Privacy Policy

ArchbridgeCapital AG (“Archbridge”), as a member of the financial services industry, has been and continues to be subject to laws and regulations regarding the collection and exchange of non-public personal information about a client. Archbridge may use this information in order to develop, offer, and deliver products and services, respond to inquiries from you or your representative, or to fulfill legal and regulatory requirements. Archbridge may collect non-public personal information about you from many sources, including the following.

Clients that choose to invest in or be advised byArchbridge’s trading programs and/or strategies may provide Archbridge with certain personal information about themselves. Such information may include:

Archbridge pledges its commitment to maintain the confidentiality of this information, and not to disclose this information to any non-affiliated, third parties other than (a) regulatory agencies or (b) affiliated or non-affiliated third parties, including your representatives, in order for them to assist us in providing services to you, and (c) otherwise as permitted by law. However, affiliated and non-affiliated third parties who receive information about you in order to assist us in providing services to you are restricted from using your information for any other purpose. Further, Archbridge agrees to protect a client’s information by restricting access to such nonpublic personal information to those employees with a legitimate need for the information. If a client decides to terminate their advisory or other account agreement, Archbridge agrees to adhere to the privacy policy and practices as set forth above. In the event Archbridge amends its privacy policy, it agrees to provide clients with appropriate notice when such privacy policy changes.

Client information will be retained by Archbridge for a period of five or ten years after a client decides to end their business relationship with Archbridge, as per regulation in relevant jurisdictions.

The policies and practices described in this disclosure are subject to change. Clients will be notified of a change via email or postal mail.

Archbridge has procedures in place to respond to requests to correct inaccurate information in a timely manner, and to update information and remove old information. Clients may verify their personal information on file with Archbridgeat any time by request. If a client needs to inform Archbridge of a correction they may do so electronically through channels outlined in their advisory or other agreements. Clients should notify Archbridge immediately if they receive information that they believe to be inaccurate. Clients with questions regarding the privacy policy should contact Archbridge in similar fashion.

Privacy Policy Annex: EU General Data Protection Regulation

This Annex outlines the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679), the (“GDPR”), as it relates to the data protection obligations of ArchbridgeCapital (the “Company”) and your data protection rights as they relate to your registration and use of the Company’s website, (the “Website”).

Your personal data

You understand that by virtue of registering on the Website and your associated interactions with the Company or by virtue of you otherwise providing the Company with personal information on individuals connected with you (for example directors, trustees, employees, representatives, shareholders, limited partners, investors, clients, beneficial owners or agents), you will provide the Company with certain personal information which constitutes personal data within the meaning of the GDPR. This includes, but is not restricted to, data such as your name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.

In the Company’s use of this personal data, the Company will be characterised as a “data controller” under the GDPR. The Company’s affiliates and delegates may act as “data processors” under the GDPR.

Why the Company may use your personal data

You understand that the Company may collect, store and use this data for lawful purposes including, in particular: (i) where this is necessary for compliance with a legal obligation to which the Company is subject (such as the anti-money laundering obligation to verify the identity of the Company’s customers and, if applicable their beneficial owners) and retain copies of materials in respect thereof for ten years after the relationship terminates); (ii) to verify investor eligibility / qualification; and/or (iii) where this is necessary for the purposes of the legitimate interests of the Company or a third party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms.

It is noted that the GDPR states that the use of personal data for direct marketing purposes (that is, providing you with information on products and services that may be of interest including the reporting of the Company’s trading program performance) may be regarded as being for the purposes of a legitimate interest. Analysing personal data for quality control, business and statistical analysis, tracking fees and costs, training and related purposes are also legitimate interests for the Company using your personal data.

Accordingly, you understand and agree that the Company may use your personal data for such purposes as described in this Annex, provided that the Company is acting in a fair, transparent and accountable manner and has taken appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such use, as discussed in this Annex.

Given the specific purposes for which the Company envisages using your personal data, under the provisions of the GDPR, the Company does not anticipate being required to obtain your consent to do so. Should the Company wish to use your personal data for other specific purposes that require your consent, the Company will ensure it has already obtained your consent or contact you to request your consent for such usage.

Why the Company may transmit your personal data

You understand that in certain circumstances the Company and/or its authorised affiliates and/or delegates may be legally obliged to share your data and other financial information with respect to your interest in the Company with a regulatory authority and they, in turn, may exchange this information with foreign tax authorities including tax authorities, such as the IRS that are located outside the EEA.

The data protection measures the Company takes

Any transmission of your personal data by the Company or its duly authorised affiliates and/or delegates inside or outside the EEA shall be in accordance with the conditions in the GDPR.

The Company and its duly authorised affiliates and/or delegates shall apply appropriate information security measures designed to protect data in the Company’s / its affiliates and/or delegates’ possession from unauthorised access by third parties or any form of computer corruption.

The Company shall notify you of any personal data breach affecting you that is likely to result in a high risk to your interests, fundamental rights or freedoms.

Your data protection rights

You understand that you have certain rights regarding the Company’s use of this personal data such as (but not limitedto):
the right to access your personal data (in an easily readable form);
the right to examine and correct your personal data;
the right to restrict the use of your personal data;
the right to withdraw any consent given to the processing of your personal data (where applicable);
the right to receive information regarding any entities the Company discloses your personal data to;
the right to lodge a complaint with the relevant.

You also have the right to object to the processing of your personal data where the Company has considered this to be necessary for the purposes of the Company’s legitimate interests.

Please note that the right for your personal data to be erased (the “right to be forgotten”) that applies in some contexts under the GDPR is not likely to be applicable to most, if not all, of the personal data you provide to the Company through the Website, given the specific nature of the purposes for which the Company uses the personal data, as described in this Annex.

Getting in touch

As the Company does not process personal data on a large scale, the Company is not required to designate a data protection officer. However, should you have any queries or wish to discuss your data protection rights with the Company, please contact us in accordance with your advisory and/or other agreement with us.