Privacy Policy 


With this Privacy Policy we, Semper Partners AG, describe how we collect and process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements are applicable to specific circumstances.

In this Privacy Policy, the term «personal data» refers to any information that identifies or could reasonably be used to identify any natural person. 

If you provide us with personal data of other individuals (such as family members or work colleagues), please ensure that those individuals are aware of this Data Protection Statement. Only provide us with their data if you are authorized to do so and ensure that the personal data provided is accurate. 

This Privacy Notice is in accordance with the EU General Data Protection Regulation («GDPR») and the Swiss Data Protection Act («DPA»). However, the application of these laws depends on each individual case.

A. Data Controller

The «controller» of data processing as described in this privacy policy (i.e. the responsible person) is:

Semper Partners AG
Grafenauweg 8
6300 Zug
info@semperpartners.ch
www.semperpartners.ch
If you have any questions regarding how your personal data is processed or any other data protection concerns, you can contact us using the above-mentioned contact details.

B. Purpose of Data Processing and Legal Bases

We primarily use collected data to enter into and fulfill contracts with our clients and business partners, particularly in relation to providing financial services to our clients and procuring products and services from our suppliers and subcontractors. We also process personal data to comply with domestic and foreign legal obligations. Additionally, in accordance with the applicable law and where appropriate, we may process personal data for the following purposes, which are in our (or, where applicable,  third parties') legitimate interest: 

  • Providing and developing our products, services and websites, apps and other platforms in which we are involved.

  • Communication with third parties and handling their requests (e.g., job applications, media inquiries). 

  • Advertisement and marketing (including event organization), provided that you have not objected to the use of your data for this purpose (if you are part of our client base and you receive advertisement, you may object at any time, and we will add you to a blacklist to stop further advertising mailings).

  • Asserting legal claims and defending against legal disputes and official proceedings. 

  • Prevention and investigation of criminal offenses and other misconduct. 

  • Ensuring the smooth operation of our IT systems, websites, apps, and other devices.

  • Acquisition and sale of business divisions, companies, or parts of companies, and other corporate transactions involving the transfer of personal data. This includes measures for business management and compliance with legal and regulatory obligations, as well as internal company regulations.

If you have provided us with your consent to process your personal data for specific purposes (for example when registering to receive newsletters), we will process your personal data within the scope of and based on this consent, unless we have another legal basis if one is required. You have the right to withdraw your consent at any time, but this does not affect the processing of data that occurred prior to the withdrawal. 

C. Collection and Processing of Personal Data

We primarily process personal data that we obtain from our clients, business partners, and individuals in the context of our business relationships. Additionally, we collect data from users when operating our websites, apps, and other applications. 

Where permitted, we may acquire certain personal data from publicly accessible sources (e.g., debt registers, land registries, commercial registers, press, internet) or receive such information from authorities, or other third parties (such as e.g., distribution agents, custodian banks). In addition to the data provided directly by you, the categories of data we receive from third parties include, but are not limited to: information from public registers, data received in administrative or court proceedings, information related to your professional role and activities (e.g., to conclude and fulfill contracts with your employer), information from correspondence and discussions with third parties, information provided by individuals associated with you (family, consultants, legal representatives, etc.) to conclude or process contracts with your involvement (e.g. powers of attorney), information regarding legal regulations such as anti-money laundering, bank details, information about you from media or internet sources (in specific cases, e.g. job applications, media reviews, marketing/sales, etc.), your address, and data related to your use of our websites (e.g., IP address, MAC address of your smartphone or computer, device and settings information, cookies, date and time of visit, accessed content and sites, used applications, referring website, localization data).In principle, we retain this data for 10 years after the completion of the processing purpose. However, this retention period may be extended if necessary for evidentiary reasons or to comply with legal or contractual obligations.

D. Cookies / Tracking and other relevant Information regarding the Use of our Website 

Technical Data

When you visit our website, we collect and evaluate user-specific data (e.g. IP address, web browser, operating system) and technical data (such as URLs of accessed pages, execution of search queries) in an anonymous manner. The mentioned data is collected and processed for system security, stability, error and performance analysis, as well as for internal statistical purposes. This allows us to optimize our website. For subscribing to our content or when submitting a contact form/customer login, we process the necessary data to provide the requested service. Depending on the specific service, the following data may be processed: email address, first name, last name, salutation, full address, subject matter, and message. If you have given us your consent to process your personal data for specific purposes (for example, subscribing to a newsletter or making an inquiry), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, if required. You have the right to withdraw your consent at any time, but this does not affect the processing of data that occurred prior to the withdrawal. In general, we retain technical data for 6 months.

E. Sharing Data with Third Parties and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing outlined above, we may transfer data to third parties, insofar as such a transfer is permitted and deemed appropriate for them to process the data on our behalf or for their own purposes. In particular, the following categories of recipients may be concerned:   

  • Our service providers (e.g. Risk Management & Compliance, IT-Provider, CRM-System) 

  • Domestic and foreign authorities, official bodies and courts

  • Other parties involved in potential or ongoing legal proceedings

Certain Recipients are located within Switzerland, but others may be located in any country worldwide. 

If a recipient is located in a country without adequate statutory data protection, we require the recipient to commit to data protection compliance (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection, or unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, overriding public interest, contractual disclosure requirements, your consent, or if data has been publicly available and you have not objected to its processing.

F. Duration of data storage

Your data, which includes personal data, will be processed and stored only for as long as necessary to fulfil our contractual and legal obligations or for the purposes stated in the data processing activities. This may include the entire duration of the business relationship and beyond, based on legal retention requirements and documentation obligations. It is possible that personal data will be retained for the time in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so, or if legitimate business interests require it (e.g. for evidence and documentation purposes). Once your personal data is no longer required for the above-mentioned purposes, it will be erased or anonymized, to the extent possible.


G. Data Security

We have taken appropriate technical and organizational security measures to protect your personal data against unauthorized access and misuse. These measures include issuing instructions, training, IT and network security solutions, access controls and restrictions, encrypting passwords, data storage devices and transmissions, pseudonymization and controls. We cannot guarantee the security of data transmission over the internet. When transmitting data by email, there is a certain risk of access by third parties.

H. Your Rights

In accordance with and as far as provided by applicable law, you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data or if we have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. We have already informed you of the possibility to object/withdraw consent at any time. Please be aware that exercising your rights may have implications for your contractual obligations and this may result in consequences such as premature contract termination or associated costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.  In general, exercising these rights requires that you are able to proof your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us via the details provided above.  In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch). 

I. Changes to this Privacy Policy 

We may amend this Privacy Policy at any time without prior notice. The current version published on our website shall apply. If the Privacy Policy is part of an agreement with you, we will notify you via e-mail or other appropriate means in case of an amendment.