Privacy Policy
Protection of Confidentiality and Data Security
Privacy Policy
Compass Asset Management
Compass Asset Management SA (hereinafter referred to as “Compass”) is a company with many years of experience in the field of international finance, including wealth management, investment funds, trading and bond brokerage, estate and succession planning, and risk management.
The processing of any personal data that Compass may become aware of is carried out in compliance with the Swiss Federal Data Protection Act (FADP) and in accordance with the principles of fairness, lawfulness, transparency, and all limitations related to data retention, minimization, and accuracy — with full respect for the integrity, privacy, and confidentiality of all personal and sensitive information.
This Privacy Policy applies to the website www.compass-am.com (hereinafter referred to as the “Website” or “Platform”).
The Data Controller is Compass Asset Management SA.
For further information regarding the processing of personal data or to exercise your rights, users may contact us in writing at:
| by writing to: | Compass Asset Management SA Via Massimiliano Magatti 6, 6900 – Lugano Svizzera |
| by sending an email to: | compliance@compass-am.com |
What Are Personal Data and What Does Processing Mean
Personal data are any information that identifies or can identify, directly or indirectly, a natural person and may provide details about their characteristics, habits, personal relationships, etc.
Examples of personal data include, but are not limited to: name, surname, address or other contact details, an identification number, or an online identifier.
Processing refers to any operation or set of operations performed on personal data, with or without the aid of automated processes.
Examples of processing include, but are not limited to: collection, recording, organization, storage, modification, consultation, deletion, or destruction of data.
Types of Personal Data Processed
Browsing Data
The IT systems and software procedures used for the operation of this Website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified users; however, by its nature, it could, through processing and association with data held by third parties, make it possible to identify users.
Such data may include: IP addresses or domain names of the computers used to connect to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, and other parameters related to the user’s operating system and IT environment.
These data are used solely for anonymous statistical purposes, to monitor the correct functioning of the Website, detect anomalies or abuse, and are deleted immediately after processing.
The data may also be used to ascertain liability in the event of hypothetical cybercrimes against Compass or third parties.
Data Provided Voluntarily by the User via the “Info” Page
User data are collected when the User sends an email or information request to Compass, containing any personal data voluntarily provided in the message, or following telephone contact initiated by the User.
Purpose of Processing
The User’s personal data will be processed for the following purposes:
- To enable Compass to exercise its rights (both in judicial and extrajudicial contexts);
- To respond to the User’s requests for information or assistance;
- To fulfil pre-contractual, contractual, administrative, or tax obligations arising from any relationship established between the User and Compass;
- To send the User communications or notifications related to the service;
- To comply with legal or regulatory obligations and satisfy requests from competent authorities.
Legal Basis for Data Processing
Each processing activity is justified by one of the following legal bases:
Performance of a contract: processing is necessary to execute an existing contract or pre-contractual measures requested by the User. In this case, providing data is optional, but failure to do so may prevent the execution of the contract or requested service.
Legal obligation: processing is required to comply with applicable laws or regulations. In this case, providing data is mandatory, and failure to do so prevents the provision of the service.
Legitimate interest: processing is necessary to pursue Compass’s legitimate interests, provided that these do not override the User’s fundamental rights and freedoms.
Consent: processing occurs only when the User has given explicit consent for specific purposes. Consent may be withdrawn at any time.
Data Sharing and Disclosure
Within Compass’s business activities and for the purposes described above, the User’s personal data may be shared with:
Data Processors formally appointed by Compass to perform specific processing or auxiliary services on its behalf (the User may request an updated list of Data Processors at any time);
Independent Data Controllers, when communication of data is required by law or by orders of competent authorities;
Authorized personnel within Compass, who process data strictly necessary for the performance of their duties and are bound by appropriate legal and contractual confidentiality obligations.
Compass does not sell or otherwise disclose User data to third parties.
Data Storage Location
All personal data are stored electronically on servers located in Switzerland.
Data Retention Period
Personal data are retained in compliance with confidentiality and applicable laws for a maximum period of 10 years following the termination of the contractual relationship.
For curriculum vitae (CVs) submitted by Users for employment purposes, data are retained for a maximum period of 2 years from receipt.
Compass reserves the right to retain personal data for a longer period where permitted by Swiss law, in order to protect its legitimate interests.
User Rights
Users may request confirmation, at any time, as to whether their personal data are being processed and, if so, may exercise the following rights:
Access: to obtain information on the purposes of processing, categories of data, recipients, retention period (where possible), and the existence of automated decision-making;
Rectification: to request the correction or completion of inaccurate or incomplete personal data;
Erasure (“Right to be Forgotten”): to request deletion of data when they are no longer necessary for the purposes for which they were collected;
Restriction: to request limitation of processing in cases provided for by law;
Portability: to request transfer of data to another controller in a commonly used, machine-readable format;
Objection: to object to the processing of personal data, including profiling or decisions based solely on automated processing.
To exercise these rights, Users may contact Compass using the details provided in Section 1, or consult the website of the Federal Data Protection and Information Commissioner (FDPIC): http://www.edoeb.admin.ch
Automated Decision-Making
The User is not subject to decisions based solely on automated processing, including profiling.