Aspen Asset Management AG and its subsidiaries ("Aspen Asset Management AG," "we," or "us") appreciate your interest in our goods and services and welcome you to our website, mobile applications, and other electronic services (collectively, "Electronic Services").

Appropriate data protection is vital to Aspen Asset Management AG. This page describes how we handle your personal data when you use our Electronic Services (the "Privacy Policy"). You certify that you are 18 years of age or older by continuing to use the Aspen Asset Management AG Electronic Services.

Purpose And Scope Of The Privacy Notice

It is vital to us to protect your privacy and treat the personal data of all users of our Electronic Services in line with the law. We recognize that by using our Electronic Services, you may be entrusting us with personal data ("data"), and we assure you that we take our responsibility to preserve and safeguard this data very seriously. As a result, this Privacy Policy describes what types of data we collect when you use our Electronic Services, why we collect it, how we collect it, who we may share it with, and the security measures we've put in place to secure it.

This Privacy Policy covers any information we collect from you when you use our electronic services. It does not apply to data we collect through other means, nor to third-party Electronic Services ("third-party Electronic Services"), even accessing them through a link in our Electronic Services or if they are required for our Electronic Services to function. We have no control over the content or privacy policies of third-party Electronic Services; thus, we cannot be held liable for them.

Types Of Data Being Processed

When you use our Electronic Services, our backend systems may automatically record information about your usage (such as your IP address, http-header user agent, browser, device-specific information the content you accessed, time and date of access, user interaction, usage, and the redirecting website from which you came to our Electronic Services). Aspen Asset Management AG also processes personal data such as your name, address, e-mail address, phone number, gender, date of birth, and other information you provide to us when you register for our Electronic Services or fill out an application form.

The legal basis for data processing and the purpose of data processing

The following legal reasons are used to process the data:

  • For the purposes of carrying out a contract to which you are a party or taking actions at your request prior to entering into a contract;
  • For the purpose of complying with a legal duty to which we are bound;

In order to protect our legitimate interests

The data is processed for the following purposes:

  • To follow the bank's own internal policies;
  • To verify a client's identity and eligibility for particular products and services;
  • To provide a foundation for future information about Aspen Asset Management AG 's goods and services and to increase the quality of that information;
  • To make technical administration, research, and development for the Aspen Asset Management AG Electronic Services more efficient;
  • To guarantee that our IT infrastructure is secure and functional;
  • It will be used for marketing and advertising purposes;
  • To analyze and monitor the use of the Electronic Services, as well as user behavior and navigation while using them;
  • To make client management easier.

All of your personal data is processed in compliance with relevant data protection regulations and for as long as is necessary.

Disclosure Of Electronic Services Usage Data

Aspen Asset Management AG only distributes Electronic Services use data to third parties as authorized by law, if we are legally required to do so, or if disclosure is required to enforce our rights, such as claims resulting from a contractual agreement. We may send data inside Aspen Asset Management AG between Group companies in Switzerland and overseas for this reason and improve our goods and services. Additionally, if necessary for providing products and services, we may release data to third-party service providers. Such service providers are prohibited from using the information for any reason other than processing the order in question. All of the following individuals and companies that may receive data must comply with all applicable data protection laws, as well as Aspen Asset Management AG's data protection standards.

On request or under a continuing obligation to give information, Aspen Asset Management AG may disclose data to authorities, judicial authorities, or other people of authority, as required by relevant legislation.

Security Measures Of Aspen Asset Management AG

Taking into account the applicable legal and regulatory requirements, Aspen Asset Management AG will make every effort to implement appropriate technical and organizational security measures to ensure that your personal data processed within the Aspen Asset Management AG-controlled IT environment is protected against unauthorized access, misuse, loss, and/or destruction.

Firewalls, passwords, and encryption and authentication technologies are all used by Aspen Asset Management AG to protect both physical and electronic processes. Our workers and the service providers we hire are obligated to maintain professional secrecy and abide by all data protection laws.

Furthermore, access to personal data is limited to those employees, contractors, and third parties that require it for data processing and the supply of products and services (need to know principle).

Transmission Of Data Via An Open Network

Aspen Asset Management AG would like to remind you that if you use our Electronic Services over an open network, third parties (such as app stores, network providers, or the manufacturer of your device) may be able to access and handle your data from wherever they are. Aspen Asset Management AG has no control over open networks; thus they cannot be considered a secure environment. Data may be intercepted, altered, corrupted, lost, destroyed, arrive late or incomplete, include viruses, or be monitored during transmission via such an open network. Data transferred via an open network, in particular, may leave the nation – even if both the sender and the receiver are in the same country – and be sent to and potentially processed in third-party countries, where data privacy laws may be less stringent than in your home country.

We cannot be held responsible for the security of data transferred via an open network, and we assume no responsibility or liability for the security of your data during transmission. As a result, we advise against sending any private information via open networks.

Cookies

Cookies are used by Aspen Asset Management AG Electronic Services for statistical purposes as well as to improve the user experience. Cookies are tiny files that are saved on your computer to keep track of your visit to the Electronic Services and your choices; as you navigate between sites; and to remember settings between visits. Cookies assist Electronic Services developers in gathering information about how often users visit specific sections of the site and in customizing Electronic Services to be more helpful and user-friendly.

Please keep in mind that most web browsers allow cookies by default. You may choose your browser not to save any cookies or just specific types of cookies on your device or always display a warning when a new cookie is received. However, disabling cookies may prohibit you from accessing certain features of our Electronic Services. Cookies are only permanent for a user session and are erased after the session is over for some Electronic Services.

Analysis Tools

For the purpose of reporting on Electronic Services, we employ a variety of third-party analytic tools, such as Google Analytics. This entails the production of pseudo-anonymized data, and the usage of cookies to analyze how users interact with our Electronic Services. These cookies collect information about your usage of the site, such as:

  • The identity of the electrical device that is being used to access the internet (masked IP address)
  • Referrer URL type/version of browser used operating system (website from which visitors are redirected to the Aspen Asset Management AG Electronic Services by clicking a link)
  • Server request device's date and time

Personal data may be sent to third-party servers in countries outside of the European Union for analysis.

Links

Electronic Services provided by Aspen Asset Management AG may contain connections to third-party Electronic Services that are not controlled or monitored by us. Please be warned that such third-party Electronic Services are not subject to this Privacy Policy and that we are not to be held responsible for their content or data handling policies. As a result, we urge that you review and consult the privacy policies or terms of service of third-party Electronic Services.

Data Subject Rights

You may have the following rights under relevant data protection laws and regulations:

  • requesting information about the personal data we hold about you.
  • requesting that the information be corrected if it is incorrect.
  • requesting that your data be deleted if the Bank is not permitted or legally required to keep the data.
  • requesting that the processing of your data be restricted.
  • objecting to the processing by us, and requesting that your data be transferred in a generally usable, machine-readable, and standardized format.

You also have the right to file a complaint with the relevant Data Protection Supervisory Authority.

Questions / Contact

If you have any queries about how your personal data is processed, please contact us using the following information:

Aspen Asset Management AG
+82 2 3143 9360
info@aspen-am.com