1. Data Controller
The controller responsible for the processing of your personal data is:
HPC Suisse SA
Via Adolfo e Oscar Torricelli 23, 6900 Lugano, Switzerland
Email: info@hpcsuisse-ch.com
Telephone: +41 44 523 60 50
2. Scope & Applicable Law
This Privacy Policy describes how HPC Suisse SA collects, processes and uses personal data in accordance with:
- The Swiss Federal Act on Data Protection (revised FADP / nFADP, in force since 1 September 2023);
- The EU General Data Protection Regulation (GDPR, Regulation 2016/679), where applicable;
- Sector-specific Swiss financial market regulations (FinSA, FinIA, AMLA).
3. Categories of Personal Data Processed
- Identification data: name, date of birth, nationality, identification documents.
- Contact data: address, email, telephone number.
- Financial data: account information, investment objectives, risk profile, transaction history.
- Technical data: IP address, browser type, device information, cookies, log files.
- Communication data: emails, call recordings (where notified), correspondence.
4. Purposes & Legal Basis of Processing
- Provision of services: performance of contractual obligations (Art. 6(1)(b) GDPR; Art. 31(2)(a) FADP).
- Legal & regulatory compliance: AML/KYC checks, FINMA reporting, tax reporting, suitability assessments under FinSA (Art. 6(1)(c) GDPR; Art. 31(2)(c) FADP).
- Legitimate interests: fraud prevention, IT security, business analytics (Art. 6(1)(f) GDPR; Art. 31(1) FADP).
- Marketing communications: only with your prior consent (Art. 6(1)(a) GDPR; Art. 31(1) FADP).
5. Data Recipients
We may share your personal data with:
- Authorised employees and directors of HPC Suisse SA bound by confidentiality;
- Custodian banks, brokers, and counterparties involved in executing your transactions;
- External service providers (IT, audit, legal, compliance) bound by data processing agreements;
- Swiss and foreign authorities where required by law (FINMA, tax authorities, courts).
6. International Data Transfers
Where personal data is transferred outside Switzerland or the EEA to countries that do not provide an adequate level of data protection, we implement appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission and the Swiss Federal Data Protection and Information Commissioner (FDPIC).
7. Retention Period
Personal data is retained only as long as necessary for the purposes for which it was collected, or as required by applicable law. Client records under FinSA and AMLA are typically retained for ten (10) years following the end of the business relationship.
8. Your Rights
Under Swiss FADP and EU GDPR, you have the right to:
- Access your personal data and obtain a copy;
- Request rectification of inaccurate data;
- Request erasure of your data (right to be forgotten);
- Restrict or object to processing;
- Data portability;
- Withdraw consent at any time (without affecting prior lawful processing);
- Lodge a complaint with the Swiss FDPIC (www.edoeb.admin.ch) or your local EU supervisory authority.
To exercise your rights, contact us at info@hpcsuisse-ch.com.
9. Cookies & Tracking Technologies
Our website uses cookies and similar technologies. For full details, see our Cookie Policy. You can manage your preferences at any time via the Cookie Preferences link in the footer.
10. Data Security
We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, alteration, or disclosure, in line with Swiss banking secrecy and FINMA requirements.
11. Changes to this Policy
We may update this Privacy Policy from time to time. The current version is always available on this page with the date of last update.
12. Contact & Data Protection Officer
For data protection inquiries, contact our Data Protection Officer at info@hpcsuisse-ch.com.