“Client” means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Schroders.
“Schroders”, “we” or “us” means Schroder Investment Management (Switzerland) AG with its registered office at Central 2, CH-8001 Zurich, Switzerland or any of its subsidiaries or affiliates, details of which can be found on the Schroders website. Together these are referred to as the Schroders Group.
“Schroders Websites” means the websites operated by Schroders.
“Schroders Products and Services” means the products and services that we offer to our Clients, including through our related support, mobile or cloud-based services
“Personal Data” means any data which relates to a person who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Schroders (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of a person.
“You” means each person to whom this notice is addressed, who may be:
(a) a Client or prospective Client of ours;
(b) a visitor to the Schroders website; or
(c) an employee, director, officer or representative of another organisation with which we have a business relationship.
TABLE OF CONTENT
1. BACKGROUND INFORMATION
(1.1) Schroders collects and uses certain Personal Data. Schroders is responsible for ensuring that it uses that Personal Data in compliance with applicable data protection laws.
(1.2) At Schroders, we respect your privacy and we are committed to keeping your Personal Data secure.
2. OVERVIEW OF CIRCUMSTANCES IN WHICH WE HANDLE YOUR PERSONAL DATA
(2.1) Schroders gathers information about you in the following ways:
a) Information we receive in the course of providing products or services to you. This may be provided directly from you or from other parties, such as, for example, providers of ‘know your client’ and anti-money laundering services which we sometimes use to help us meet our legal obligations.
We may combine the personal and other data we collect directly from you with information collected from or about you in other contexts, such as from our Web Sites or obtained from third parties.
3. THE TYPES OF PERSONAL DATA WE COLLECT
(3.1) Many of the products or services offered by Schroders require us to obtain and process Personal Data, such as:
- Information that you provide to Schroders. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of Personal Data we might ask for. Such information may include:
- basic Personal Data such as first name; family name; national insurance number; email address; phone number; address (including city postcode and country); occupation and job title; bank details; ID documentation; date of birth; life events and family information;
- sensitive Personal Data, which may be included in information we handle about your nationality, place of birth, health related information, disability status, or details of political affiliations, or records of criminal offences and court proceedings.
- Information that we collect or generate about you. This may include:
- files that we may produce as a record of our relationship with our Clients and prospective Clients, including contact history; and
- any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements; or
- any Personal Data that we obtain in relation to your use of Schroders Websites (but this will be limited to the situations where users make themselves known by establishing a secure, authenticated session).
- Information we obtain from other sources. Some of this Personal Data may be sensitive and may include:
- information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as criminal registers; and other publicly accessible sources;
- - information provided to us by independent financial advisors (IFAs), other professional advisers, product providers, events organisers, other agents and/or representatives, industry databases and other business intelligence tools Schroders subscribes to; and
- information obtained from sanctions checking and background screening service providers.
4. HOW WE USE YOUR INFORMATION
(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- to allow Clients and prospective Clients to use and access Schroders Products and Services;
- to assess Client and prospective Client applications or contracts for Schroders Products and Services;
- to set up / on-board prospective Clients to use Schroders Products and Services;
- to keep our records up to date;
- to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
- - to protect our premises from unauthorised access or use, or any unlawful activity;
- to administer or maintain IT systems in order to uphold standards of service;
- for ongoing review and improvement of the information provided on Schroders Websites to make them user friendly and prevent potential disruptions or cyber attacks;
- to understand feedback on Schroders Products and Services and to help provide more information on the use of those products and services quickly and easily;
- to communicate with and better understand the interests of Clients and prospective Clients in order to provide services or targeted information about Schroders and other Schroders Products and Services;
- to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests and learn more about our Clients and prospective Clients in order to develop, improve and manage the products and services we can offer;
- for the management and administration of our business;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
- for the administration and maintenance of databases storing your Personal Data.
(4.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:
- we are performing our contractual obligations;
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
- we have obtained your consent;
- the use of your Personal Data as described is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures;
- enabling quick and easy access to information on Schroders Products and Services.
5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
(5.1) We may share your Personal Data within the Schroders Group for the purposes described above.
(5.2) We may also share your Personal Data outside of the Schroders Group as further described below:
- with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
- with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);
- with third party agents and contractors for the purposes of them providing services both to us (for example, Schroders’ accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) and to Clients or prospective Clients. These third parties will be subject to appropriate data protection obligations;
- with any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
- where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;
- to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights; and
- if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.
(5.3) In the individual case, the disclosure to third parties may be limited or prohibited by a statutory or contractual duty of confidentiality.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
(6.1) Schroders is a global business with Clients and operations around the world. As a result, we collect and transfer Personal Data within companies part of the Schroders Group, and from time to time to our third party service providers, on a global basis. That means that we may transfer your Personal Data to locations outside of your country.
(6.2) Where we transfer your Personal Data to another country we ensure that it will be protected and transferred in a manner consistent with legal requirements. In relation to data transferred outside of Switzerland, for example this may be done in one of the following ways:
- the country to which we send your Personal Data is approved by the Federal Data Protection and Information Commissioner FDPIC (the “Approved Country”) as offering an adequate level of protection for Personal Data;
- the recipient signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your Personal Data;
- where the recipient is located in the US, it might be a certified member of the Swiss-US Privacy Shield scheme; or
- in some limited circumstances the law may permit us to otherwise transfer your Personal Data outside Switzerland and the Approved Countries.
(6.3) You can obtain more details of the protection given to your Personal Data when it is transferred outside Switzerland by contacting us as described in paragraph 12 below.
7. HOW WE SAFEGUARD YOUR PERSONAL DATA
(7.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value.
We ensure safe processing operations by operating and maintaining physical, electronic and procedural safeguards to guard your non-public personal information and we restrict access only to authorised personnel. The effectiveness of these safeguards is periodically tested.
We have extensive controls and mechanisms in place designed to detect, respond and recover in case of adverse events that may arise.
8. HOW LONG WE KEEP YOUR PERSONAL DATA
(8.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:
- our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
9. YOUR RIGHTS
(9.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Schroders;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
the right to lodge a complaint with the relevant data protection supervisory authority if you think that any of your rights have been infringed by us. (9.2) You can exercise your rights by contacting us using the details provided at paragraph 12 below.
10. SCHRODERS WEBSITES AND OTHER WEBSITES
We also gather anonymous information related to browsing habits of users through other categories of cookies with the purpose of managing and improving our Website.
12. QUESTIONS AND CONCERNS
To exercise your right to withdraw consent to receive electronic marketing communications at any time, please follow “unsubscribe” instructions found in such marketing materials.
Schroder Investment Management (Switzerland) AG
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns directly to your local courts or data protection supervisory authority competent for your jurisdiction.
If you raise a concern, we may:
- request additional details from you regarding your concerns and Personal Data limited to what is necessary for the purpose of authenticating you;
- engage or consult with other parties in order to investigate and resolve your issue (and these parties will receive and process information about you); and/or
- keep records of your request and any resolution of your issue,
in each case in accordance with our data protection and other legal obligations.