"Investment research is the process of reducing large piles of information to manageable ones, distilling the investment wheat from the chaff. There is needless to say, a lot of chaff and very little wheat." – Seth Klarman
Privacy Statement
We use and protect your data just like ours!
Compliance with data protection laws (specifically with the General Data Protection Regulation of the EU [GDPR]) and thus the protection and confidentiality of your personal data is one of our company’s key concerns. This privacy statement informs you how we process personal data in our role as investment sub-advisor to Anemothiela Global Equity Strategy and outlines in particular the rights to which you are entitled with respect to your personal data.
General
The processing of personal data, especially of the name, the address, the email address or telephone number of a data subject, is always handled in compliance with the General Data Protection Regulation as well as with the country-specific data protection provisions to which our company is subject. With this privacy statement, ANEMOTHIELA Ltd. wishes to inform the public about the nature, scope, and purposes of the personal data that we collect, use, and process. Further, this privacy statement informs data subjects about the rights that they have.
Data processing
Categories and origin
We process personal data that we receive within the scope of our business relationships with you and any third parties involved. On principle, we process the smallest possible amount of personal information. Personal data is differentiated by the following data categories:
- Personal particulars
- Information from the fulfilment of our legal obligations
- Data from the fulfilment of contractual obligations
- Information concerning occupational background
- Documentation data
- Marketing data
- Technical data
- Information from your digital communication with our company
- Data from public domain sources
We process personal data from the following sources:
- Personal data that we receive from you in the form of contracts, forms, your correspondence or other documents submitted
- Personal data collected or transmitted in conjunction with the use of products and services
- Personal data legitimately sent to us by third parties, by public entities or by other companies (such as for the execution of contracts or for contractual fulfilment purposes)
Legal framework and purposes
We process personal data in compliance with the provisions of the GDPR based on the following legal framework and for the following purposes:
- Due to your consent (Art. 6 para. 1 lit. a GDPR)
- For the fulfilment of a contract or for the implementation of precontractual measures (Art. 6 para. 1 lit. b GDPR)
- For the fulfilment of legal obligations (Art. 6 para. 1 lit. c GDPR)
- For safeguarding legitimate interests
Use and storage of your personal data
Forwarding of data
Entities within and outside our company may obtain access to your data. If the company’s business activities and services are fully or partially outsourced (e.g. IT systems and operation or optimization of the website) this will be done in compliance with applicable legal provisions. These companies are bound by the code of confidentiality and the privacy statement.
Data erasure and storage
We process and store your personal data for the entire duration of the business relationship, from the initiation to the termination of the contract. After the termination of a contract, which eliminates the purpose of storage, the duration of storage depends on legal safekeeping and documentation obligations. Safekeeping periods may extend across 10 or more years.
Rights and obligations
Data protection rights
Right of confirmation
You have the right to request confirmation as to whether personal data about you is being processed.
Right of access
You have the right to gain access, free of charge and at any time, to stored personal data about you and to obtain a copy of such data.
Right to rectification
You have the right to demand the immediate rectification of incorrect personal data that relate to you.
Right to erasure
You have the right to demand the immediate erasure of personal data related to your person if no processing is required.
Right to retract
You have the right to retract your consent to the processing of personal data at any time.
Right to data portability
You have the right to receive the personal data concerning your person and which was provided by you, in a structured, commonly used, and machine-readable format.
Exercising rights
We accept requests for information in writing, accompanied by a legible certified copy of a valid identification document (e.g. passport, ID card, driver’s license). You can exercise further rights by sending us an appropriate message.
Right to lodge a complaint with the supervisory authority
You have the right to lodge a complaint with a supervisory authority in an EU or EEA member state, in particular at the place where you live or work or where the alleged infringement of the provisions of the GDPR took place. The supervisory authority responsible for us is the Swiss Data Protection Office (Autorité de protection des données et de droit à l’information), Rue Saint-Martin 6, Case Postale 5485, 1002 Lausanne, Switzerland.
Obligation to provide personal data
Please be advised that the provision of personal data may be required by law or can be the result of contractual provisions (information concerning the contractual party, etc.). To finalize a contract with us, it may be necessary for you to provide us with personal data that we will subsequently need to process. For example, you are obliged to provide us with personal data if our company concludes a contact with you. The non-provision of personal data would prevent the finalization of the contract.
You are not obliged to consent to data processing of those data that are not relevant and/or not required for legal or regulatory reasons to fulfil the contract.
Contact and mailing list
If you contact us by email or via a contact form, the personal data you share with us is automatically stored. The same applies if you use the subscription form. Such personal data communicated on a voluntary basis is stored to enable processing or contact purposes. In selecting a subscription, or for as long as you are on our mailing list, you consent to the terms of this privacy statement.
Email communication with us is currently open and unencrypted. We are therefore not able to exclude the possibility that data sent by email will not be seen by third parties and contacts made to us will not be retraced. Data may also move across national boundaries, even if the sender and recipient are located in the same country. Confidentiality is therefore not always guaranteed in email communication.
Use of cookies
Cookies are text files that are stored on your electronic device to track your use of electronic services as well as your navigation preference settings across the individual web pages and if applicable to store your settings between visits. They enable analysis to be made of how our website is used. This does not involve collecting or storing any personal data which could allow your identity to be traced.
Please note that most internet browsers accept cookies automatically. You can configure your browser to prevent cookies from being stored on your electronic device, to accept cookies only from certain websites, or to notify you before a new cookie is accepted. If cookies from our website are deactivated, it may no longer be possible for you to seamlessly use all functions offered by our website.
Analysis tools
In this context, pseudonymized data is collected and cookies are used to analyze how users make use of our website. The information generated with cookies regarding your use of the website (for instance the host name of the electronic device used to access the website [IP address], browser type and version, the operating system used, as well as the date and time of the server request) may be transferred to the servers of third parties and are used for analysis purposes.
Our company website uses Google Analytics, an analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, text files which are stored on your computer and enable your usage of the website to be analyzed.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this app.