DATA PRIVACY NOTICE

Your privacy is very important to us. This Privacy Notice is provided by MSM Investment Advisors SA (herein “MSM”, “we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

MSM is incorporated in Geneva, Switzerland and is authorised by the Swiss regulator, FINMA. This Privacy Notice is issued in respect of the Swiss Federal Act on Data Protection (“FDPA”) and to the extent is it relevant to your location, the EU General Data Protection Regulation (“GDPR”).

How we collect information about you

We collect information about you when you engage with us for any of the services provided by MSM to include, but not limited to, discretionary asset management, investment advice, financial planning and family office services. This information will relate to your personal and financial circumstances and is intended to ensure that we provide you with a service that is appropriate to your needs.

We may also collect information from you in other circumstances, for example when you provide feedback to us, apply for employment, subscribe to marketing or information communications or visit our website.

What information do we collect about you?

The nature of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected.

Such personal data may include names, residential addresses or other contact details, signatures, nationality, date and place of birth, tax identification number, identification documents, bank account details and statements, information about assets or net worth, credit history, criminal and administrative offences, source of funds and wealth or any other such information as deemed necessary to fulfil our contractual, legal or regulatory obligations.

Why do we need to collect and use your personal data?

The primary basis that we intend to collect and process your data is for the performance of the services in which were are contracted with you. The information that we collect about you is essential for us to carry out the services that you require from us. Without collecting your personal data we would not be able to fulfil our legal and regulatory obligations.

We also collect, and process data as required by law and our financial regulators in relation to compliance with legal and regulatory obligations to which we are subject.

How will we use the information about you?

We will only use your personal data where we have a lawful basis for doing so. The primary use of your data is to perform our contract with you and to comply with legal and regulatory requirements.

Please note that MSM treats your data with utmost care and consideration and is subject to certain confidentiality and secrecy obligations, arising under Swiss data protection, contract, professional or banking secrecy.

Who might we share your information with?

Your data may be stored by approved third party service providers but will not otherwise be shared with third parties unless we are legally required to do so. MSM does not sell or rent your data to any third parties.

In regard to our legal obligations, we may be required to disclose or make accessible your personal data to the following non-exhaustive recipients, provided it is legally or otherwise required:

• Public entities and institutions (for example Swiss National Bank, FINMA, other financial authorities and supervisory bodies, criminal prosecution authorities)
• External Auditors

We may also provide your details to third parties in connection with fulfilling our contract with you, this may include parties that we engage for professional compliance, accountancy or legal services as well as product provider and custodian banks and platforms that we use to arrange financial products for you.

How do we ensure the safety of personal data?

MSM implements internal technical and organisational measures to keep personal data safe and secure which may include encryption, anonymization, access limitations and physical security measures.

MSM requires its employees and any third parties to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of personal data.

Where third parties are involved in processing your data, we have contracts in place with them in regard to data protection.

How long do we keep hold of your information?

We will generally retain your personal information for as long as necessary in relation to the purpose for which it was collected and in accordance with applicable laws and regulations (for example, data collected for AML purposes must be retained for 10 years following the termination of the business relationship).

You have the right to request deletion of your personal data. We'll comply with this request, subject to the restrictions of our regulatory or legal obligations as noted above.

How can I access the information you hold about me?

You have the right, subject to applicable local data protection legislation, to request a copy of the information that we hold about you. If you'd like a copy of some or all of your personal information, please email or write to us using the contact details noted below.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing and communication

MSM may hold your details for marketing and communication purposes, for example to provide you with our market updates, research data or investment insights. This information may be sent by email or accessed via our website.

We do not share your information held for marketing purposes with any third parties.

In general the receipt of such information will have been initiated by yourself. You have the right, at any time, to stop us from contacting you for whatever reason, by sending us a request by email.

MSM Website

Cookies

The MSM websites use cookies, which are saved on the User's computer. These enable MSM to retrace the User's visit and to save their preferences if they switch pages or revisit the website at a later date.

Cookies particularly serve the following purposes:

• save the User's preferred language and country settings
• perform a statistical analysis of the number of users and of their usage habits
• improve the loading speed of the individual pages

The User can control cookie specifications via their browser settings. The relevant browser options and instructions on use can generally be found in the browser manual or help file. If the User rejects, blocks or deactivates cookies, this may restrict the availability of the services offered via the website. In addition, parts of the website may not work correctly under certain circumstances.

Web analysis

MSM analyses how its websites are used with the help of third-party analysis tools, such as Google Analytics (hereinafter «Analysis Service Providers»). MSM assumes no responsibility or liability for any data processed by Analysis Service Providers.

Google Analytics

Google Analytics, a web-based analysis service by Google Inc. (hereinafter “Google”), uses cookies, which are saved on the User's computer. The information generated by the cookie concerning their visit is usually sent to and stored on a Google server in the USA. If MSM activates IP anonymization for this website, Google shortens the User's IP address within Member States of the European Union or in other partner states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and anonymized there. Google evaluates the information that has been saved on behalf of Google for the purpose of compiling reports on the website's usage and in order to provide other associated services for MSM. Google may combine the IP address transmitted from the User's browser by Google Analytics with other data that has been collected.

Detailed information on this can be found at http://tools.google.com/dlpage/gaoptout?hl=en and http://www.google.com/intl/en/analytics/privacyoverview.html (general information on Google Analytics and data protection).

Social Media Buttons

Functions (plugins) of third-party providers or social media platforms (Facebook, Twitter, Google+, etc.) are embedded into the websites of MSM. These plugins enable the User to share content on the social networks mentioned. The interfaces are deactivated by default when the website is accessed. This means that no Personal Data is transmitted to the respective third-party providers without intervention on the part of the User. Once the User has activated the interfaces, data (incl. also Personal Data) is automatically transmitted to the relevant third-party providers by the plug-ins. If the User is simultaneously logged in to the network of the respective third-party provider when they visit the website, the third-party provider can assign the visit to the User's network account. MSM has no influence on this. The purpose and scope of such a form of data collection and the further processing and usage of Personal Data are outlined in the data protection guidelines of the individual social networks. Users can also obtain information there on rights and settings options in relation to protecting their privacy.

Other websites

Currently our website does not contain links to other websites however this may change in the future. Any access to, and use of such third party websites, is not governed by this Privacy Notice, but is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Changes to our privacy policy

We keep our privacy policy under regular review and will update this privacy notice as required.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you by email at contact@msmiam.ch.