applicable, with the European General Data Protection Regulation (GDPR). Personal data that we process may also be subject to banking secrecy or other contractual or professional confidentiality obligations applicable to us. We process personal data for the following purposes (hereinafter the “Purposes”) and legal bases:

(a) for the performance of contractual obligations

We collect and process personal data as necessary for the performance of a contract to which you or a related person is a party, or to carry out pre-contractual measures that occur as part of a request, which includes in particular the following processing operations: (i) opening and management of an account and business relationship with us, (ii) the execution of transactions, (iii) the provision of investment advice as well as (iv) asset and portfolio management and the distribution of financial products.

(b) for compliance with a legal obligation or in the public interest

As a bank, we are subject to various legal obligations which require us to process and collect personal data, including in relation to accounting requirements, the provision of information about products and services, the prevention of money laundering activities, bribery, corruption, tax frauds as well as other frauds and crimes, the recording of phone conversations, the satisfaction of any requirements of cooperation with, or reporting to, any competent public prosecution, supervisory, administrative or tax authority or court, as well as the assessment and management of risks.

(c) for the purposes of safeguarding legitimate interests

When necessary, we process your personal data for the purpose of the legitimate interests pursued by us or a third party, if such processing does not unduly affect your interest or fundamental rights and freedoms. Examples include (a) the development of our business relationship with you (b) measures for the security of our properties and systems (c) the recording of phone conversations to verify instructions, improve the quality of our services or to safeguard our rights (d) the exercise or defense of actual or potential legal claims, or the conduct of investigations or similar proceedings (e) review and improvement of our internal processes and organization, including for the purpose of risk management (f) the evaluation of certain characteristics of data subject on the basis of automatic processing of personal data (profiling).

(d) on the basis of your consent

To the extent that the processing of your personal data requires that you give your prior consent thereto, we will ask for your consent in due time. Any consent granted may be revoked at any time. Please be advised that the revocation of your consent shall only have effect for the future. Any processing that was carried out prior to the revocation shall not be affected thereby.

The provision of personal data may be mandatory, for instance in connection with compliance with applicable laws and regulations. If the required data are not provided, this may preclude us from establishing or pursuing a business relationship or from rendering services to you.