This site was created for informational purposes only and is aimed at qualified investors within the meaning of art. 10 of the Federal Act on Collective Capital Investments and art. 6 of the Ordinance on collective capital investments in Switzerland.
By accessing this website (hereinafter “the Site”), as well as the products, services, information, tools and other elements it contains or describes, you acknowledge that you understand and accept the following conditions of use.
Access to the Site
Access to the Site is prohibited to any person subject to a jurisdiction (in particular due to their domicile, residence or nationality) whose applicable laws and/or regulations prohibit the publication and/or making available of the Site.
The information published on this Site constitutes neither an offer nor a recommendation to make or liquidate an investment or to carry out any other transaction. They cannot be considered as the basis for an investment or other decision. Any investment decision must be based on relevant, specific and professional advice.
Past performance should not be considered an indication or guarantee of future results. The value of and income from securities or financial instruments mentioned on this Site may fluctuate upwards or downwards and investors may not get back the full amount initially invested.
As part of its business dealings, Clairvaux Capital AG (hereinafter “CC AG”, “we”, “us” or “the company”) may need to collect certain personal information.
Contact details for any question related to this policy
Clairvaux Capital AG
Address: Henric Petri-Strasse 35, P.O. Box 257, CH-4010 Basel, Switzerland
Phone Number : +41 58 200 30 00
CC AG complies with various legal obligations and requirements, which have basis in the EU and in Switzerland, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“EU GDPR”). Such legal obligation, to which CC AG is subject, may be sufficient as a legitimate basis for the processing of personal data.
Parties subject to information collection
CC AG collects and processes personal information from the below types of parties:
• Clients, investors and beneficiaries (current, prospective and former) and any of their directors, officers, employees, partners, shareholders or agents;
• Directors, officers, employees, partners, shareholders or agents of service providers (including counterparties);
• Individuals who contact CC AG by email, phone or otherwise and any visitors of CC AG or CC AG’s website;
• Employees, contractors and other members of CC AG’s staff and collaborators (current, prospective and former); and
• Directors and officers of certain listed companies and other market participants
Type of information collected
The types of information collected depends on the product, service or relationship the parties (“data subject”) have with CC AG. This information may include any or some of:
• Personal data, which is any information which may be related to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, date of birth, nationality, photo ID, civil status, criminal records, social security number, tax identification number, address, location data, phone number, age, gender, an employee, a job applicant, a collaborator, clients, suppliers and other business partners. This may also include special categories of personal data (sensitive personal data) and confidential information such as health information, account number, identification number, or an online identifier.
• Company and business, phone number, work email address, position, career summary;
• Financial information;
• Investment experience, objectives and risk appetite;
• Connection information including IP address.
• CC AG may receive this information from parties subject to information collection, their representatives, third parties, public sources, or it may be collected using cookies when they access CC AG’s website.
Processing of information
Personal data shall always be:
• Processed lawfully, fairly and in a transparent manner in relation to the data subject;
• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that inaccurate personal data, having regard to the purposes for which it is processed, is erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Use of the information
CC AG may use the information:
• For their everyday business purposes, e.g. to fulfill regulatory obligations, to process transactions, to maintain accounts(s) or to respond to court orders and legal investigations;
• For marketing purposes, e.g. to provide information about products and services;
• For HR and career management purposes, e.g. to process job applications, to manage payroll and benefits;
• To fulfil any contract between CC AG and the subjects, and to ensure compliance with applicable legal or regulatory requirements;
• To administer, maintain and improve CC AG’s systems and website, including for security purposes;
• Should CC AG wish to use the personal data of the data subject for other specific purposes, the company will endeavour to contact the subject to obtain their approval.
CC AG may share the parties information with the following:
• Service providers and/or sub-contractors;
• Legal or regulatory authorities if CC Ag is required to do so under applicable rules.
To protect the personal information from unauthorized access and use, CC AG has implemented security measures in compliance with applicable law. These measures include computer safeguards, secured files and buildings, as well as organizational measures such as giving access to personal information only to the employees, agents or service providers that need it.
When personal information is disclosed to third parties, CC AG requires that the third party maintain the confidentiality of the information disclosed and limit the use of information by the third party solely to the purposes for which the information is disclosed or as otherwise required by law.
Information collection procedure
CC AG may collect personal information, for example, when parties:
• Provide information related to a form, questionnaire, meeting, in person, by telephone, electronically or by another means;
• Provide personal information to other financial institutions and service providers who have a contractual relationship with CC AG and who are authorized to provide personal information to CC AG.
CC AG will only keep personal information for as long as it needs it to fulfil its obligations under a contract entered into with the subject, obligations under a contract entered into with third parties in the parties’ interest, or obligations under applicable laws and regulations.
CC AG may also retain personal information for direct marketing purposes, to which the subject may object by contacting the company by email at firstname.lastname@example.org.
Unless particular conditions apply, CC AG will only retain personal information for up to seven years after the end of the parties’ relationships with the company.
Rights of parties subject to information collection
Under GDPR, the parties have the right to:
• Access any personal information held about them at any time;
• Receive information regarding any entities CC AG shared their personal information with;
• Where this does not conflict with the execution of a contract with the subject or applicable laws and regulations, request that CC AG rectify and/or erase personal information concerning the subject, restrict the use of this data in certain circumstances, or object to CC AG processing of personal information concerning the subject;
• Lodge a complaint with the relevant personal data supervisory authority.
This policy has been reviewed on 08 January 2024 and will be revised from time to time.