Privacy Policy

DATA PRIVACY NOTICE

Data protection under the Data Protection law of the European Union.

Legal Asset Servicing AG ("LAS", "we", "our", or "us") takes your privacy seriously. This Privacy Notice ("Notice") contains information on what Personal Data LAS and other companies of the group to which we belong (the "LAS Group") collect, what we do with that information, and what rights you have.

As part of our commitment to protect your Personal Data in a transparent manner, we want to inform you:

  • Why and how LAS collects, treats and stores your Personal Data;
  • The lawful basis on which your Personal Data is processed; and
  • What your rights and our obligations are in relation to such processing.

1. What does this Privacy Notice cover?

This notice applies to any and all forms of use of Personal Data ("processing") by us if you are a former, current or prospective client of Legal Asset Servicing AG in Switzerland.

2. What types of Personal Data do we collect?

For prospective clients with whom we have not yet made contact, we may collect (to the extent permitted by applicable law):

  • Personal identification details (such as name, address, nationality) and contact information (such as telephone, e-mail address);
  • Information related to professional profile (such as directorship/positions and professional networks).

For former and current clients or prospective clients with whom we are taking steps to enter into a business relationship, we collect (to the extent permitted by applicable law):

  • Personal details such as your name, phone number, business address, and electronic address;
  • Professional information about you, such as your job title;
  • Details of our interactions with you and the services you use, including electronic interactions across various channels such as e-mails and client portals;
  • Identifiers we assign to you, such as your client, business relation, contract, partner or account number; and
  • When you access LAS websites or applications, your activity in our products and services, data transmitted by your browser or device, and automatically recorded server data.

3. For which purposes do we process your Personal Data and what legal basis do we rely on?

We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process Personal Data, within applicable legal limitations, for the following purposes:

  • Client Onboarding:
    • To verify your identity.
    • For legal and compliance checks.
  • Client Relationship Management:
    • To manage our relationship with you, including communicating with you in relation to the products and services you obtain from us and our business partners, and handling customer service-related queries and complaints;
    • To help us to learn more about you as a client, your preferences on the products and services you receive, and other products and services, including those offered by us and our business partners you may be interested in receiving;
    • To collect and analyze your individualized and personal or anonymous and group-based activity and potential interests in the use of our products and services, of LAS websites, our applications for mobile devices and LAS platforms, multimedia portals and social networks.
  • Product implementation and execution:
    • To provide products and services to you and ensuring their proper execution, for instance by ensuring that we can identify you and carry out transactions in accordance with your instructions and the product and servicing terms; and
    • To provide IT solutions to you and ensure their proper execution in accordance with your instructions and our contractual arrangements with you, for instance by providing incident management and testing directly connected to the provision of the service.
  • Engaging in prospecting and business development and/or protecting and enhancing the LAS brand:
    • To evaluate whether and how LAS may offer products, services and events, including those offered by us, LAS Group entities, and our other business partners, that may be of interest to you;
    • To contact you for direct marketing purposes about products and services we think will be of interest to you.
  • Compliance and Risk Management and/or Crime Prevention, Detection and Investigation:
    • To carry out legal and regulatory compliance checks, including to comply with anti-money laundering regulations and fraud prevention;
    • To meet our on-going regulatory and compliance obligations, or in proceedings and investigating or preventing crime;
    • To receive and handle complaints, requests or reports from you or third parties;
    • To reply to any actual or potential proceedings, requests or the inquiries of a public or judicial authority.
  • Supporting, Enhancing and Maintaining LAS's technology:
    • To take steps to improve our products and services and our use of technology, including testing and upgrading of systems and processes, and conducting market research to understand how to improve our existing products and services or learn about other products and services we can provide; and
    • To analyze the results of our marketing activities to measure their effectiveness and relevance.
  • Other purposes:
    • For the LAS Group's prudent operational management (including compliance and risk management, technological support services, reporting, insurance, audit, systems and products training and administrative purposes);
    • To enable a transfer, merger or disposal to a potential buyer, transferee, merger partner or seller and their advisers;
    • To undertake transactional and statistical analysis, and related research; or
    • To exercise our duties and/or rights vis-à-vis you or third parties.

4. How do we protect your Personal Data?

All LAS employees and contractors accessing Personal Data must comply with our internal rules and processes in relation to the processing of your Personal Data to protect them and ensure their confidentiality. LAS has also implemented adequate technical and organisational measures to protect your Personal Data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing.

5. Who has access to Personal Data and with whom are they shared?

  • Within LAS Group: We usually share Personal Data with other LAS Group companies, for the purposes indicated in Section 3.1, to ensure a consistently high service standard across our group, and to provide services and products to you.
  • Outside LAS and the LAS Group: We transfer Personal Data to third parties such as professional advisers, service providers and authorities, in accordance with legal obligations and as necessary for providing our services.
  • Data transfers to other countries: The Personal Data transferred within, or outside LAS and the LAS Group, is in some cases also processed in other countries. We only transfer your Personal Data abroad to countries which are considered to provide an adequate level of data protection, or in the absence of such legislation that guarantees adequate protection, based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission).

6. How long do we store your data?

We will only retain Personal Data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. As far as necessary, we will keep your data for the duration of our business relationship subject to applicable legal and regulatory requirements. In addition, we might process your data after the termination of our relationship for compliance or risk management in accordance with the applicable laws as well as pursuant to various retention and documentation obligations or if it is in LAS's legitimate interest.

7. What are your rights and how can you exercise them?

Your rights regarding your Personal Data that we process can be found in the annex dedicated to the country you are domiciled in. To exercise your rights, please contact us at: info@legalassetservicing.com.

8. Changes to Personal Data

We are committed to keeping your Personal Data accurate and up to date. Therefore, if your Personal Data changes, please inform us of the change as soon as possible.

9. Updates to this Notice

This Notice was updated in October 2025. We reserve the right to amend it from time to time. Any amendment or update to this Notice we will make available to you here. Please visit the LAS website frequently to understand the current Notice.

10. LAS Entities in Switzerland covered by this Notice

The provisions herein apply to you if you are a resident in a foreign country listed above and have a contractual relationship with the following LAS entity in Switzerland:

Entity Name: Legal Asset Servicing AG
Registered Address: c/o Fellmann & Partner AG, Grafenaustrasse 7, 6300 Zug, Switzerland

ANNEX I – EU

Data protection under the EU General Data Protection Regulation (EU GDPR)

This appendix applies to any and all forms of use of the Personal Data of Clients domiciled in the EU by Legal Asset Servicing AG (LAS).

1. Legal basis for the processing of Personal Data

Depending on the purpose of the processing activity (see Section 3.1), the legal basis for the processing of your Personal Data will be one of the following:

  • Necessary for taking steps to enter into or executing a contract with you;
  • Required to meet our legal or regulatory responsibilities;
  • Necessary for the performance of a task carried out in the public interest;
  • Necessary for the legitimate interests of LAS, without unduly affecting your rights and freedoms; or
  • In limited circumstances, processed with your explicit consent (particularly for special categories of Personal Data).

Examples of LAS's legitimate interests include:

  • Managing our relationship with you;
  • Evaluating whether and how LAS may offer products and services;
  • Preventing fraud or misuse of our services;
  • Handling complaints and requests;
  • Improving our services and conducting market research;
  • Cooperating with public or judicial authorities; and
  • Ensuring a consistently high service standard across the LAS Group.

Where the Personal Data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this Personal Data there is a possibility we may be unable to onboard you as a client or provide services.

2. What are your rights and how can you exercise them?

You have a right to access and obtain information regarding your Personal Data that we process. If you believe any information we hold about you is incorrect or incomplete, you may request correction. You also have the right to:

  • Object to the processing of your Personal Data;
  • Request the erasure of your Personal Data;
  • Request restriction on the processing of your Personal Data;
  • Withdraw your consent where processing is based on consent.

When Personal Data is processed for direct marketing purposes, your right to object extends to direct marketing, including profiling. You may object to direct marketing by clicking the "unsubscribe" link in our emails or by contacting LAS (see Section 7 of this Notice).

Where we process your Personal Data based on your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your Personal Data be transferred to you (the 'data portability' right).

LAS will honor such requests, withdrawals or objections as required under applicable law, but these rights are not absolute. We may require proof of identity to respond to a request. If you are not satisfied with LAS's response, you have the right to lodge a complaint with the data protection authority in your country of residence or work. Contact details of EU Data Protection Authorities are available here: https://edpb.europa.eu/about-edpb/board/members_en