CLIENT INFORMATION PURSUANT TO THE SWISS FEDERAL ACT ON DATA PROTECTION ("FADP")

 

Reynov Financial Solutions hereby provides information regarding its data protection policy and the processing of personal data within the scope of its contractual relationship with clients.

 

The revised Swiss Federal Act on Data Protection ("FADP"), effective as of September 1, 2023, aligns with the principles of the EU General Data Protection Regulation ("GDPR"). The applicability of specific legal provisions will depend on the particular circumstances of each case.

 

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Identity and Contact Details of the Data Controller

 

Reynov Financial Solutions

Sergey Reynov
Albisriederstrasse 30

8003 Zürich
Switzerland 
 

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Collection and Processing of Personal Data

 

Personal data encompasses any information related to an identified or identifiable individual. In the course of fulfilling its mandate, Reynov Financial Solutions collects various categories of personal data from clients, which may include:

 

• Personal details (e.g., name, address, date of birth, marital status, etc.)

• KYC (Know Your Client) information (e.g., source of wealth, source of funds, AML-related transactions, etc.)

• Bank account data (e.g., account statements, correspondence)

 

Additionally, any other information provided by clients in the context of the business relationship may also be collected.

 

Where legally permissible, Reynov Financial Solutions may receive personal data from affiliated entities, public authorities, or third parties (e.g., custodian banks). The types of data obtained from third parties may include:

 

• Information from public registers

• Data received during administrative or judicial proceedings

• Information gathered from third-party interactions

• Data provided by individuals connected to the client (e.g., family members, advisors, legal representatives) for the purpose of concluding or executing contracts

• Information concerning legal obligations such as anti-money laundering requirements

• Data available in the media or online sources

 

As a general rule, personal data is retained for a minimum period of 10 years. This period may be extended if required for evidentiary purposes or to meet legal or contractual obligations.

 

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Purpose of Data Processing and Legal Basis

 

The primary purpose of collecting and processing personal data is to deliver the agreed services to clients and to ensure compliance with domestic and international legal requirements. Additionally, data may be processed for the following purposes, in line with applicable law:

 

• Providing products and services to clients

• Communicating with third parties and responding to their inquiries

• Marketing and promotional activities (including event organization), unless the client has objected to such use of their data

• Asserting legal claims and defending against legal disputes or official proceedings

• Preventing and investigating criminal activities or other misconduct

• Ensuring the proper functioning of business operations, including IT systems and platforms

 

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Rights of Data Subjects

 

In accordance with the applicable legal framework, individuals whose personal data is processed ("Data Subjects") are entitled to various rights. Reynov Financial Solutions is committed to ensuring that clients can exercise these rights transparently and efficiently. Such rights include:

 

• Requesting information on whether and what personal data is being processed

• Requesting the correction of inaccurate or incomplete data

• Objecting to the processing of data, in whole or in part

• Requesting the deletion of data

• Requesting the transfer of personal data in a commonly used electronic format to themselves or a designated third party

• Withdrawing consent where processing is based on prior consent

• Requesting further information on how to exercise these rights

 

Generally, the exercise of these rights requires proof of identity. Requests should be submitted in writing using the contact details provided above. Reynov Financial Solutions reserves the right to impose legal restrictions or exceptions, such as when data retention is mandated by law, when overriding legitimate interests apply, or when data is necessary for the assertion of legal claims.

 

Clients should also note that exercising certain rights may affect the contractual relationship, potentially resulting in early termination and associated costs. In such cases, Reynov Financial Solutions will provide prior notice unless already stipulated in the contract.

 

Additionally, Data Subjects may seek judicial remedies or file a complaint with the competent data protection authority. In Switzerland, the responsible authority is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).

 

 

Data Transfers to Third Parties and Abroad

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To fulfill contractual and regulatory obligations, Reynov Financial Solutions may transfer personal data to third parties for processing, provided such transfers are lawful and appropriate. Potential recipients may include:

 

• Data hosting and software service providers

• Custodian banks and other financial institutions

• Domestic and foreign regulatory authorities, government agencies, and courts

 

While some recipients are based in Switzerland, others may be located in foreign jurisdictions. If data is transferred to a country without adequate legal data protection, Reynov Financial Solutions will require the recipient to adhere to applicable data protection standards, unless the recipient is already subject to a recognized privacy framework or an exception applies. Exceptions may include instances such as foreign legal proceedings or when disclosure is necessary for contract performance, provided client consent has been obtained or the data is publicly accessible without objection.

 

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Confidentiality

 

Reynov Financial Solutions maintains strict confidentiality regarding all client information obtained during the course of its business activities. This duty of confidentiality extends beyond the termination of the contractual relationship.

 

To carry out its activities, Reynov Financial Solutions collaborates with custodians, asset managers, and other service providers. Clients acknowledge and consent to the exchange of their personal data with such counterparties to the extent necessary for the execution of services.

 

Reynov Financial Solutions takes reasonable steps and implements appropriate security measures to ensure compliance with relevant data protection laws. This includes safeguarding client data against unauthorized access, misuse, disclosure, alteration, or destruction.

 

Clients consent to the transfer of their data to the aforementioned recipients, including cross-border transfers, and acknowledge that such data may be used for purposes including account administration, transaction processing, responding to client inquiries, and fulfilling regulatory requirements (e.g., KYC and AML obligations). Clients also consent to their data being used to evaluate product suitability and to receive marketing information, with the option to opt-out by submitting a written request via email or post.

 

Client data may be retained beyond the termination of the business relationship where necessary for legal, regulatory, or business purposes.

 

If personal data is collected by Reynov Financial Solutions as a data controller under the FADP, the company will provide the necessary information through its privacy policy, which is available on its website or upon request in electronic or physical format.

 

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Amendments to the Privacy Policy

 

This privacy policy may be updated at any time without prior notice. The latest version will be published on our website. Where the policy forms part of a contractual agreement, clients will be informed of any significant changes via email or other suitable means.