Lawsons Wealth understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://lawsonswealth.com/ and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
- “Cookie Law” means the relevant parts of the Swiss Telecommunications Act;
Information About Us
Our site is owned and operated by Lawsons Network AG, registered in Switzerland under company number CHE-394.490.386. Lawsons Wealth is a division of Lawsons Network AG.
Registered address: Route de Malagnou 40a, 1208 Genève, Switzerland
Data Protection Officer: Mark Butcher
Email address: firstname.lastname@example.org
Telephone number: +41 41 508 70 11
Postal address: Route de Malagnou 40a, 1208 Genève, Switzerland
We are regulated by SO-FIT (Organisme de Surveillance pour Intermédiares Financiers & Trustees) – License No. 1202.
What Does This Policy Cover?
What Is Personal Data?
Personal data is defined by the GDPR and the revised (DPA) Swiss Federal Data Protection Act (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e., prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
What Data Do You Collect and How?
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. We use your personal data to respond to your message or enquiry submitted on a website form or for providing and managing your access to your Client Portal.
With your permission AND/OR were permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and the Swiss Unfair Competition Act 2007, and you will always have the ability to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- If you register a web query your personal data will be kept for 2 years
- If you have our services provided to you, we’ll retain personal data which is necessary to provide the services. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship. We are also subject to regulatory requirements to retain your data for specified minimum periods.
These are, generally:
- Five years for investment business
- Indefinitely for pension transfers and opt-outs
- Three years for insurance business
How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in our cloud-based systems on secure servers. We will only store your personal data within Switzerland, the European Economic Area (the “EEA”) and the UK. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from Switzerland and the UK are permitted without additional safeguards.
The security of your personal data is essential to us, and to protect your data, we take several important measures, including the following:
- Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
- The Company has in place procedures for the detection, investigation, and reporting of data breaches. This Policy applies to all data breaches (including personal data breaches) within the Company and is designed to assist in both the handling of such breaches and in determining whether or not they must be reported to the ICO and/or to data subjects.
- The Company’s Data Protection Officer, Mark Butcher, email@example.com is for the implementation of this Policy, for overseeing the handling of all data breaches, and for ensuring that this Policy is adhered to by all staff.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails) and by managing your Account in your Client Portal.
Can I Withhold Information?
You may access certain areas of our site without providing any personal data at all. However, to submit a message or enquiry on a web form or to access the Client Portal you will be required to submit or allow for the collection of certain data.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on our site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our site may not function fully or as intended.
Our site uses analytics services provided by google analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and the services offered through it.
The analytics service(s) used by our site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our site use of them does not pose any risk to your privacy or your safe use of our site, it does enable us continually to improve our site, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Telephone number: +41 41 508 70 11
Postal Address: Route de Malagnou 40a, 1208 Genève, Switzerland