Privacy Policy

This data protection/privacy policy (the “Policy”) needs to be read in conjunction with the Terms of Use. Capitalized terms shall have the same meaning as defined therein, unless otherwise defined in this Policy.
The Website may include External Links that are not operated or controlled by Alprime. This Policy only applies to the Website and Alprime is not responsible for the content or the privacy practises of third party websites.
The terms of this Policy are without prejudice to any contractual terms you may enter into with us, which will take precedence over the terms of this Policy.

Alprime accepts no responsibility or liability for the security of your data whilst in transit via the Internet to us. In order to protect your privacy we would like to remind you that you may choose another means of communication with us, where you deem it appropriate.

Alprime does not collect personal data relating to you from the Website except when specifically and knowingly provided by you.
Alprime will act as a Data Controller in respect of Personal Data provided to Alprime by you. Personal Data is processed by Alprime for the following purposes:

Purpose of Processing	Lawful Basis under GDPR
To carry out services to investors and potential investors.	As necessary and proportionate in Alprime’s legitimate business interests (per Art. 6(1)(f) GDPR).
For any other specific purposes where the individual has given specific and informed consent based on an appropriate notice.	Based on Shareholder consent (per Art. 6(1)(a) GDPR).

Alprime will engage certain service providers to perform certain services on its behalf which may involve the Processing of Personal Data. To the extent that such Processing is undertaken based on the instructions of Alprime and gives rise to a Data Controller and Data Processor relationship, Alprime will ensure that such relationship is governed by a Contract which includes the data protection provisions prescribed by Data Protection Law.

You acknowledge and agree to “cookies” technology being used in certain instances to provide you with information tailored to your needs. A cookie is an information file stored on a computer’s hard drive to ensure that it is recognised again on future visits to the Website. You acknowledge that your browser can be set up to notify you about the receipt of cookies. You can withdraw your consent with regard to future use at any time by blocking the receipt of cookies in your browser settings or by unsubscribing via email at dataprotection@alprimecapital.com. Your data will not at any time be linked to the personal data recorded at Alprime.

The Website may feature retargeting technology, which would be used to make our Internet presence more interesting for you. This technology makes it possible to show advertising on other websites to users that have already shown an interest in our funds or products.

Opt-in process: In addition to one-to-one email messages from client managers or other contacts you have at Alprime, you may also be subscribed to our centralised mailing lists. This will only happen if your explicit permission has been given, which will have been expressed in writing or verbally.

Opt-out process: You can unsubscribe from our mailings at any point. Every email has several options to unsubscribe at the end of the message. Alternatively, you can ask your Alprime contact or send an email to dataprotection@alprimecapital.com to remove you from specific mailings.

Types of centralised mailings: You may receive fund reporting mailings (e.g. fund fact sheets, holding reports, special reports, performance updates) if you are a client of Alprime, invested in an Alprime fund or upon request. From time to time, we may also send you marketing or event-related messages.

Tracking: We may track recipient response to the mailings we send out. This data will be collected and stored securely, and may be used to compile statistics on an aggregated and individual basis. We will only use this information to improve the quality and relevance of our email communications. If you wish to opt-out from tracking, please send us an email with your opt-out from tracking request or ask your Alprime contact or send an email to dataprotection@alprimecapital.com to remove you from the relevant list.
Tracking data storage: All data collected via email communications will be stored in accordance with applicable legal and regulatory requirements.

Alprime undertakes to hold any Personal Data in confidence and in accordance with the Data Protection Law. Accordingly, Alprime has technical and organisational measures in place to protect Personal Data from unlawful or unauthorised destruction, loss, change, disclosure, acquisition or access. Personal Data is held securely using a range of security measures including, as appropriate, physical measures such as locked filing cabinets, IT measures such as encryption, and restricted access through approvals and passwords. We will take all reasonable steps in order not to allow your personal data to be seen by any third parties other than those, which have been engaged by Alprime to provide services to you. We will only disclose your data to other third parties, if compelled to do so for legal or regulatory purposes. We will not supply any information about you to anyone unless we believe it is lawful to do so. We may store data in locations other than your country of residence. In such cases Alprime will endeavour to ensure that there are adequate levels of protection for your data taking into account applicable legal and regulatory requirements, including those relating to data protection.

The GDPR obliges Data Controllers to notify the Data Protection Commission and affected data subjects in the case of certain types of personal data security breaches. Any Data Breaches identified in respect of Personal Data controlled by Alprime will be dealt with in accordance with Data Protection Law and Alprime’s Data Breach Procedure.

Data Protection Law provides certain rights in your favour. The rights in question are as follows:

1. the right of a data subject to receive detailed information on the processing (by virtue of the transparency obligations on the Data Controller);
2. the right of access to Personal Data;
3. the right to amend and rectify any inaccuracies in Personal Data;
4. the right to erase Personal Data (right to be forgotten);
5. the right of data portability;
6. the right to restrict Processing;
7. the right to object to Processing; and
8. the right to object to automated decision making, including profiling.

In order to claim one of the above rights, please ask your Alprime contact or send an email to dataprotection@alprimecapital.com.

We will keep Personal Data for:

1. the duration of the investment by an investor in Alprime’s funds or products and afterwards in accordance with the Alprime’s legal and regulatory obligations and any applicable record retention policy of Alprime;
2. such period as may be deemed by us to be necessary in light of applicable statutory limitation periods; and
3. otherwise only for as long as the retention of such Personal Data is deemed necessary for the purposes for which that Personal Data are Processed (as described in this Privacy Policy).

Further information about this Privacy Policy and/or the Processing of Personal Data by or on behalf of Alprime may be made available if necessary by contacting dataprotection@alprimecapital.com.

We reserve the right to amend this Policy without giving prior notification. We therefore advise you to check this page on a regular basis.

In this Privacy Policy, the terms below have the following meaning:

“Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.

“Data Controller” means the entity which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Data Processor” means the party that Processes Personal Data on behalf of the Data Controller.

“Data Protection Law” means the Swiss Federal Act on Data Protection (1993), the EU Data Protection Directive 95/46/EC, the EU ePrivacy Directive 2002/58/EC (as amended), and any relevant transposition of, or successor or replacement to, those laws, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the and any other laws which apply to Alprime in relation to the Processing of Personal Data.

“Personal Data” is any information relating to a living individual which allows the identification of that individual. Personal Data can include:
a name, an identification number;
details about an individual’s location; or
any other information that is specific to that individual.

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “Process” and “Processing” are interpreted accordingly.

12 — Data Protection Statement (Privacy Notice)

Alprime Capital AG (“Alprime”), within the framework of its business activities, processes information and personal data about you and/or persons connected to you (the connected person(s) and you, collectively the “Data Subject(s)”).

This document sets out Alprime’s policy on the processing of personal data and the rights granted to any identified or identifiable person whose data is processed (hereinafter the “Data Subject(s)”).

Definitions:

“Processing” of personal data includes collecting, recording, storing, using, modifying, communicating, archiving, deleting or destroying personal data, and this notice describes how we process personal data (hereinafter “Processing”).

For any questions relating to data protection, our Data Protection Officer (DPO) can be contacted at the following address: operations@alprimecapital.com or by post: Data Protection Officer, St. Annagasse 9, 8001 Zurich.

What personal data is concerned?

Personal data includes any information relating to an identified or identifiable natural person.

The personal data that we process may be based on the following legal grounds:

On a contractual basis:

• Identification data, e.g. name, address, telephone number, e-mail address, business details, marital status, family composition;
• Personal characteristics, e.g. date of birth, country of origin;
• Professional information, employment and work history, professional qualifications;
• Financial information, bank details;
• Data relating to current or past investments, investment profile;

Alprime does not carry out any profiling or evaluation of characteristics on the basis of automatically processed data.

On the basis of regulatory requirements:

• Ongoing information contained in official identification documents (passport/identity card, etc), social insurance etc;

On a legal basis requiring your prior consent:

• Certain information relating to cookies, e.g. cookies and similar technologies on the website and in mailings.

The purposes for which we collect personal data (hereinafter “Purposes”) may be based in particular on the legal bases applicable to Alprime in the context of its activities.

Personal data is collected and processed in particular as part of the implementation/execution of a contract to which you are a party;

• When opening and maintaining a business relationship with our company, including all formalities concerning your identification;
• The management, administration and distribution of investment funds, including all ancillary services related to these activities.

In the course of its business activities, Alprime may need to process personal data of “Related Persons” linked to a Customer, Service Provider or Employee (“Contact Person”). In such a situation, the “Contact Person” providing Alprime with information about the “Related Person” must ensure the content of this Notice has been communicated to the latter and, where applicable, his or her consent has been obtained to the extent necessary.

What are the purposes and legal bases of the personal data processed by our company?

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:

Sources used to collect your personal data:

• Directly from the persons concerned, e.g. when making contact or by means of contractual documentation;
• Indirectly via other external sources, in particular publicly accessible sources (various sanctions lists published by international organisations, information available via subscription services (e.g. Worldcheck, Bloomberg) or information provided by third parties.

Tools used:

1. Google Tag Manager
2. Google Analytics 4
3. LinkedIn Ads
4. Meta Business Suite (Instagram & Facebook Ads)
5. Google Ads
6. HubSpot CRM

Rights of data subjects:

Subject to the limitations set out in this Privacy Notice and/or Swiss data protection regulations, any data subject whose personal data has been processed by Alprime, may exercise the rights below free of charge, by contacting our DPO:

• Request access to the personal data processed by Alprime and receive a copy thereof;
• Request rectification or deletion of inaccurate personal data;
• Request the deletion of personal data, where their Processing is no longer necessary to achieve the Purpose, or is not lawful for other reasons, subject to the applicable retention periods;
• Request a restriction on the Processing of personal data whose accuracy is disputed;
• object to the Processing of personal data.

Retention period for personal data:

Alprime retains personal data for the purposes for which the data was collected and processed in accordance with applicable legal and regulatory provisions, such as the fight against money laundering and the financing of terrorism, contractual and tax obligations.

In certain cases, Alprime 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.

Transfer/sharing of personal data: 

Alprime may disclose personal data to third parties, insofar as legally or otherwise authorised or required:

• Alprime or third party processors likely to process personal data, in which case the personal data may be used by the recipients independently for their own purposes, in accordance with the legal provisions applicable to them;
• Auditors or legal advisors;
• Public/governmental administrations, courts, competent authorities (e.g. FINMA supervisory authorities) or financial market players (i.e. custodian banks, brokers, registers of issuers of securities or financial products).

Transfer of personal data abroad:

Alprime may transfer personal data to recipients abroad.  The transfer of personal data to third parties may involve the transfer of data to jurisdictions outside the European Economic Area which do not offer an equivalent level of data protection. The transfer and processing of such data will be accompanied by appropriate security measures, in particular contractual clauses, to ensure that the transfer is carried out in compliance with data protection rules.