DATA PROTECTION STATEMENT
 

(For the legally binding version, please refer to the German version. This English translation is only for the purpose of convenience.)

• General: This data protection declaration provides information on how MaieutCapital AG processes your personal data. "Personal data" means all information relating to a specific or identifiable natural or legal person. "Processing" means any handling of personal data, regardless of the means and procedures used, in particular the procurement, storage, use, modification, disclosure, archiving, deletion or destruction of personal data. There are further regulations for certain data processing, e.g. in the context of contract conclusions with MaieutCapital AG. These can be found in the relevant contracts.
• Data Security: MaieutCapital AG undertakes measures to protect personal data and privacy in accordance with the applicable laws, in particular the Data Protection Act (DSG). For this purpose, MaieutCapital AG takes various technical and organizational security measures (e.g. access restrictions, personalized passwords as well as encryption and authentication technologies etc.).
• Data Used: MaieutCapital AG processes and stores data that it receives from the business relationship with you. This includes, among other things, personal, identifying data (e.g. name, address, telephone numbers, etc.). or data which, in connection with other information, leads to such identification (e.g. account and securities account numbers). Furthermore, data is processed that is related to the legal requirements of the Money Laundering Act and the resulting regulations and guidelines as well as other regulations that MaieutCapital AG has to meet, e.g. due to legal requirements or its FINMA subordination (e.g. FINMA circular). This also includes all detailed information that allows an assessment of your financial situation and an assessment of your risk capacity and willingness to take risks. In addition to data that MaieutCapital AG receives directly from you, it also obtains and processes data about you from publicly accessible sources (e.g. Internet, debtor directories, commercial register, press, etc.). The following personal data are processed: • Personal details (name, address and other contact details, date of birth, place of birth, nationality) • Legitimation and authentication data (e.g. ID data) • Order data (e.g. asset management contract) • Data from the fulfillment of contractual obligations (e.g. reports, statistics and evaluations from previous years) • Information about your financial situation (e.g. information about the origin of assets) • Documentation data (e.g. recordings of conversations or telephone calls with you)
• Purposes for which MaieutCapital AG Uses Your Data: a) To fulfill our obligations within the framework of an asset management mandate The processing of your data allows MaieutCapital AG to provide the services contractually agreed with you. Your data will be used for needs analysis, asset management, support and initiating transactions. b) As part of the balancing of interests In order to protect legitimate self-interests or interests of third parties, MaieutCapital AG also processes data for the following purposes: • Review and optimization of procedures for needs analysis • Risk control • Assertion of legal claims and defense in the event of any disputes • Prevention and investigation of criminal offenses c) Due to legal requirements or in the public interest MaieutCapital AG is subject to various legal obligations (e.g. Money Laundering Act, FINMA ordinances and circulars, tax laws, etc.) as well as regulatory requirements. The purposes of processing include, among other things, the prevention of fraud and money laundering and the assessment and management of risks.
• Access by Service Providers to your Data and Where it is Processed: Your data is accessed to fulfill the contractual and legal obligations of MaieutCapital AG. For the same purpose, service providers (processing service providers, IT service providers) commissioned by MaieutCapital AG in Switzerland can process your data. Data that is particularly worthy of protection (e.g. information about personal circumstances and the origin of assets) are not processed by service providers/third parties. Our direct supervisory bodies (FINMA, supervisory organization, auditors) are an exception. MaieutCapital AG does not transmit any data abroad for processing; data transmission abroad would require your express consent.
• Retention Period of your Data: MaieutCapital AG processes your data as long as it is necessary for the fulfillment of contractual and legal obligations, in particular in the course of an asset management mandate. In order to fulfill legal storage obligations and to ensure any information obligations, the data will also be stored beyond the point in time at which contractually defined services (e.g. as part of an asset management mandate) are provided for you. This procedure also serves, among other things, to document and, if necessary, prove that MaieutCapital AG is proceeding correctly in accordance with the contractual, supervisory and legal regulations.
• Your Data Protection Rights: You can request information from MaieutCapital AG as to whether personal data about you is being processed. You have the right to object, restriction of processing and, if applicable, the right to data portability. Incorrect data can be corrected. In addition, the deletion of personal data can be requested, provided that there are no legal or regulatory provisions (e.g. legal storage obligations for business-relevant data) or technical hurdles to the contrary. The deletion of data can result in MaieutCapital AG no longer being able to provide certain services. In addition, where applicable, there is a right of appeal to a competent authority. Where MaieutCapital AG processes personal data based on consent, this consent can be revoked at any time. In order to support MaieutCapital AG in answering your request, we ask for a corresponding, understandable message. We will examine and respond to the concerns within a reasonable period of time.
• Information You Must Provide: MaieutCapital AG needs the data from you that is necessary for the establishment and implementation of a business relationship, in particular an asset management mandate, and the fulfillment of the associated contractual and legal obligations. Without this data, MaieutCapital AG is unable to conclude or execute a management contract with you. In particular, MaieutCapital AG is obliged, in accordance with the regulations on combating money laundering and terrorist financing, to identify you using your ID document before entering into a business relationship and to collect and record your address, nationality, name, place of birth, date of birth and ID data. In order for MaieutCapital AG to comply with these regulations, you are obliged to provide it with the necessary information. Should this data change in the course of the business relationship, you are obliged to inform MaieutCapital AG about it. If you do not provide the required information, it will not be possible to establish or continue a business relationship with you.
• Further Information on the Processing of Data at MaieutCapital AG: As part of our data processing processes, there is no automated decision-making regarding the establishment and implementation of a business relationship. Biometric data from you (e.g. fingerprint or another biometric identification feature) is particularly worthy of protection and is neither recorded nor processed by us.
• Website Use and Cookie Policy: When a person visits the MaieutCapital AG websites, the webserver might register details of the visit (e.g. the website from which the visit is made, the IP address of the visitor, the contents of the MaieutCapital AG websites that are accessed, including the date and duration of the visit). Such tracking data might be used to optimize the MaieutCapital AG websites and provide information on how the visitor finds out about and uses the products, services and offers of MaieutCapital AG. However, as a rule, they do not allow any conclusions to be drawn about the identity of the visitor. In this respect, no personal data is processed. However, if the visitor makes personal data available, for example by filling out a registration form or message field for newsletters etc., MaieutCapital AG can use this data in addition to the purposes mentioned under Section 4, in particular for the following: • for customer and user administration; • to inform the visitor about services and products; • for marketing purposes (e.g. sending newsletters); • for technical "hosting" and further development of the MaieutCapital AG websites. When visiting MaieutCapital AG websites, the visitor's data is transported via the Internet, which is an open network accessible to everyone. Data transmitted via electronic media (incl. e-mail) cannot be effectively protected against access by third parties. This entails, among other things, the risk that the data will be disclosed or its content changed, that the identity of the sender (e.g. e-mail) as well as the content of the message will be pretended or manipulated in some other way by unauthorized persons, that viruses will be released, that there are technical transmission errors, delays or interruptions, data is sent abroad uncontrolled, where lower data protection requirements may apply than in Switzerland, etc. By using the MaieutCapital AG website, a visitor confirms his/her express consent to the present data protection declaration and the risks mentioned. In addition, a visitor agrees to the use of cookies by using the MaieutCapital AG website. Cookies are small files that are stored on the visitor's computer in order to track the relevant website visit and navigation between different pages and/or to save settings (e.g. selected language). Cookies are used to collect statistical data about the frequency and time of visits to individual sections of the website and help to design customized, useful and user-friendly websites. The visitor can decide against the use of cookies at any time by deleting the cookies set by the MaieutCapital AG website. Deletion is possible via the settings in the visitor's Internet browser. Occasionally, MaieutCapital AG might use third party components (such as plug-ins) to improve user experience and online advertising campaigns. These components may also use cookies for similar purposes. Neither these third parties nor MaieutCapital AG have access to the data collected by the other through cookies. Finally, MaieutCapital AG also uses cookies as part of MaieutCapital AG's advertisements on third-party websites with which MaieutCapital AG maintains marketing relationships. If third parties collect anonymous information about the use of MaieutCapital AG websites and other websites, MaieutCapital AG can use this anonymous data to improve the effectiveness of advertising. This title of the present data protection declaration only applies to data that MaieutCapital AG receives as a result of using MaieutCapital AG websites. It is not applicable to third-party websites, even if the visitor accesses them via links on a MaieutCapital AG website. MaieutCapital AG has no influence on the content and data protection handling of third-party websites and cannot assume any responsibility for them.
• Inspection of the Current Data Protection Declaration of MaieutCapital AG: This data protection declaration can be adapted at any time in compliance with the relevant regulations. You can view the currently valid version at www.maieutcapital.ch.
• Contacting MaieutCapital AG: If you have any questions about the handling of your data, we will be happy to answer them using the details given in the contact section.
• Zurich, August 2023