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INFORMATION ON THE NEWSLETTER AND CONSENT
We are providing you with the following information to explain the content of our newsletter as well as the registration, dispatch and statistical evaluation processes and your right of objection. By registering for ZEST newsletter, you agree with the described processes and the following Privacy and Cookies Policy, as well as with ZEST’s Important Legal information, which can be found on www.zest-management.com.
CONTENT OF OUR EMAILS
We only send emails and other electronic notifications with advertising material (referred to hereinafter as the “newsletter”) with the consent of the recipients or legal permission. If specific content of the newsletter is altered during the registration process, this content is essential for the consent of the users. Our emails contain information regarding our products, market analysis, trends.
The content is intended of purely informative nature and shall in no way constitute an invitation, offer, recommendation or inducement to buy or to sell, to apply for or to subscribe to securities, financial instruments, financial or investment products or services, nor persuasion to effect transactions.
The newsletter may contain information on several collective investment schemes or financial products in general which are registered in different jurisdictions. Not all products described in the newsletter are available in all countries. The eligibility to purchase certain products is subject to laws and regulations that apply to the investor in his/her country of residence. We refer to our Important Legal information for further details.
USE OF THE EMAIL SERVICE PROVIDER
The monthly newsletter is dispatched by ZEST SA, Via Greina 3, 6900 Lugano, Switzerland.
The email addresses of our newsletter recipients and their further details described in this information are stored on ZEST servers.
You need to provide your name and your email address to register for the newsletter.
LEGAL BASE FOR THE TREATMENT OF PERSONAL DATA
This Policy sets out the policies and procedures of ZEST SA in relation to the collection, storage and sharing of personal data, with reference to the Swiss Federal Data Protection Law dated 19th June 1992 and the Regulation (EU) no. 2016/679 of the European Parliament and the Council dated 27th April 2016 on the Protection of Natural Persons with regard to the processing of personal data and on the free movement of such data.
USE OF YOUR PERSONAL INFORMATION
Your private data’s are primarily used for the regular sending of our monthly newsletter. From time to time we could send you other e-mails regarding events, research and publications. You can opt-out of receiving such additional information at any time by following the “unsubscribe” instructions at the bottom of those communications. Furthermore, we could use your personal information for internal marketing purposes.
PERSONAL INFORMATION WE MAY COLLECT
We may need to collect certain personal information in connection with providing our services, this information may include the following:
- Personal details (name, gender)
- Contact details;
- Assets held / wealth;
- Investment experience;
- Transaction history; and
- Website cookies, history and logs
HOW WE COLLECT THIS INFORMATION
We collect this information through various means. For example, when we obtain contact information for investor relations purposes, enter into agreements, for AML or due diligence purposes or when we are party to information relating to the purchase or sale of interests in a fund we manage. We collect personal information through each subscription of our newsletter and may also collect personal information from other companies.
STATISTICAL INFORMATION ABOUT YOUR VISIT TO OUR WEBSITE
When you visit ZEST Website, our systems collect personal information and statistical or non-personally identifiable information about your visit to our sites (e. g., IP address, pages visited, origin of visitor domains, and types of browsers used). However, unless you actively submit personal information, we do not typically identify you via the non-personally identifiable information. Notwithstanding the foregoing, to the extent permitted by applicable law, we reserve the right to combine non-personal information with personal information that you have actively submitted.
ZEST does not display or provide advertising facilities to third parties. The only third-party cookies used are for statistical and marketing purposes and are provided by Google Analytics, which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimizations our users appreciate the most.
HOW WE USE THIS INFORMATION
All financial companies need to, as required, collect and share customers’ personal information to run their everyday business. ZEST therefore may need to collect and share information to:
- Provide investment management services;
- Market products and services;
- Provide investor relation services;
- Respond to legal or regulatory investigations
Specifically, we use your information to deliver services to you, to respond to your questions and provide related customer services, to improve our services, to bill you for services you have received, and to communicate with you, to notify you about changes to our Website or other services, to detect and prevent fraud or other financial crime, to monitor and protect the security of our information, systems and network, for internal business intelligence purposes, product development and enhancement, and to ensure that content from our website is presented most effectively for you and your computer.
We will also use your contact details to provide you with information on our products and services that may be of interest to you. You can opt-out of receiving such information at any time by following the “unsubscribe” instructions at the bottom of those communications.
DISCLOSURE TO OTHERS
We may provide personal information to third firms that assist us in delivering our services, for example a broker or fund administrator. We require third-party service providers and financial institutions with which we have arrangements with to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them.
OUTSOURCING OF BUSINESS UNITS OR SERVICES
We can decide to outsource certain business units and services, wholly or partially, to third parties.
We carefully select any contractors who process personal data on our behalf. Where possible, we use service providers domiciled in Switzerland. The service providers might be entitled to outsource certain services to other third parties.
The services providers are only permitted to process the data received to the extent that we do ourselves. Additionally, they are contractually required to guarantee confidentiality and the security of personal data.
PROTECTION OF YOUR PERSONAL INFORMATION
To protect your personal information from unauthorized access and use, we use security measures that comply with relevant data protection laws. These measures include computer safeguards and secured files and buildings.
ACCESS AND REVIEW
You may, where permitted by applicable law and regulation:
- check whether we hold your personal data;
- request access to any personal information we hold about you and related information;
- request a copy of your personal data;
- require the correction of any of your personal data that is inaccurate;
- request that your personal information is deleted provided the personal information is not required by ZEST by applicable law or regulation, or for the establishment, exercise or defence of a legal claim;
- under certain circumstances prevent or restrict processing of your personal information, except to the extent processing is required for the establishment, exercise or defence of legal claims; and
- under certain circumstances, request transfer of your personal information directly to a third party where this is technically feasible.
You can exercise any of these rights by contacting us via e-mail at email@example.com.
RETENTION OF PERSONAL INFORMATION