This data protection declaration explains how we process personal data.
“Personal data“ means all details related to a specific or identifiable natural or legal person. "Processing“ means all ways of dealing with personal data, irrespective of the means and procedures used, in particular procuring, storing, using, revising, disclosing, archiving and destroying of personal data.
In connection with specific kinds of data processing, e.g. the entry into contracts, additional provisions might apply. Such provisions are available in the respective contracts.

We undertake to protect your privacy in accordance with the applicable laws, especially the code of conduct and data protection law. For this reason, we take a number of precautions, such as implementing technical and organizational security measures (e.g. access restrictions, firewalls, personal passwords such as encryption and authentication technologies, staff training).

We can process the following categories of personal data while limiting the processing to the necessary minimum.

Client data such as:
Master data and data on holdings (e.g. name, address, nationality, date of birth, information about accounts, custody accounts, concluded transactions and contracts, information about third parties who are also affected by the data processing, such as spouses, authorized representatives and advisors).
Transaction data, order data, and risk management data (e.g. data regarding beneficiaries of payments, the beneficiary’s bank, the amount of payments, data on risk and investment profiles, investment products). Technical data (e.g. business numbers, IP addresses, internal and external identifiers, records of access).
Marketing data (e.g. preferences, needs).
Data of interested parties and visitors (i.e. our visitors or visitors of our website) such as:

• Master data and data on holdings (e.g. name, address, date of birth).
• Technical data (e.g. IP addresses, internal and external identifiers, records of access).
• Marketing data (e.g. preferences, needs).

Supplier data such as:

• Master data and data on holdings (e.g. name, address, date of birth).
• Technical data (e.g. IP addresses, internal and external identifiers, records of access).

For the purposes of section 5, we can collect personal data from the following sources:

Personal data given to us, e.g. for the entering into a business relationship, the execution of contracts, or our products and services.
Personal data necessary for the use of products or services and transmitted to us via the technical infrastructure or complex processes.
Personal data from third parties, e.g. authorities or UNO/EU sanction lists.

We can process personal data for the provision of own services and for own or legally prescribed purposes. In particular, the purposes of our data processing are the following:

Protecting our interests and securing our rights in case of claims against us or own claims against third parties.

• Entering into and executing of contracts, processing and managing products and services (e.g. payments, investments). Monitoring and managing risks (e.g. investment profiles, combating of money laundering, limits, market risks).
• Planning, business decisions (e.g. developing of new or assessing of existing services and products).
• Marketing, communication, information about and review of the range of services (e.g. advertisements in print and online; events for clients and interested parties as well as other events, determination of future client needs).
• Protecting our interests and securing our rights in case of claims against us or own claims against third parties.

We may disclose client data to the following third parties in the following cases:

Based on legal obligations, legal justifications or official orders, e.g. to courts, supervisory authorities, tax authorities, or other third parties.

Where necessary, to protect our legitimate interests, e.g. with respect to any legal action threatened or initiated against us by clients, in case of public statements, to safeguard our claims against clients or third parties, or for debt collection proceedings. With the consent of the person concerned, to other third parties. In particular in connection with certain products or services, personal data must also be disclosed to third parties domiciled in countries which do not have an appropriate level of data protection (e.g. the United States). If data has to be transferred to such a country, we will take measures for a continuous appropriate protection of personal data.

When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation.

If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information.

When visiting our website, the visitor’s data is transmitted over the internet, an open network accessible to everyone. The electronic transmission of data (including via email) prohibits an effective protection of the data against third party interventions. This bears the risk that the data is being disclosed or altered, that the identity of the sender (e.g. email address) or the content of the data is imitated or otherwise manipulated by unauthorized third parties, that viruses are released, that technical transmission errors, delays or interruptions occur, that information is transmitted abroad including countries whose data protection laws are not comparable to those of Luxembourg etc.

When visiting our website, the visitor explicitly agrees to this data protection declaration and the mentioned risks. Furthermore, a visitor of our website can agree to the use of cookies. Cookies are small files that are saved on the computer of the visitor of our website in order to follow the website visit if the visitor navigates between different pages or to save settings (e.g. selected language). Cookies help to collect statistical data on how often and how long people visit specific areas of the website and help to develop customized websites that are more useful and user-friendly. The visitor may decide to stop the use of cookies at any time by deleting the cookies created by our website. This can be done by deleting all cookies via the settings in the visitor’s web browser.

The duration of storage for personal data depends on the purpose of the data processing and/or statutory storage provisions (depending on the applicable legal basis, five, ten or more years).

You can ask us whether personal data about you is being processed. You have the right to object to the data processing, the right to restriction of processing, and, if applicable, the right to data portability. You also have the right of rectification and, provided that there are no compelling statutory or regulatory requirements (such as storage provisions) or technical barriers, the right to erasure. The erasure of your personal data may lead to the result that we cannot provide certain services any longer. Furthermore, if applicable, there is also a right to lodge a complaint with an appropriate data privacy supervisory authority. Where we process personal data based on your granted consent, you may revoke your consent at any time.

To help us reply to your request, please send us a clear message. We will examine your issue and reply in good time.