(Version as of October 1, 2023)

 

We respect your privacy. This privacy statement demonstrates our commitment to protecting and respecting your personal data when you visit our website. Responsible for the processing of your personal data is:

Moning Wealth Management AG

Dr. Hans R. Moning

Speerstrasse 32

CH-8805 Richterswil

E-mail: hr.moning@moning.com

1. General

In this privacy statement, we, Moning Wealth Management AG (hereinafter MWM), explain how MWM collects and otherwise processes personal data. This is not an exhaustive description; if necessary, other data protection declarations (or general terms and conditions, conditions of participation and similar documents) regulate specific facts. Personal data is understood to be all information that relates to an identified or identifiable person.

If you provide MWM with personal data of other persons (for example family members, work colleagues and/or business partners), please make sure that these persons are aware of this Privacy Policy and only share their personal data with MWM if you are allowed to do so and if these personal data are correct.

This Privacy Policy is designed to comply with the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA") and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case.

By using this website, you consent to the collection, processing and use of data as described below. This website can generally be visited without registration. Data such as pages called up or names of files called up, date and time are stored on the server for statistical purposes without this data being directly related to your person. As far as personal data (e.g. name, address or e-mail addresses) are collected on the pages of MWM, this is always done on a voluntary basis whenever possible. These data will not be passed on to third parties without your explicit consent.

 

2. Collection and processing of personal data

MWM primarily processes the personal data that it receives from its clients and other business partners in the course of its business relationship with them and other persons involved in it, or that it collects from their users in the course of operating its website and other applications.

As far as permitted, MWM also takes certain data from publicly accessible sources (for example debt enforcement registers, land registers, commercial registers, press, Internet) or receives such data from others from authorities and other third parties.

The MWM processes different categories of personal data. The most important categories are the following:

-      Master and personal data (for example name, address, nationality, date of birth, tax number, information regarding account, deposit, concluded transactions and contracts, information about third parties involved in data processing, such as spouses, agents and consultants)

-      Technical data (for example business numbers, IP addresses, internal and external identifiers, access records)

-      Transaction or order and risk management data (for example information on beneficiaries of transfers, beneficiary banks, amount of transfers, information on investment products)

-      Financial data (for example creditworthiness data, information on assets, liabilities, risk and investment profile)

-      Visitor and prospect data (for example visitors to MWM's website)

-      Marketing data (for example, preferences, needs)

-      Communications data (for example contact information such as email address, phone number)

-      Data on compliance with legal requirements, such as anti-money laundering, as well as sanctions and embargoes

-      Other data (for example video or audio recordings, access data).

MWM processes and stores personal data for the duration required for the respective purpose or purposes. In case of longer-term storage obligations due to legal and other obligations to which MWM is subject, the processing will be limited accordingly.

 

3. How we process data on the internet

Every time you use our website, certain data is generated for technical reasons, which is temporarily stored in log files (log data), especially the IP address of your end device, information about the Internet service provider and about the operating system of your end device, information about the referring URL, information about the browser used, date and time of access and accessed contents when visiting the website.

We use log data so that our website can be used, furthermore to ensure system security and stability and to optimize our website.

Our website does not use cookies, i.e. files that your browser automatically stores on your terminal device.

 

4. Legal basis and purpose of processing

MWM processes personal data in accordance with the data protection law

- for the conclusion and fulfillment of the contracts of MWM, 

- to comply with legal or regulatory requirements and

- to protect legitimate interests of Moning MWM or third parties.

Furthermore, MWM processes personal data to protect legitimate interests (for example to contact and maintain contact or communication, for market research, for the development and control of services, for quality assurance (for example for training and education), for the investigation or prevention of crime or other misconduct, for the prevention of damage and loss (for example to combat fraud and abuse, internal investigations), to defend against or enforce legal claims in procedures and processes, to safeguard operations and infrastructure (for example, in the IT area), to protect persons and assets (for example, to create visitor lists, access controls or other records), for business and risk management (for example, for business organization and corporate development) or to comply with foreign law).

 

5. Data security

MWM processes as little personal data as necessary and protects it from loss and misuse (for example from access, modification, or disclosure by unauthorized persons). The technical and organizational measures for data security are appropriate and meet high requirements (for example use of up-to-date firewall and antivirus products, personal passwords with multifactor authentication technologies as well as encryption and access restrictions, sensitization and training of employees). These measures are continuously adapted to the threat situation. The protection corresponds to the current state of the art as well as the type and scope of processing.

 

6. Recipients of personal data

MWM complies with the secrecy obligations, which are based on the data protection law and other regulations (for example bank client secrecy). These obligations apply to all employees and organs of MWM as well as to persons who work on behalf of MWM in the context of outsourcing tasks. Within MWM, personal data can only be accessed by those who need it for the processing purpose.

Personal data may be disclosed to third parties if this is necessary for the fulfillment of contractual obligations (for example to payees as well as stock exchanges and brokers in the context of financial services, to beneficiaries and insurers as well as co-insurers and reinsurers in the context of insurance services, to employers as well as medical service providers and experts in the context of insurance, pension, fiduciary, or broker services), to comply with legal or regulatory requirements (for example to public authorities, courts), to protect legitimate interests (for example to service providers in the context of an outsourcing arrangement) or if

you have given your consent.

 

If personal data is disclosed to service providers in the context of an outsourcing of tasks (for example, to IT service providers, marketing service providers, providers of communication and printing services, claims adjusters), such service providers may only process such personal data in the same way as MWM may do so itself. MWM selects its service providers carefully and obligates them contractually to comply with confidentiality obligations and to ensure data security.

 

If personal data is disclosed to service providers in the context of an outsourcing of tasks (for example, to IT service providers, marketing service providers, providers of communication and printing services, claims adjusters), such service providers may only process such personal data in the same way as MWM may do so itself. MWM selects its service providers carefully and obligates them contractually to comply with confidentiality obligations and to ensure data security.

Under no circumstances will personal data be sold to third parties for marketing or other purposes.

 

7. Disclosure of personal data abroad

The recipients of personal data mentioned in section 5 may be located in Switzerland or abroad. Personal Data may therefore be processed anywhere in the world.

 

When disclosing personal data abroad, MWM ensures that the country in question has an adequate level of data protection or that appropriate data protection is contractually guaranteed with the recipient, unless disclosure abroad is based on a legal exception in individual cases (for example for the conclusion and fulfillment of our contracts, for the defense or enforcement of legal claims in proceedings and lawsuits).

 

 

8. Profiling and automated individual decisions

MWM may automatically analyse and evaluate personal data in order to recognize characteristics, predict developments and create profiles (so-called profiling). Profiles are used in particular to provide you with optimal support (for example personalized offers) and to tailor marketing measures to your needs. As part of the assessment of creditworthiness,
MWM may use so-called scoring. Thereby, the probability is calculated with which

payment obligations are fulfilled according to the contract.

 

As a rule, MWM does not make individual decisions that are based exclusively on automated processing of personal data. If automated individual decisions are used, affected persons will be informed about it according to the legal requirements and they will be granted the legally provided rights.

 

 

9. Retention period

How long personal data is processed depends on the processing purpose in section 4. MWM takes into account in particular the legal or regulatory retention periods, the protection of its legitimate interests (for example for contacting and maintaining contacts), as well as technically required data storage.

 

10. Rights

You may request information about your personal data processed by MWM and, in particular, you have the right to object to the processing of your personal data or to request the deletion of your personal data.

However, these rights are not unlimited: In particular, legal or regulatory obligations (for example, the fulfillment of disclosure and information obligations) or the protection of legitimate interests (for example for the defense or enforcement of legal claims in proceedings and lawsuits before or by authorities and courts) may make further processing of your personal data necessary in individual cases. 

In order for MWM to comply with your request for information, you must always submit your request in writing to MWM, together with a copy of a valid official identification document (for example passport, ID, driver's license). 

If your personal data is processed for marketing purposes, your right to object also applies to marketing activities (for example mailings, newsletters) and profiling for marketing purposes. You can stop unwanted marketing activities at any time by informing MWM of your wish. 

If the processing of your personal data is based on consent, then you can revoke this consent at any time. However, such a revocation is only effective for the future. Personal data that were processed before are not affected by a revocation.

 

11. Final provisions

MWM can adapt its privacy policy at any time by publishing it on the website.