Mt Fort Advisers SA - Data Protection Policy (DPP)

MT FORT ADVISERS (for the purposes of this Notice, defined as Mt Fort Advisers SA, our subsidiaries and Appointed Representatives) recognizes the importance of protecting personal data. This Notice is designed to help you understand how your personal information is processed by MT FORT ADVISERS under the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).

MT FORT ADVISERS is committed to informing you of the following:

I. Types of personal data that is processed, as well as how and when it is gathered

The types of personal data that may be collected and processed in connection with prospective and/or existing business relationships include:

• Names, addresses, telephone numbers, email addresses, business contact information (identification data);
• Employment and job history, title, representation authorities (professional information);
• Information regarding the financial situation (such as origin of assets, investment objectives and experience, risk tolerance, financial and investment qualifications, income and account balances and trading and transaction history).
• Details of any interactions through emails, phone calls and meetings, including products you may be interested in;
• Cookies and similar technologies on websites and emails (cookie information); and
• Passport information and identification card numbers (identifiers issued by public bodies).

We collect or receive personal data:

• Directly from you, the data subject, through meetings and documentation submitted to us (including pre-contractual documentation and business cards); and
• Indirectly from external sources such as websites.

II. Purposes and legal bases for processing of personal data

Personal data collected may be processed in order to:

• Develop business relationships;
• Improve our services to you and/or provide you with information on MT FORT ADVISERS products and services;
• Initiate and manage your business relationship with MT FORT ADVISERS, including all related procedures to establish your identity;

Personal data is collected and processed for the following purposes:

• Provide administrative, investment advisory and/or management services in the context of carrying out our contracts with our clients or to carry out pre-contractual measures that occur in response to a request.
• The performance of a contract to which you are a party (as well as to take pre-contractual steps at your request), such as providing advice, routing your trades to our brokers, processing your transactions, maintaining and archiving your accounts and information, exchanging information with and passing on instructions to your custodian, client referrals) and can include needs assessments, advice, performance calculations, asset management and support, consultation with outside legal counsel as well as the routing of transactions.
• Assessment of identity and age verification, anti-fraud and anti-money laundering measures, the satisfaction of regulatory obligations to carry out compliance controls and monitoring, including of electronic communications, the satisfaction of tax law control and reporting obligations as well as the assessment and management of risks, including through consultation with outside legal counsel.
• The pursuit of our legitimate interests, to the extent that your interests are not overridden;
• To comply with legal or regulatory obligations.

In relation to our legal or regulatory obligations, provision of personal data may be mandatory. Please be aware that failure to provide such information may preclude MT FORT ADVISERS from pursuing a business relationship with, and/or rendering services to you.

III. How your personal data is handled and how long it is kept for

MT FORT ADVISERS does not conduct any profiling or assessment of your characteristics based on automatic processing of your personal data.

The disclosure of personal data to the third parties set out above may involve the transfer of data to the USA and other jurisdictions outside the European Economic Area (EEA) in accordance with the requirements of the GDPR. Such countries may not have the same data protection laws as your jurisdiction. Where such a transfer is made, MT FORT ADVISERS will ensure that EU Commission approved Standard Contractual Clauses or other appropriate safeguards permitted under data protection legislation have been put in place with relevant parties to whom personal data will be transferred.

Provided it is legally or otherwise authorized or required, MT FORT ADVISERS reserves the right to disclose or make accessible personal data to:

• Entities within MT FORT ADVISERS;
• Auditors, legal advisors and/or competent authorities; and
• Service providers (These are companies in the categories of financial services, IT services, logistics, printing services, telecommunications, collection, advice and consulting, including law firms, and sales and marketing).

• Public authorities and institutions (such as financial supervisory authorities, anti-money laundering and other financial authorities, criminal prosecution authorities) insofar as a statutory, regulatory or official obligation exists;

MT FORT ADVISERS undertakes not to transfer personal data to any third parties other than those listed above, except as disclosed to you from time to time or if required by applicable laws or regulations.

MT FORT ADVISERS will retain personal data for different periods of time as required to process the data for the purposes set out above or as required by applicable legal or regulatory requirements. MT FORT ADVISERS will then delete or anonymise personal data.

IV. Your rights as a data subject

As the subject of personal data collection or processing, you may request:

• access to and receive a copy of the personal data in structured, commonly used and machine-readable format;
• rectification of personal data that is inaccurate
• restriction of processing of personal data if inaccurate, unlawful or you have objected to the processing; and
• erasure of personal data where the processing is no longer necessary, or no longer lawful for other reasons, subject however to any applicable legal or regulatory retention requirements;

Subject to the limitations set forth herein and/or in applicable local data protection laws, you may exercise the above rights free of charge by contacting our Data Protection Officer. Where you have provided your consent to processing for the purposes stated above, you may also withdraw your consent at any time by contacting our Data Protection Officer.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by MT FORT ADVISERS or our service providers infringes the GDPR.

For any questions you may have in relation to this Privacy Notice or more generally the processing of your personal data within MT FORT ADVISERS, you may send a letter to:

Mt Fort Advisers SA
Rue de Lausanne 20bis
CH – 1201 Geneva

or contact us at the following e-mail address: contact@mtfortadvisers.com