Privacy Policy

1. Who we are

The data controller is Rubicon Asset Management SA, Rue du Général-Dufour 15, P. O. Box 5050, 1204 Geneva, Switzerland. For any question about this policy or about how we handle your data, please contact us at the address above, by telephone on +41 22 808 09 30, or via our contact page.

2. Personal data we collect

Depending on our relationship, we may collect: identification data (such as full name, nationality, date of birth and identity-document details); contact data (such as postal address, email and telephone number); financial, tax and employment-related information; data from your interactions with us (calls, emails and meetings); and technical information collected through your use of this website (such as IP address and browser type).

When you simply use the contact form, we collect only the information you provide there: your first and last name, email address, the subject of your enquiry and your message.

With your consent, we also use Google Analytics to collect aggregated, anonymised statistics about how this website is used. You can accept or decline this when you first visit, and withdraw consent at any time. See our Cookie Notice for full details, including the cookies set, the data processed and how to opt out.

3. Sources of personal data

We obtain personal data directly from you; from service providers (for example identity-verification and anti-money-laundering checks); from publicly available sources (such as commercial registers and sanctions lists); and from other third parties where you have consented.

4. Why we process your data

Legal and regulatory obligations: to comply with anti-money-laundering and counter-terrorist-financing rules, international sanctions, tax and investor-protection laws, and to respond to regulatory or judicial authorities.

Contractual relationship: to open and administer accounts, process instructions, prepare reports and assess the suitability of products and services.

Legitimate interest: to operate, secure and improve this website and our services, and to manage operational risk.

Consent: certain activities, such as direct marketing, are carried out only with your explicit consent, which you may withdraw at any time.

5. Sharing your data

Your personal data may be shared with trusted IT, compliance and email service providers who act on our instructions and are bound by confidentiality; with regulatory, judicial and tax authorities; with other professional advisers such as auditors and lawyers; and with any third party where you have consented or where disclosure is required by law.

6. International data transfers

Where data is transferred outside Switzerland, we ensure an adequate level of protection through appropriate safeguards, such as Swiss-approved standard contractual clauses, or by transferring only to countries whose data-protection regime is recognised as adequate by the Swiss Federal Data Protection and Information Commissioner (FDPIC).

7. Data security and retention

We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration or loss, and we limit access to authorised personnel.

We retain personal data for as long as necessary and, where applicable, for up to ten years or longer where required by financial-market, anti-money-laundering, tax, accounting or legal obligations, or for the establishment, exercise or defence of legal claims.

8. Your rights

Subject to applicable law, you may request access to your personal data and ask for it to be corrected, deleted or restricted; object to certain processing; request data portability; and withdraw consent at any time. To exercise these rights, please contact us in writing using the details in section 1. We may ask you to verify your identity before responding.

9. Transmission, hosting and security of this website

Please note that transmission of information over open networks such as the internet or email is never completely secure. While we take care to protect your data, we cannot guarantee its security during transit; you may use alternative means, such as registered post, to send us sensitive information.

10. Applicable law and jurisdiction

This Privacy Policy is governed by Swiss law. Any dispute arising from or relating to it is subject to the exclusive jurisdiction of the competent courts of the Canton of Geneva, subject to any right of appeal to the Swiss Federal Supreme Court.

11. Changes to this policy

We may update this policy from time to time. The date shown below indicates when it was last revised.