Privacy Policy

1. Data We Collect and How

We collect personal data that you voluntarily provide to us – such as your name, contact details, professional information, and investor classification details – when you correspond with us, submit an enquiry via our website, attend an event, or engage with us in a business context. We may also receive limited information from publicly available sources such as professional registers, regulatory databases, or LinkedIn, in order to confirm your professional position. Where required by law, we collect identity documentation for AML and KYC purposes.

When you visit our website, we automatically collect certain technical data (such as your IP address, browser type, and device) and usage data (pages visited, navigation paths) through server logs and analytics tools including Google Analytics. Please refer to Section 5 on cookies for further details.

 

2. How and Why We Use Your Data

We use personal data to respond to your enquiries, manage our business relationship with you, and send you relevant information about the funds we distribute – including fund updates, market commentary, and event invitations. Where required by law, we use your data to verify your identity, assess your investor classification under FinSA, and conduct AML, KYC, and sanctions screening. We also use data to operate and improve our website and to comply with applicable legal and regulatory obligations.

We process personal data on the basis of: (i) the performance of or preparation for a contractual relationship; (ii) compliance with a legal obligation, including AML/GwG and FinSA requirements; (iii) our legitimate interest in maintaining a database of professional investor contacts and communicating with them about fund opportunities relevant to their role; and (iv) your consent, where given, for example for marketing communications – which you may withdraw at any time by unsubscribing.

 

3. Sharing and Storage of Your Data

We do not sell your personal data. We may share it, to the extent necessary, with technical service providers (such as hosting, email, and website analytics providers) who act under data processing agreements, with the fund managers whose funds we distribute for introduction purposes, with professional advisors bound by confidentiality, and with regulatory authorities including FINMA and MROS where required by law. Personal data is primarily stored and processed in Switzerland. Where service providers process data outside Switzerland or the EEA, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses or equivalent measures approved by Swiss authorities.

We retain personal data for as long as is necessary for the purposes described above, and in any event for the periods required by applicable law – including a minimum of ten years for AML/KYC documentation under the GwG, and ten years for contractual records under the Swiss Code of Obligations. Contact and communications data is retained for as long as you remain an active business contact; you may unsubscribe at any time. Website analytics data is retained for up to twenty-six months. Data is securely deleted or anonymised once no longer required.

 

4. Security

We implement appropriate technical and organisational measures to protect your personal data against loss, manipulation, and unauthorised access, including encrypted data transmission and access controls. While every reasonable precaution is taken, no electronic system is completely secure. In the event of a data breach posing a material risk to your rights, we will notify you and the relevant supervisory authority without undue delay.

 

5. Cookies

Our website uses cookies to ensure proper technical functionality and, where you consent, to collect aggregated usage analytics via Google Analytics. You may manage or withdraw your cookie preferences at any time via the cookie settings on this website. Functional cookies necessary for the operation of the site are placed on the basis of our legitimate interest; analytics cookies require your consent.

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6. Your Rights and Contact

Under the nFADP and, where applicable, the GDPR, you have the right to access, correct, delete, or restrict the processing of your personal data, to object to processing based on legitimate interests, to receive your data in portable form, and to withdraw consent at any time. You also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch) or, where applicable, the competent supervisory authority in your EU/EEA member state.

To exercise any of these rights or for any questions about how we handle your data, please contact us at info@21capitaladvisors.com or at the address above. We will respond within thirty (30) days. This Privacy Policy may be updated from time to time; the current version is always available on this website.

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