Privacy Statement

This Privacy Statement explains how AAMIL (Swiss) SA (hereafter referred to as “AAMIL”) collects, uses and discloses your personal data, and outlines your rights concerning the personal data we hold.

AAMIL is a data controller under the Swiss Federal Act on Data Protection (FADP).

We collect, process, and store personal data related to you, such as your passport details, proof of address (e.g., utility bills, credit card statements), bank references and other sensitive personal data.

As part of our client onboarding process and service provision, AAMIL treats your personal data as private and confidential, adhering to data protection laws including the Swiss FADP and, where applicable, the EU General Data Protection Regulation (GDPR).

We strictly comply with the regulations set forth under the Swiss Federal Act on Data Protection and, where applicable, the EU GDPR.

This Privacy Statement contains important information on who we are, why we collect, store, share and use your personal information.

It is important for you to review this statement carefully, as it details our data collection processes, storage, use and sharing of your personal information.

1. Collection

We collect your personal data directly from you during the execution of our contract, including identification documents (passport, identity card), proof of address (utility bill, credit card statement), and bank references.

Where lawful and reasonable, we may also collect information from third parties and publicly available sources, such as business introducers, intermediaries, internet websites (e.g., Google, LinkedIn), and anti-money laundering screening tools.

This data is collected for purposes including:

• Fulfilling our corporate secretarial, administrative, and fiduciary responsibilities towards you.
• Conducting ordinary business activities (e.g., bank account openings, day-to-day operations, following your instructions, administering claims, executing agreements, and meeting compliance and regulatory obligations, such as anti-money laundering laws).
• Complying with requirements from tax authorities or any competent court or legal authority.
• Adhering to prevailing laws.

We use the information provided by you to perform the agreement between AAMIL and yourself.

2. Use of Your Personal Data

As a client, we process your personal data under the lawful basis for which it was collected, including:

• Carrying out your instructions and responding to your inquiries.
• Conducting and verifying ongoing creditworthiness and standing checks.
• Using information regarding ownership of assets for automatic exchange of information.
• Performing ongoing due diligence or other “Know-Your-Customer,” anti-money laundering, counter-terrorist financing, or anti-bribery checks.
• Complying with regulatory or legal obligations vis-à-vis regulatory bodies such as the Swiss Financial Market Supervisory Authority (FINMA), the Commercial Register, the Swiss Federal Tax Administration (SFTA), and other relevant authorities.

3. Transfer Across Borders

In cases where we need to process your personal data in other countries, we will seek your prior approval unless otherwise required by law, such as in cases of automatic exchanges of information.

To ensure your rights are respected, we will require the recipient of the data to agree to our privacy policies and measures in place.

4. Data Storage

Information about you is retained as long as necessary to fulfill the purpose for which it was collected.

The information is then destroyed unless its retention is required to satisfy legal and regulatory requirements in Switzerland.

As a rule, the maximum retention period is ten (10) years.

5. Our Security Practices

We have implemented well-designed security systems, along with technical and organizational measures, to protect your personal data from accidental loss, alteration, unauthorized destruction, damage, or unlawful access.

6. Access to Your Personal Data and Your Rights

You have several rights concerning your personal data, including the right to:

• Access and obtain copies of your personal data by making a “subject access request.”
• Request correction of outdated or inaccurate personal data, or, in certain circumstances, request deletion.
• Object to further processing in certain circumstances, including the right to object to marketing.
• Request that we transfer your personal data elsewhere (data portability).
• Withdraw any consent you have provided if we are not processing your personal data accordingly.
• Request not to have your personal data processed automatically.

Please note that these rights are not absolute, and we may be entitled to refuse requests under certain conditions.

To exercise any of your rights or require additional information or assistance, please contact our Data Protection Officer at the address provided below.

7. Monitoring of Electronic Communications

We communicate with you through various methods and channels.

We may record and monitor electronic communications to ensure compliance with our legal and regulatory responsibilities and internal policies.

8. Retention of Personal Data

Your personal data will be retained in accordance with statutory and regulatory requirements in Switzerland.

If there is no legal requirement to retain such data, it will be destroyed once the lawful purpose for which it was obtained has been fulfilled.

9. Right to Change This Privacy Statement

We may update this Privacy Statement.

We will communicate all changes on our website. The latest version of our privacy statement will replace all earlier versions, unless it says differently.

10. Queries, complaints and breach

If you have any queries or complaints about privacy or believe that there has been a breach with respect to your privacy, please contact our Data Protection Officer at the below mentioned address: compliance@aamil.com.