Privacy Policy

Personal data (usually referred to just as “data” below) will only be processed by us to the extent necessary and for the purpose of providing a functional and user-friendly website, including its contents, and the services offered there.

Per Art. 4 No. 1 of Regulation (EU) 2016/679, i.e. the General Data Protection Regulation (hereinafter referred to as the “GDPR”), “processing” refers to any operation or set of operations such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction performed on personal data, whether by automated means or not.

The following privacy policy is intended to inform you in particular about the type, scope, purpose, duration, and legal basis for the processing of such data either under our own control or in conjunction with others. We also inform you below about the third-party components we use to optimize our website and improve the user experience which may result in said third parties also processing data they collect and control.

Our privacy policy is structured as follows:
I. Information about us as controllers of your data
II. The rights of users and data subjects
III. Information about the data processing

I. Information about us as controllers of your data

The party responsible for this website (the “controller”) for purposes of data protection law is:

Legacy CAM SA
Via Pretorio 9
CH-6900 Lugano

Switzerland

Telefono +41 91 260 36 00

privacy@legacy-cam.ch

www.legacy-cam.ch

The controller’s data protection officer is: Andrea Grassi, Managing Partner

II. The rights of users and data subjects

With regard to the data processing to be described in more detail below, users and data subjects have the right

In addition, the controller is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.

Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the controller’s future processing of their data pursuant to Art. 6 Para. 1 lit. f) GDPR. In particular, an objection to data processing for the purpose of direct advertising is permissible.

III. Information about the data processing

Your data processed when using our website will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations or unless otherwise stipulated below.

Cookie

a) Session cookies

We use cookies on our website. Cookies are small text files or other storage technologies stored on your computer by your browser. These cookies process certain specific information about you, such as your browser, location data, or IP address.

This processing makes our website more user-friendly, efficient, and secure, allowing us, for example, to display our website in different languages.
The legal basis for such processing is Art. 6 Para. 1 lit. b) GDPR, insofar as these cookies are used to collect data to initiate or process contractual relationships.
If the processing does not serve to initiate or process a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Art. 6 Para. 1 lit. f) GDPR.
When you close your browser, these session cookies are deleted.

b) ) Third-party cookies

If necessary, our website may also use cookies from companies with whom we cooperate for the purpose of advertising, analyzing, or improving the features of our website.

Please refer to the following information for details, in particular for the legal basis and purpose of such third-party collection and processing of data collected through cookies.

c) Disabling cookies

You can refuse the use of cookies by changing the settings on your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support. Browser settings cannot prevent so-called flash cookies from being set. Instead, you will need to change the setting of your Flash player. The steps and measures required for this also depend on the Flash player you are using. If you have any questions, please use the help function or consult the documentation for your Flash player or contact its maker for support.

If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.

Contact

If you contact us via email, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your inquiry; otherwise we will not be able to answer it in full or at all.

The legal basis for this data processing is Art. 6 Para. 1 lit. b) GDPR.

Your data will be deleted once we have fully answered your inquiry and there is no further legal obligation to store your data, such as if an order or contract resulted therefrom.

Google Analytics

We use Google Analytics on our website. This is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google).

Through certification according to the EU-US Privacy Shield

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.

The Google Analytics service is used to analyze how our website is used. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.

Usage and user-related information, such as IP address, place, time, or frequency of your visits to our website will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.

The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. This data can also be used to provide other services related to the use of our website and of the internet in general.

Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at


https://www.google.com/intl/de/policies/privacy/partners,including options you can exercise to prevent such use of your data.

In addition, Google offers an opt-out add-on at

https://tools.google.com/dlpage/gaoptout?hl=en

in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics’ JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.

Terms of Use

General

Please read the following legal notice/terms and conditions of use (“Terms of Use”) carefully before accessing the website (the “Website”) of Legacy CAM SA. By accessing the Website, you confirm that you have read and understood the Terms of Use and agree to all the terms set out herein. If you do not understand or do not agree to any of the terms contained in the Terms of Use, do not access, or use this Website in any way.

Access Restrictions

This Website offers certain information about the approach of Legacy CAM SA to investment advisory management services. No information on the Website is intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution, publication or use would be contrary to local law or regulation. Individuals or legal entities in respect of whom such prohibitions apply, whether on grounds of their nationality, their place of residence or on other grounds, must not access or use the Website.

Use of information and material

This Website and the information herein are for general information purposes only and are subject to change without notice. Unauthorized use of the Website, misuse of any information posted on this Website, is strictly prohibited. Legacy CAM SA reserves the right to change these Terms of Use from time to time. Legacy CAM SA takes no responsibility for all liability, direct or indirect, completeness, correctness and accuracy of the information published on the Website and has no obligation to update, delete and/or replace any outdated information on the Website.

No offer, no recommendation, no advice, no warranty, no guarantee, no orders

The information and materials published on this Website are provided for general consumption only and should not be construed as to provide tax, legal or investment advice. They do not constitute any advertisement, offer, recommendation or solicitation. The information contained on this Website is not suitable for use as a basis for decision-making. Any indication of past performance of financial instruments and/or investment strategies published on the Website is no indication or guarantee of future performance. Moreover, investments in financial instruments are subject to multiple risks (including but not limited to currency risk, geographic risk, industry risk and economic risk) and may result in a complete loss of the invested assets. Therefore, you are strongly advised to consult with your own personal financial advisors before making any investment in financial instruments.

Disclosure of information

Legacy CAM SA has the right, but not the obligation, to monitor any activity and material associated with the Website. Please also read the Legacy CAM SA Privacy Policy, which explains how personal information you provide to Legacy CAM SA will be used. The Privacy Policy forms an integral part of these Terms of Use.

Disclaimer of warranties

No warranty is given that the Website will operate error free or without interruption, that any faults will be corrected, or that the Website and servers from which information is accessible will be free of viruses, trojan horses, worms, or other harmful malware, components, and programs and Legacy CAM SA accepts no liability in respect thereof.

Limitation of liability

Legacy CAM SA gives no warranty that the information provided on its website is up-to-date, accurate or complete and accepts no liability in respect thereof. Under no circumstances shall Legacy CAM SA be held liable for any direct, indirect, or consequential damages whatsoever, or for any loss or damage resulting either directly or indirectly from use of the Website its information, documents, forms, links etc. or from risks associated with the financial markets.

Indemnity

You agree to indemnify, defend and hold harmless Legacy CAM SA from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including reasonable attorneys’ fees) arising from or relating to: (a) your use of the Website; (b) your breach of any terms and conditions contained in these Terms of Use or any representation, warranty or covenant made by you herein; or (c) your violation of any applicable law, statute, ordinance, regulation or any third party’s rights. This obligation survives the termination of these Terms of Use.

Intellectual property and copyright

The entire content of the Website is subject to copyright protection with all rights reserved to Legacy CAM SA Nothing on the Website shall be construed as the granting of any license or right to use any image, trademark, logo or software published therein. Any downloading or copying of the whole or any part of this Website shall not transfer any title in any intellectual property rights to you. Copyright notices and trademarks may not be changed or removed. Components of the Website may not be reproduced in whole or in part in any manner or form (including electronic or printed form) without the prior written consent of Legacy CAM SA and unless full acknowledgement of the source is provided. Users are not permitted to create hyperlinks or inline links from other websites to the Website without the prior written consent of Legacy CAM SA.

Links to other websites

The Website may contain links to the websites of other providers and information supplied by such providers (“External Links”). Please also read the Legacy CAM SA Privacy Policy, which explains how links to other websites will be used. The Privacy Policy forms an integral part of these Terms of Use.

Applicable law/place of jurisdiction

Access to and use of the Website as well as the Terms of Use shall be governed by and construed in accordance with Swiss law, with Lugano as the place of jurisdiction.

Disclaimer

The information on this website is not intended as an offer or solicitation to buy or sell any investment product, nor does it constitute any form of investment, legal tax or other advice, and as such it should not be relied upon in making an investment decision.

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