DAPM Privacy Policy

1. General Principles

We at DAPM DYNAMIC ASSETS & PERFORMANCE MONITORING SA respect your concerns about privacy. On the basis of Article 13 of the Swiss Federal Constitution, the data protection provisions of the federal government in the Federal Act on Data Protection (FADP) and of the privacy policy pursuant to Articles 13 and 21 of Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), every person has the right to the protection of their privacy and to protection against the misuse of their personal data. Personal data is treated confidentially and not sold and we strive to protect it against unauthorised access, loss, misuse or falsification.

This privacy policy is intended to inform you of our efforts to protect your personal data and rights, and explains whether and in what way DAPM DYNAMIC ASSETS & PERFORMANCE MONITORING SA (CHE-109.666.128), Rue Pierre-Fatio 15, 1204 Geneva, Switzerland (hereinafter referred to as “DAPM”) collects, uses and discloses your personal data when you visit this website or use our mobile application. By accessing this website/mobile application, you agree and consent to the collection, use and disclosure of your personal data in accordance with the requirements of this privacy policy. The provision of personal data is required for the use of the website/mobile application and the failure to provide such data may prevent the use of the website/mobile application.

DAPM reserves the right to amend the terms of this privacy policy at any time. The amendments shall take effect immediately upon publication of the amended content on this site. By using the website/mobile application you agree to access and review the privacy policy regularly in order to remain informed of any such amendments. By continuing to use the website/mobile application after any amended conditions have been published, you will be deemed to have implicitly accepted the amended privacy policy. If you do not agree with any such amendments, the sole and exclusive response available to you is to stop using this website/mobile application immediately.

2. Collection of Personal Data

We do not collect targeted data on individuals via this website and/or our mobile application. When you visit our website or use our mobile application, some information is collected automatically and is stored in log files: IP address, date, time, browser query and general information transmitted about the operating system and browser. This usage data forms the basis for statistical, anonymous evaluations that make it possible to identify trends that we can use to improve our website and/or mobile application accordingly. When using this general data, we are not able to draw conclusions about the data subject.

When you visit our website, we do not collect any personal data other than as described above unless you submit it directly when contacting us by e-mail or through a contact form. Personal data provided in this way is stored in order to process and, if appropriate, answer your enquiry. If you contact us in this manner, you agree to the collection and use of your personal data for the purpose of answering your enquiry. If you submit personal data by e-mail to apply for a job or other form of collaboration with DAPM, you agree to the collection, use and storage of your personal data for a reasonable length of time, as long as we deem it necessary to do so for a possible job or other form of collaboration or for as long as we are required to do so for a legal retention period. Your personal data is collected to the extent necessary in the individual case.

When you visit our website, we may use cookies or other similar technologies some of which are generally aimed at monitoring and analyzing your interactions with the website and/or to enable us to improve the website and its functionalities. We also use cookies and similar technologies to measure and monitor the traffic and use of the website, as well as its performance. If you do not want cookies to be stored on your device, you can configure your browser or your device to refuse and/or restrict the cookies or use the interface available on the website. Certain cookies are however essential to the functioning of the website and its use may be altered or prevented by refusing these cookies. If you do not refuse or restrict the cookies, you consent to their use and to the processing of your personal data collected in this manner.

3. Use of Personal Data

We use personal information about you to:

• provide information that you or your organization request;
• enhance, improve, operate, and maintain our services, programs, website, apps, and other systems and features;
• prevent fraudulent use of our services and other systems and features;
• prevent or take action against activities that are, or maybe, in violation of our Terms of Use or applicable law;
• tailor content and other aspects of your experience on and in connection with the services available on the website/mobile application;
• maintain a record of our dealings with you; and
• perform other administrative activities.

We may use your personal information for other purposes as well about which we will notify you when we request the information, with your consent.

4. Storage and Protection of Personal Data

Information collected about users of the website/mobile applications is only stored for the purpose of providing the desired service and to the extent necessary in order to do so. Once the service has been provided, all the data will be deleted no later than the end of the legally stipulated retention period. You have the right to access the data processed by us at any time. If your data needs to be updated or changed or deleted from our files, please send your request to us at any time.

We take all necessary and reasonable technical and organisational measures to ensure the confidentiality and security of the data and to protect it from theft or any other unlawful use or other unauthorised access.

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information by adopting appropriate and suitable safeguards which may be available upon request.

5. Access to and Disclosure of Personal Data

At DAPM, employees only have access to data if necessary, in order to carry out their work and provide services. All employees are trained in the handling and protection of personal data and are subject to confidentiality obligations.

DAPM may disclose data to other units within the company, including those abroad, if necessary. Those units will use and protect the data in accordance with the same guidelines and provisions of this privacy policy and with the FADP and the GDPR.

DAPM may disclose data to external service providers, which may be situated abroad, if necessary for the purpose of providing the service and if it is guaranteed that the data will be used in accordance with the terms of this Privacy Policy, the FADP and the GDPR and that the protection of the data is ensured by appropriate and suitable safeguards.

DAPM may disclose data if necessary, in order to comply with prevailing laws and regulations, in legal proceedings, at the request of the competent courts and authorities or on the basis of other legal obligations.

Except as described in this Policy, we will not disclose your personal information to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• We may disclose personal information to third-party service providers such as those used for data storage, and processing facilities that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such personal information.
• We may also disclose personal information if legally required, or to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

Your rights in relation to your personal data include the following:

• You have the right to request information on the data we process about you at any time.
• You also have the right to know how and why your data is processed, to whom it has been disclosed and for how long it is retained or stored.
• You have the right to request the correction or completion of your data if it contains errors.
• You also have the right to request the deletion of your data if further storage is no longer required under contractual or legal guidelines.
• You have the right to receive the data we process about in a structured, commonly used and machine-readable format (data portability).
• You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent before its withdrawal.
• You have the right to lodge complaint with a supervisory authority.

For any query, please contact DAPM’s Data Protection Team by email: dataprotection@dapm.com or send your request to the Data privacy officer, DAPM DYNAMIC ASSETS & PERFORMANCE MONITORING SA, Rue Pierre-Fatio 15, 1204 Geneva, Switzerland.