Data Privacy Notice

We strongly believe in protecting the confidentiality and security of your information.

This document sets out Woodman’s policy on the processing of personal and stipulates the key aspects of personal data processing. There are many different ways you may interact with our website and/or our services. We want you to be informed on how we are using your information and the ways in which you can protect your privacy.

Woodman places utmost emphasis on data protection and privacy. We strongly believe in protecting the confidentiality and security of your information. Woodman processes data in accordance with the provisions of the law, based on a contractual basis, a regulatory requirement or on prior consent. In principle, Woodman does collect and process data only if needed. Thus, data is processed for the fulfilment of contractual obligations, to preserve legitimate interests of Woodman, for its own purposes of for those prescribed by law and by regulatory requirements. Woodman does not collect or process data outside the context of business relationships with its clients.

Our Privacy Policy explains:

  1. Who we are
  2. The information and the type of personal data we collect
  3. Purpose of data processing
  4. Sources used to collect data
  5. Automated data processing
  6. Right to information of data subjects
  7. Contact for exercising rights or complaints
  8. Duration of storage
  9. Data security
  10. Outsourcing and sharing of information with third parties
  11. Status of this data privacy notice
  12. Other websites

1 Who we are

In this Privacy Notice when we say “we”, “us” or “Woodman” we mean Woodman Asset Management AG, a company registered in Switzerland, with offices in:

Woodman Asset Management AG
Poststrasse 26, 6300 Zug, Switzerland
+41 41 725 04 04

Woodman Asset Management AG (Genève branch)
Place du Grand-Mézel 1, 1211 Geneva 3, Switzerland

Woodman Asset Management AG (Lugano branch)
Via alla Sguancia 5, 6902 Lugano-Pazzallo, Switzerland

2 The information and the type of personal data we collect

In order to provide you with a service that meets your precise financial needs we obtain certain information about your personal and financial situation.

We collect the following information:

  • Personal information (e.g. name, address and other contact data, date and place of birth, nationality tax number, e-mail address, phone number, identification data).
  • Inventory data (e.g. information about an account, custody account, transactions and contracts executed, information about third parties who are affected by data processing, e.g. spouses, authorised representatives and consultants).
  • Data in connection with the fulfilment of contractual obligations, order and risk management data (e.g. stock exchange orders, risk and investment profile, data relating to remuneration).
  • Technical data (e.g. business numbers, IP addresses when using our website, internal and external identifications, access recording, cookies when using our website (for further details with regard to the use of cookies, please see our Cookies policy).
  • Marketing data (e.g. preferences, needs in relation to a business relationship).

Additionally, we may be provided with information from your relatives, parents or legal guardian, trustees of a trust you are connected with, trust beneficiaries, registered agent or introducer, insurers, banks custodians, credit reference agencies and other financial institutions.

3 Purpose of data processing

We collect and process personal data necessary to comply with our legal and regulatory obligations to which we are subject, such as:

  • Collect sufficient documentation on a financial services relationship or offer of financial products;
  • Comply with legal obligations relating to financial market regulations;
  • To conduct regular audits and/or reviews of the business relationship;
  • To cooperate with the competent authorities, supervisory authorities, administrative or criminal authorities and any other public authority (e.g. in the fight against money laundering and the financing of terrorism) (AML-CTF).
  • To prevent fraud, corruption and the provision of financial and other services to persons subject to international and national sanctions, in accordance with our internal money laundering procedures, and to retain AML reports and other reports required for detection purposes.
  • To monitor and control of risks;
  • To measure for business management and further development of services and products;
  • To communicate with you;
  • To market on Woodman’s services, information on news and insights about Woodman’s services (where you have consented to us doing so)
  • To provide information about the service offering and its verification;
  • To maintain our records and improve data accuracy;
  • To track interaction with our website and emails;
  • To assert legal claims and defence in case of legal disputes.

4 Sources used to collect data

We process the personal data which we get from our clients, e.g. account opening or in connection with contracts or products/services we offer.

So far it is allowed, we collect data from third parties (from publicly accessible sources, from authorities, SECO sanction lists, public registers, internet, media etc.). We also collect data connected to technical infrastructure when providing services to our clients.

5 Automated data processing

Woodman reserves the right to effect in the future automated processing of personal data where necessary, for example, to comply with legal and regulatory requirements imposed to combat money laundering, terrorist financing and asset-endangering crimes. Furthermore, client data may be processed, in particular, to identify important personal features of the client, to predict developments and prepare client profiles (e.g. risk profile). This serves in particular to verify and develop offers and optimise the provision of services.

6 Right to information of data subjects

Each data subject may request information from Woodman as to whether personal data about him/her is being processed. Within Woodman, the responsible Team to handle such requests is the Compliance Team.

Within the limits of applicable legislations and regulations, a data subject’s rights are the following:

  • Access to personal data and receipt of copy of personal data;
  • Correction of inaccurate personal data;
  • Prohibition or limitation of processing of personal data;
  • Requesting the deletion of personal data when processing is no longer necessary or when it is no longer appropriate.

7 Contact for exercising rights or complaints

If you have any questions related to data protection, please contact us under:

Woodman Asset Management AG
Mr Mirza Hasic
Poststrasse 26
6300 Zug

8 Duration of storage

Woodman only processes and stores personal data for as long as it is necessary for the fulfilment of and in accordance with contractual and legal obligations. Once these purposes or retention obligations, the data must be deleted or anonymised.

In certain cases, Woodman reserves the right to retain data for a longer period, in particular if required to do so by judicial measures or regulatory oversight, requiring the continued processing and retention of data.

9 Data security

Woodman takes appropriate technical and organisational security measures to ensure that personal data processed within the IT environment controlled by Woodman is protected against unauthorised access, misuse, loss and/or destruction (e.g. access restrictions, firewalls, personalised passwords as well as encryption and authentication technologies, employee training).

10 Outsourcing and sharing of information with third parties

Service providers such as IT-companies, logistics, advisory and consulting engaged by Woodman may also receive data for these purposes, provided they maintain professional secrecy. Any service providers processing personal data for this purpose on behalf of Woodman are selected very carefully in accordance with Woodman’s outsourcing policy. The service providers may only process personal data received by them to the same extent as Woodman does so itself and they are contractually required to safeguard the confidentiality, professional secrecy and security of data. Outsourcing by Woodman is performed in Compliance with the legal and regulatory requirements.

11 Status of this data privacy notice

Woodman reserves the right to change/amend this Data Privacy Notice from time to time without any announcement. It is a notice explaining what Woodman does, rather than a document binding Woodman or any other party contractually. If the Data Privacy Notice is part of a contract, the contracting party will be informed of relevant changes by appropriate means.

12 Other websites

Our website may link to other websites that have their own privacy policies. We are not responsible for the content of any other website, or how they deal with your information. We therefore recommend that you read the relevant third-party privacy policy before continuing to browse to any other website.

This Data Privacy Notice was last updated on 28 November 2023.