PRIVACY NOTICE

Atlanticomnium SA truly values and is committed to respect your privacy throughout our daily activities.

The purpose of this Privacy Notice is to inform about how we collect, store and process your personal data. It is separate and in addition to any client confidentiality obligations we may owe you in relation to regulations other than personal data protection ones. Please refer to our terms and conditions, applicable to your engagement, for further details on confidentiality.

1. WHO CONTROLS YOUR PERSONAL DATA?

Atlanticomnium SA, (“the Company” or “we” or “us”), located 13, route de Florissant, 1206 Genève, registered to the Commercial Register of Geneva under CHE-100.872.437, is your personal data controller.

We process your personal data and any personal data of individuals or entities related to you (together the “Data Subjects” or “you”), which you or a third party may provide to us. Typically, you will provide us with personal data in connection with our prospective and/or existing business relationship (“Business Relationship”), e.g. your use of our services, website (cookies).

We may process your personal data as controller or as joint controller (the “Controller”).

2. WHO TO CONTACT FOR QUESTIONS OR CLARIFICATIONS?

Feel free to write to your usual contact person with us and/or to : dataprotection@atlanti.ch

3. WHAT PERSONAL DATA DO WE COLLECT?

Personal data (“Personal Data”) includes any information, irrespective of the storage medium, relating to an identified or identifiable natural person, i.e., Data Subject.

Typically, we may process the following personal data:

  • Identification data, g., first name, family name, date of birth, gender, address, email, telephone numbers, nationality, citizenship, residency, identity documents.
  • Information on relevant family members and business relationships.
  • Education, g., professional qualifications, employment and professional information, references.
  • Human resources information, g., salary, pension.
  • Financial information, g., tax data, banking.
  • Website information, g., cookies, website-related technology information.

4. WHAT ARE OUR SOURCES OF COLLECTION?

We collect Personal Data at different times, and from different sources:

  • This includes compliances with the Swiss Data Protection Act (DPA) and the EU General Data Protection Regulation (GDPR), where applicable.
  • Directly from the data subjects, e.g., if and when you or your organisation contact us in relation to any Business Relationship.
  • Indirectly from other external sources, e.g., public information, information provided by other third parties, our website.

5. WHY (OUR PURPOSES) AND ON WHAT BASES DO WE PROCESS YOUR PERSONAL DATA?

We process your Personal Data in connection to our Business Relationships with Data Subjects (i.e., you and any personal data of individuals related to you). Kindly note that we may be under an obligation to collect and process certain elements of your Personal Data to comply with legal and regulatory requirements. Failing to provide such information will likely limit in all or in part our ability to maintain a Business Relationship with you.

For clarity’s sake, we do not process your Personal Data for any purpose unconnected to our Business Relationship, all the more to sell your Personal Data.

As illustrations, we process your Personal Data to:

  • Contact and identify Data Subjects;
  • Perform our contractual duties arising under our Business Relationship, g., to provide our services, to manage your relationship with custodian bank, to process payments and billing, to process and respond to Data Subjects queries including to provide third parties or authorities with relevant information;
  • Comply with any mandatory legal obligations to which we are subject, g., to keep tax and corporate records[1], to cooperate with or report to competent administrations, law enforcement authorities, regulatory bodies and/or public authorities.
  • Monitor, develop and improve our services and processes;
  • Establish, exercise or defend our legal rights;
  • Send newsletters and marketing material;
  • Monitor the use of the Website.

Accordingly, our main bases (alone or combined) to process your Personal Data is the performance of a contract, compliance with our legal obligations and for our legitimate interest. We are available to provide more detailed information as regards what base we rely on for certain purposes.

We may also rely on your consent to process your Personal Data, in which case we will inform you and seek your informed consent prior to any processing activity.

6. DO WE SHARE YOUR PERSONAL DATA OUTSIDE OF ATLANTICOMNIUM SA?

Yes, we may share your Personal Data with third parties other than us (“Third Party.ies“) if necessary and related to our Business Relationship and the Purposes set out under §5 above. We do so in full transparency with you and undertake to disclose any disclosure or transfer to a Third Party, e.g., in our contractual documentation.

In order to fulfill certain mandates, we may transfer Personal Data to the Swiss regulatory and fiscal authorities.

E.g., as per Swiss code of obligations, the Swiss Anti-Money Laundering Act, the Swiss VAT Act, and Swiss tax law.

7. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF SWITZERLAND?

Yes, we may disclose, transfer and/or store Personal Data outside of Switzerland (“International Transfer”); and we intend to do so with full transparency.

We will only transfer your Personal Data in connection with our Business Relationship and our Purposes for processing your Personal Data (see §5 above). Typically, we transfer Personal Data to service providers and custodian banks, as part of our efforts to strive for efficient and lean services that will ultimately benefit you.

8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU ENFORCE THEM?

We value and respect your rights and will do our very best to address and reply efficiently to you exercising them.

You may reach out to us (see our contact details under §2 above) to exercise your rights arising under applicable regulations, in particular your right to information / access, right to request rectification or erasure of inaccurate Personal Data, request erasure of Personal Data, request a restriction of processing, object to the processing, receive your Personal Data in a conventional electronic format (data portability).

You also have the right to withdraw your consent (previously given) to a specific processing activity. Your withdrawal will then apply prospectively, for future processing activities (no retroactive effect).

Please keep in mind that enforcement of your rights above may be subject to certain conditions and/or exceptions that may restrict their enforcement and/or limit our ability to assist and positively reply to you. We will endeavour to clarify and inform you accordingly.

Even if a Subject contests the processing of its data, we are entitled to continue such processing if it is (i) legally binding, (ii) necessary for the performance of the mandate to which the Data Subject is party, (iii) necessary for the performance of a public interest mission or (iv) necessary for the legitimate interests that the Company pursues, including the finding, exercise or defense of a right in justice.

9. HOW DO WE STORE AND SECURELY PROCESS YOUR PERSONAL DATA?

The Company undertakes to ensure that there are adequate levels of protection, in particular those relating to banking secrecy and data protection.

Subjects’ Data will be transmitted to and stored on Cloud, access to which is strictly limited. We have taken the appropriate technical and organisational precautions to ensure that our servers are accessible exclusively to duly authorised persons, as well as special precautions with regard to the protection of our technical environment (e.g., use of anti-viruses and Firewalls). Atlanticomnium’s Cloud provider also complies with the ISO 27001 standard (recognised by the OECD for Automatic Exchange of Information for tax purposes), combined with strong authentication and encrypted communications. As regards any paper files, we exclusively store them in Switzerland.

We electronically store your Personal Data on servers located in Switzerland, including backups. As regards any paper files, we exclusively store them in Switzerland.
We take all reasonable and necessary measures to securely process your Personal Data. Accordingly, we implement appropriate administrative, technical and physical measures which are reasonably necessary to protect the confidentiality, the integrity, the availability and the traceability of your Personal Data.

For transparency’s sake, where International Transfers (please see §7 above) take place, your relevant Personal Data will be stored on the recipient’s servers, possibly outside of Switzerland. See §7 above for further development in this respect.

10. HOW LONG DO WE KEEP YOUR PERSONAL DATA (RETENTION)?

We retain your Personal Data for as long as we need to carry out the purposes listed under §5 above. For clarity’s sake, these purposes include legal or regulatory requirements to keep Personal Data beyond the expiry of our Business Relationship.

If and when the Personal Data is no longer required to achieve the purposes, we will delete or anonymise the same.

11. ARE THERE ANY SANCTIONS IF ATLANTICOMNIUM SA DOES NOT RESPECT ITS OBLIGATIONS?

In the event that an employee of the Company fails to fulfil its obligations under this Privacy Notice, we apply the usual penalties provided for breaches of compliance obligations, such as more precisely stipulated in the employment contract concluded with each employee.

12. WHEN DOES THIS PRIVACY NOTICE COME INTO EFFECT?

This Privacy Notice entered into force with effect from 1 September 2023.

  • The Valuation date: October 7, 2024
    serieAsOFDateFKFund NameISINMTDYTDSIMTDYTDSI
    120,241,002GAM Sustainable Climate Bond fundIE000BSJBO140.00130.0506-0.02320.135.06-2.32
    220,241,002GAM Star Crdt Ops EUR InvIE00B50JD3540.00100.10460.64600.1010.4664.60
    320,241,002GAM Star Crdt Ops GBP InvIE00B510J173-0.00010.08950.9224-522.538.9592.24
    420,241,002GAM Star Crdt Ops USD InvIE00B57693100.00060.09840.85200.069.8485.20
    520,241,002GAM Interest Trend IncIE00BYM4P9130.00030.09690.38260.039.6938.26

  • Please read this important legal information before proceeding.

    Information contained herein are solely for the use of the person who has accessed this information and may not be reproduced or distributed, even partially, to any other person or entity.

    The material contained herein is confidential and intended solely for the use of the persons or entities with nationality of or respectively with their residence, domicile, registered office or effective administration in a State or Country in which distribution, publication, making available or use of the information is not contrary to applicable laws or any other regulation.

    The material contained herein is aimed at sophisticated, professional, eligible, institutional and/or qualified investors/intermediaries who have the knowledge and financial sophistication to understand and bear the risks associated with the investments described.

    The information is solely product-related and does not take into account any personal circumstances and does not qualify as general or personal investment recommendation or advice. In particular, the information is given by way of information only and does not constitute a specific legal offer for the purchase or sale of financial instruments. Moreover, nothing contained herein is constitutive of any tax advice.

    Every effort has been made to ensure the accuracy of the financial information herein but the information contained herein has not been independently reviewed or verified. Therefore, Atlanticomnium SA gives no assurance, express or implied, as to whether such information is accurate, true or complete and no responsibility is accepted by Atlanticomnium SA for any errors or omissions. Third-party content is the property of its respective provider or its licensor and is protected by applicable copyright law.

    Past performance is not indicative of future performance. The price of shares/units and the income from the funds/trusts can go down as well as up and may be affected by changes in rates of exchange or financial markets fluctuation, out of the scope of Atlanticomnium SA.

    To the fullest extent permitted by law, in no event shall Atlanticomnium SA or our affiliates, or any of our directors, employees, contractors, service providers or agents have any liability whatsoever to any person for any direct or indirect loss, liability, cost, claim, expense or damage of any kind, whether in contract or in tort, including negligence, or otherwise, arising out of or related to the use of the information provided.

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