This privacy Notice (the “Privacy Notice”) is issued by NS Partners (“NS Partners”). This Privacy Notice explains how Personal Data (as defined below) is processed at NS Partners and individuals’ rights in relation to their Personal Data processed by NS Partners.
Any question regarding the processing of Personal Data by NS Partners may be sent to the addresses below:
|NS Partners Data Protection Officers, DPO|
|Rue de Saint-Jean 98||11, Boulevard de la Foire||22 Upper Brook Street||Old Devonshire Post Office
|1201 Genève||1528 Luxembourg||London W1K7PZ||29 Middle Road
1. How do we handle your personal data?
2. What personal data do we process?
“Personal data” include any information that may enable one to identify directly (e.g., first name, surname) or indirectly (e.g., passport number or data combination) a natural person. Personal data of Data Subjects we process may include:
- Identification data, e.g., names, addresses, telephone numbers, email addresses, business contact information;
- Personal characteristics, e.g., date of birth, country of birth;
- Professional information, e.g., employment and job history, title, representation authorities;
- Identifiers issued by public bodies, e.g., passport, identification card, tax identification number, national insurance number, social security number;
- Financial information, e.g., financial and credit history information, bank details;
- Transaction/investment data, e.g., current and past investments, investment profile, investment preferences and invested amount, quantity and value of shares held, role in a transaction (seller/buyer of shares), transaction details;
- Sensible personal data, e.g., information regarding health or administrative or criminal proceedings;
- Cookie information, e.g., cookies and similar technologies on websites and in emails.
3. For what purposes and on what legal bases do we process personal data?
- provide offering documentation to Data Subjects about products and services;
- carry out any other form of cooperation with, or reporting to, competent administrations, supervising authorities, law enforcement authorities and other public authorities (e.g., in the field of anti-money laundering and combatting terrorism financing (“AML-CTF”)), for the prevention and detection of crime under tax law (e.g., reporting of name, address, date of birth, tax identification number (TIN), or Foreign Account Tax Compliance Act (“FATCA”) or other tax legislation to prevent tax evasion and fraud as applicable);
The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from maintaining a Business Relationship with, and/or from providing services to you.
4. What sources do we use to collect your personal data?
We collect or receive personal data:
- directly from the Individuals concerned, e.g., when contacting us or on the basis of a (pre-) contractual documentation directly sent to us; and/or
- indirectly from other external sources, including any publicly available sources (e.g., UN or EU sanctions lists), information available through subscription services (e.g., Bloomberg) or information provided by other third parties.
5. Do we share your personal data with third parties?
6. What are your rights in connection with data protection?
- access and obtain a copy of his/her Personal Data;
- request the rectification of his/her Personal Data when they are inaccurate or incomplete;
- request the erasure of his/her Personal Data, e.g., when they are no longer necessary for the purposes for which they were collected or processed, or when the data subject withdraws the consent necessary for the processing (subject to point 7 below);
- object on legitimate grounds to the processing of his/her Personal Data;
- request the limitation of the processing of his/her Personal Data;
- receive information on the safeguards which NS Partners may have implemented for transferring Personal Data to jurisdictions which do not ensure an adequate level of data protection (if applicable); and
- lodge a complaint with a competent data protection supervisory authority.