Last updated on February 18, 2019
Symbiotics SA is committed to protecting and respecting your privacy. This Notice explains how your personal information is processed by Symbiotics, including any affiliates listed in the Data Controllers and Contact section below (hereinafter also collectively referred to as “us” or “we”).
This Notice concerns personal information relating to several categories of identified or identifiable natural persons that we may collect through any medium, including specifically in relation to the investment services we provide to you, via our partners and service providers, or through our website. This policy describes how you can access and make certain choices about how we use your personal information.
We may collect and process data in relation to the below listed information with respect to persons connected with the investment services we provide, our website, and our job applications. As well as collecting personal data from our clients (including potential clients), we may also process personal data about relevant persons connected with the investment services, for example 3rd party agents acting on behalf of prospective or existing investors, co-investors, their beneficial owners, contractors, etc.
We may collect this information from a number of sources, including directly from you, via our affiliates, delegates, partners, service providers, legal professional advisors, distributors, or third-party entities with whom we undertake due diligence checks upon you or publicly available sources. In doing so, we will ensure that the information we collect is proportionate to our stated purposes.
Where relevant, we may collect and process personal information related to persons associated with you. In such circumstances, it is your responsibility to ensure you have permission from that third-party for us to collect their information and you remain responsible for ensuring that the third-party understands how their information is being used.
In each case, we collect such information only insofar as is necessary or appropriate to fulfill the purpose of the person’s interaction with us, e.g. to provide the online products and/or services or individuals connected with our investment services. A person can always refuse to supply personal data, with the caveat that it may prevent such person from engaging in certain related activities with us.
Personal data that we may collect and process includes:
Unless specifically stated otherwise in a Privacy Notice provided to you, we use your personal information in the following ways and based upon the following lawful bases:
We may disclose your personal information with the following category of recipients, and based upon the legal bases and purposes set-out above:
We store your physically-held and electronically-held personal information in our Swiss offices in secure locations and secure servers.
We take all reasonable steps to protect your personal information; however, where you choose to transmit your personal data to us via the internet, we do not guarantee the security of the personal information transmitted and therefore any transmission is at your own risk. When you enter sensitive information (such as investment information) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We may transfer your personal information to our affiliates, partners, or service providers that are based outside of Switzerland or the European Economic Area. In such circumstances, we will ensure that your personal information is adequately protected to European Commission approved standards. Transfers of this type will be restricted to limited, specific, and necessary situations.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
In certain circumstances, in relation to your data, you have certain rights:
Further details of your rights can be found on the websites of many Data Protection Authorities (i.e. the ICO website), however, please note that your rights are subject to our overarching legal responsibilities. If you wish to exercise any of these rights, please contact the relevant data controller (listed below).
We reserve the right to retain your personal information for as long as we reasonably believe it to be necessary in order to facilitate our legitimate interests, in order for us to comply with our legal or regulatory obligations, where based upon reasons of substantial public interest, or where your personal information remains public information by your own actions. Your personal data will not be retained for longer than necessary with regard to the purposes and compliance obligations contemplated in this notice, subject always to applicable legal minimum retention periods. For further information, please contact the relevant data controller (listed below).
We may make changes to our Privacy Notice at any time and may do so without expressly notifying you of these changes. However, should the legal bases or purpose for processing your personal information changes then we shall expressly notify you.
Questions or individual data requests relating to this Notice should be addressed to the relevant data controller. For the purpose of the data protection legislation, the relevant data controllers are:
Rue de la Synagogue 31, 1204 Geneva, Switzerland
+41 (0) 22 338 15 40
Group headquarters responsible for setting Group strategy. All asset management activities related to (Swiss) FINMA regulated activities.
Symbiotics UK Ltd
Registered number: 08618323
6, Belvis Marks, London, England EC3A 7BA
+44 (0) 20 378 611 86
Advising on investments, arranging (bringing about) deals in investments, making arrangements with a view to transactions in investments activities related to (UK) FCA regulated activities.
Symbiotics Netherlands BV (Operating Plumseeds platform)
Meester Treublaan 7, 1097 DP Amsterdam, Netherlands
+31 (0) 20 240 9329
Provision of delegated online platform services related to Symbiotics’ investment products and services.
Symbiotics SA’s GDPR Article 27 Representative in the EU.
Technologies such as cookies (a small piece of data sent from a website and stored on the user’s computer while the user is browsing), tags, and scripts are used by Symbiotics and our partners, including marketing partners affiliates, or analytics service providers (like Google Analytics) and business process service providers. These technologies are used in order to provide the services in a more individual way. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Cookies are typically deleted from your device once the browsing session is terminated. You can choose to block cookies that we may deliver to your device through settings on your web-browser; however, in doing so you may not be able to access or utilize all aspects of our website.