Arlas Advisors SARL web privacy policy

Arlas Advisors SARL values your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, share, and protect your personal data when you visit our website, www.arlascapital.com (the “Site”).

You may be required to provide certain personal information via this Website (e.g., your name, address, email address, telephone number, etc.). This information, including technical and navigation data, will be treated as confidential. We use this information for internal purposes to ensure compliance with our legal obligations. We may disclose this information to any governmental entity, regulatory authority, and/or court if required or permitted by applicable law.

We may also use tracking technology (e.g., cookies) to collect information that enables Arlas to understand how you use this Website. This technology helps us improve the Website. By using this Website, you expressly agree that, despite all precautions in place, the Internet network does not provide a fully secure means of communication of information, and you use the Internet at your own risk, releasing us from all liability, including interception by third parties of any information you provided on this Website.

At Arlas, protecting your privacy is important to us, and we take precautions to safeguard your information. After all, your relationship with us is built on trust, and our goal is to maintain that trust. This policy applies when we act as a data controller regarding your information, meaning we determine the purpose and means of processing that information. This policy establishes the basis on which we collect, store, and use your information.

Contents of this Privacy policy

Who we are and how to contact us
Information we collect
How and why we use information
Sharing your information
Your rights
Storage, transfers and retention
Data Protection & Security
Making changes to this information

Who we are and how to contact us

This is the Privacy Policy of Arlas Advisors Sarl (referred to as ‘Arlas’, ‘we’, ‘us’, or ‘our’ throughout this policy). Arlas encompasses Arlas Advisors Sarl and its partner companies, including Bolder Group (fund administrator) and other companies. As part of our ordinary business operations, Arlas collects and uses information, and it is our responsibility to ensure that this information is used in accordance with applicable data protection laws. This Privacy Policy governs how Arlas handles your information. It explains how your information may be stored and used by Arlas companies. Please note that information may be shared between Arlas and its international subsidiaries.

If you have any questions or concerns about our Privacy Policy or how we process your information, please contact us via email at privacy@arlascapital.com.

Information we collect

By “information,” we mean all the personal and financial information we collect, use, share, and store about you. Most of the information we collect is provided directly by you, either when you sign up online to receive information from us or when you become a client of ours.

The information we collect from you when you visit our website or request information includes personal contact information such as your first name, last name, position in the company, company name, company email address, business phone number, business address, city, postcode, and country. We also collect information about how you access and use our website or other digital services, such as your IP address, location, device and software used, pages visited, content viewed, and links clicked.

In addition to the above, we may also collect or generate additional information about you if you are or become a client of ours. This includes financial information associated with managing your account, investment details, regulatory requirements, information about people financially linked to you, new account information, employment status, proof of identification, and any other relevant information provided by you in correspondence.

There may be instances where we receive information about you from third parties, such as investment professionals, fraud protection agencies, background checks, and events featuring our products.

Please note that we use cookies to collect technical information about the services you use and how you use them. For more information on the cookies we use, please refer to our Cookies policy.

How and why we use information

We process your information in order to carry out investment activities, provide communications to you, meet our regulatory obligations, and for other legitimate purposes permitted by applicable law. Your information may be stored and processed by us in the following ways and for the following purposes (not an exhaustive list):

– Opening and managing your investment accounts, updating your records, and contacting you about your account.

– Understanding your needs and interests.

– Allowing you to use and access our website services.

– Communicating with you regarding any product or service you have requested or consented to, or any other situation where you have engaged us for information.
– Ensuring the security of your investments by obtaining and verifying instructions from you or your appointed agent.

– Notifying you about any changes to your investments and enabling you to exercise your rights.
– Investigating complaints, disputes, and concerns related to your investments and account activity.
– Verifying your identity, performing money laundering checks, and ensuring compliance with legal obligations.

– Maintaining a register of investors.

– Reviewing and improving website performance and personalization.

– Managing and administering our business.

– Complying with applicable laws, rules, regulations, and internal policies.

– Administering and maintaining databases.

-Profiling and automated decision-making relevant to your investments.

– Marketing communications (where lawful and with your consent).

– Conducting fraud protection searches.

– Handling your requests to exercise your data protection rights.

Whenever we use information, we ensure compliance with applicable laws. We rely on one or more of the following legal reasons:

– Contract performance: processing information necessary to deliver your account, product, or service.

– Legal obligation: processing information required by law to verify your identity.
– Legitimate interest: using your information where the benefits outweigh your interests or legal rights.

– Consent: obtaining your consent in specific cases or when required by law (you have the right to change or withdraw your consent).

Sharing your information

We may share your information with other companies within the Arlas group and its partner companies, both in Switzerland and internationally, for the purposes mentioned above. In addition, we may also share your information outside of Arlas under certain circumstances.

One such circumstance is when we are legally obligated to do so. This includes situations where we are required by applicable law, a governmental body, or a law enforcement agency to share information. We may also share information for crime prevention purposes, such as fraud protection. Furthermore, we may share information in connection with legal proceedings or to establish or defend our legal rights.

We may also share your information with third-party entities that we have a relationship with. This includes financial institutions like investment advisors, administrators, or compliance advisors. These third parties will be bound by appropriate data protection obligations and will only use your information as described in our Privacy Policy.

In some cases, we may share your information with someone else if you have requested us to do so. For example, if you engage the services of a professional advisor and ask us to provide information about your account to them. We may also share your information if we have obtained your consent. If we share information in a manner that is not permitted or described above, we will give you the option to opt into such sharing, and you can choose to instruct us not to share the information.

If we sell part or all of our business or assets, we may need to disclose your information to a potential buyer for due diligence purposes. If we are acquired by a third party, the information we hold about you will be disclosed to the buyer.

Your rights

You have the following rights under data protection laws, and in most cases, you can exercise them free of charge. However, if your investment is through one of our non-Swiss companies, you may not be entitled to all of these rights.

  • The right to be informed about the processing of your information.
  • The right to have your information corrected if it is inaccurate or incomplete.
  • The right to object to or restrict the processing of your information. Please note that there may be circumstances where we can legally refuse your request.
  • The right to withdraw your consent to the processing of your information at any time. However, we may still be entitled to process your information if we have another legitimate reason for doing so.
  • The right to have your information erased in certain circumstances. Please note that there may be circumstances where we can legally retain your information.
  • The right to request access to your information and to obtain information about how we process it.
  • The right to move, copy, or transfer your information.
  • The right to receive some information in a structured, commonly used, and machine-readable format, and/or request that we transmit that data to a third party where technically feasible. Please note that this right only applies to information you have provided directly to Arlas and may not always apply.
  • The right to lodge a complaint with the relevant data protection regulator if you believe any of your rights have been infringed by us.
  • The right to be informed of how your information is used in relation to automated decision making that has a legal effect on you or significantly affects you.

Please note that if you withdraw your consent for the future processing of your information, we may be unable to send you certain marketing communications or information regarding events sponsored by Arlas. Additionally, when we send you marketing materials, you will always have the option to unsubscribe or opt out of receiving further marketing from us.

If you have any questions or concerns regarding our Privacy Policy or how we process your information, please contact us via email at privacy@Arlascapital.com.

Storage, transfers and retention

Arlas Advisors SARL stores your personal data on secure servers located in Switzerland. These servers are protected by physical and technical security measures to prevent unauthorized access, use, disclosure, alteration, and destruction.

Arlas Advisors SARL may transfer your personal data to third-party service providers who assist us in processing your orders, providing you with our products and services, and improving our website and services. These service providers are located in Switzerland and other European Union countries, in compliance with the nFADP and GDPR regulations. Arlas Advisors SARL takes steps to ensure that your personal data is treated securely and in accordance with this privacy policy, regardless of where it is stored or transferred.

Arlas Advisors SARL will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with our legal, tax, and accounting obligations.

Data Protection & Security

Arlas Advisors SARL takes measures to protect your personal data against unauthorized access, use, disclosure, alteration and destruction. These measures include:

  • Restricted access to your personal data by our employees and contractors
  • Use of security technology, such as encryption and firewalls
  • Implementing security procedures to protect your personal data
  • Data breach monitoring

We have physical, administrative, procedural and technical safeguards in place to protect your information from unauthorized access, use or disclosure. We also contractually require that our third-party service providers protect such information in accordance with the standard required in the EEA. We regularly adapt these controls to respond to changing requirements and advances in technology.

As a condition of employment, Arlas employees are required to follow all applicable laws and regulations, including data protection laws. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential client information by an Arlas employee is prohibited and may result in disciplinary measures.

Making changes to this information

Arlas Advisors SARL may change this privacy policy from time to time. If we make any material changes, we will notify you via our website or by email. We encourage you to review this privacy policy periodically to stay informed about how we collect, use and protect your personal data.

If you have any questions about this privacy policy, please contact us at privacy@arlascapital.com.

Date of last version of the web privacy policy: August 7, 2023