Privacy and cookie notice KeyPeople AG
We are committed to protecting your privacy in line with
applicable data protection laws and regulations, in particular the
General Data Protection Regulation (EU) 2016/679 and (local)
This external privacy notice (hereinafter: notice)explains what
personal data we process, for what purposes, how we protect your
personal data and what your rights are in relation to your
personal data. ‘Personal data' (hereinafter: data) is any
information relating to a natural person that can be identified
directly or indirectly, in particular by reference to identifiers,
such as name and address.
In the course of our business proceedings and providing our
services, we need to process data. This notice applies to any data
processing of users of our websites, our (potential) customers,
clients, business partners, or other parties related to our
Our website may contain links to other websites that may process
your data. This notice is not applicable to any data processing on
third party websites. We are not liable for any damages as a
consequence of any data processing on those websites. Those
websites are subject to their own conditions and notices.
This notice may change from time to time. The most recent notice
can be found on our website. We encourage you to consult this
notice regularly in order to stay informed of any changes.
If you have any complaints or questions about this notice, please
feel free to contact us (§ 2).
2 Who is the data controller?
Currently, we have the following establishment:
KeyPeople AG, Alpenstrasse 15, Postfach7863, CH-6302 Zug,
KeyPeople AG is the ‘controller’ which means that it determines
the purposes and means of the data processing.
3 What data do we process?
We process the following data from our (potential) customers,
clients, business partnersor other parties related to our
Basic information: we ask you to provide us with basic
information, such as your name, prefixes, surname, title, gender
and date of birth for the purposes as set out in this notice,
including enabling us to provide you with information, respond
to your enquiries, offer our services to you or in relation to a
(potential) business or contractual relationship with you or
Contact information: we ask you to provide us with your contact
details, such as your address, e-mail address and phone number
for the purposes as set out in this notice, including enabling
us to respond to your enquiries or enabling you to register for
e-mail alerts (if any).
Financial information: in case of any transactions, we ask you
to provide us with financial information, such as your bank
Information from other sources: we also collect information from
other sources when conducting our day-to-day business, such as
those publicly available on external websites or other
information you choose to provide us with.
We process the following data from our website visitors:
Information we obtain automatically: we collect information
about you (automatically) when you visit our website. Our
estimate our audience size and usage patterns, store information
about your preferences and allow us to recognise you when you
return to the website. This information is processed for
analytical purposes or to improve our website. For more info,
please read § 12.
4 For whatpurposes do we process your data?
We will only process your data if necessary for one or more
specific purposes, such as, to:
- Verify your information, identify and contact you
- Assess and respond to your enquiries and requests if any
- Prevent and detect fraud or other crimes
- Prevent and detect fraud or other crimes
Provide you newsletters and other (commercial) information for
direct marketing purposes
Provide you with information about our funds and our other
Conduct research and to understand how our website and services
can be improved, including by using Google Analytics (§ 12)
Offer and improve any of our services, including our website o
Perform any contract with you
Fulfil tax, administration, anti-money laundering and other
purposes prescribed by law
We will never sell your data to third parties.
5 On what legal basis do we process your data?
We will process your data if the data processing is necessary:
For the purposes of legitimate interests of KeyPeople AG or
other parties, unless where such interests are overridden by
your interests or fundamental rights and freedoms. We rely on
this legal basis for antifraud investigations, working with
clients, maintaining business relationships with third parties
and to analyze or improve our website.
For the performance of any contract between you and KeyPeople
To comply with legal obligations, such as tax, administration,
anti-money laundering obligations and ‘know your customer’ due
6 With whom may we share your data?
KeyPeople AGmay share your data with third parties in the
We may share your data with our affiliates, operating groups and
subsidiaries if necessary for thepurposes as listed above.
KeyPeople AGwill require those parties to conduct activities in
a manner consistent with this notice.
We share your data with our ‘processors’. ‘Processors’ are third
parties that process data on our behalf, such as those providing
IT, webdesign, technical, HR, marketing or analytical services.
They only process your data for specific purposes and in
accordance with our instructions. We will only engage processors
that provide sufficient guarantees to implement appropriate
technical and organisational measures and ensure the protection
of your rights. We will also conclude data processing agreements
with our processors.
Employees of KeyPeople AGmay have access to your data, but only
if necessary for the performance of their tasks or specific
purposes -and only if they are bound by confidentiality.
We may share your data if required to do so by law, court order
or other legal process, e.g. with law enforcement agencies or
other governmental agencies or regulators, to establish or
exercise our legal rights or in connection with a corporate
transaction, such as a divesture, merger, consolidation, asset
sale or in the unlikely event of bankruptcy.
With advisers, accountants, lawyers and agents acting for us in
the course of our day-to-daybusiness subject to an agreement
with confidentiality and security provisions.
7 Where does KeyPeople AGstore or transfer your data?
Due to the nature of our business and the services we provide to
our customers, we may need to transfer your data to locations
outside the country where you reside. In case we transfer data, we
will value the requirement that such transfer is subject to
8 What measures does KeyPeople AGtake to protect your data?
KeyPeople AGhas taken appropriate technical and organisational
measures to ensure a level of security appropriate to the risks in
order to protect your data against accidental or unlawful
processing, including by establishing that:
- Your data are protected against unauthorized access
- The confidentiality of your data is being assured
The integrity and availability of your data will be maintained
Our personnel or personnel of third parties are trained in
information security requirements
Data breaches will be reported in accordance with applicable
laws (§ 9)
9 How do we deal with data breaches?
Under GDPR we need to notify the competent data protection
authority or authorities within 72 hours after we have discovered
a data breachunless the data breach is unlikely to result in a
risk to your rights and freedoms. When the data breach is likely
to result in a high risk to your rights and freedoms, we will also
notify the data breach to you without undue delay. In case you
will discover a (potential) data breach at KeyPeople AGor its
website, please contact us immediately (§ 2).
10 How long will we retain your data?
We will retain your data no longer than necessary for the purpose
for which we process your data. After the retention period we will
delete or anonymize your data, unless we need to retain certain
data for another purpose. If that is the case, we will have a
legal basis to do so and we will make these data only accessible
for that other purpose. An example is that we need to retain
certain information for statutory retention periods in order to
comply with tax or administration obligations,. In those cases, we
will only store the data necessary to fullfil our legal
obligations. Please contact us if you have questions about
specific retention periods.
11 What rights can you exercise in relation to your data?
Based on the law applicable to the use of your data, you may have
rights that you can exercise in relation to your data. Note that
in some cases we are not required to –fully –comply with your
request, as such rights may be conditional or because we haveto
balance your rights against our rights and obligations to process
your data and to protect the rights and freedoms of others. A
number of rights you have in the EEA are explained below:
Right of access: you are entitled to have access to your
personal data and request a copy of your data and to learn
details about how we use your data.
Right to rectification: we take reasonable steps to ensure that
your data is accurate and complete. If you believe this is not
the case, please ask us to update or amend your data.
Right to erasure: you have the right to ask us to erase your
data, e.g. where data processing is no longer necessary for the
purpose. However, we must balance this against other factors,
e.g. we are permitted not comply with your request due to legal
Right to restriction of processing: in certain circumstances,
you are entitled to ask us to (temporarily) stop using your
data. For example, where you think that your data is inaccurate
or where you think that we no longer need to use your data.
Right to object: you have the right to object to processing
based on our legitimate interests. We will no longer process
data on that basis when you file an objection, unless we have a
compelling legitimate ground for the processing. Please note
that you can always object to data processing for the purpose of
Rights relating to automated decision-making: you have the right
not to be subject to automated decision-making, including
profiling, which produces legal effect for you or has a similar
significant effect. If you have been subject to an automated
decision and do not agree with the outcome, you can contact us
and ask us to review the decision.
Right to data portability: you have the right to receive your
data which you have provided to KeyPeople AG, in a structured,
common and device-readable format and to transmit those data to
another company without our hindrance. This right only applies
where processing is automated and based on your consent or
Right to withdraw consent: currently, KeyPeople AGdoes not rely
on consent for data processing. However, if we would ask for
your consent, you have the right to withdraw your consent at any
time. KeyPeople AGwill stop further processing as soon as
possible after the withdrawal, but this does not affect the
lawfulness of the processing before consent withdrawal.
Right to lodge complaints. If you believe that any data
processing violates the law, you can contact us and we will
address your complaint as soon as possible. You have also the
right to lodge a complaint with the competent data protection
authority or start proceedings at a court. Please contact us if
you would like to exercise any of your rights.
on your device or browser when you visit our website. KeyPeople
AGmight also use techniques which are similar to cookies, such as
pixels, scripts, tags or web beacons. We include these techniques
under the definition of cookies. For storing and accessing cookies
for the sole purpose of performing communication via the internet,
we do not need your consent. We also do not need your consent for
cookies which are necessary to provide our services or analytical
cookies with privacy-friendly settings. We use Google Analytics
with privacy-friendly settings: with this tool we analyse how you
and other visitors use our website to get a better understanding
of our users and to improve ourwebsite. The information, such as
the amount of visitors, most popular parts of the website and how
much time our visitors spend on our website, will also be
processed by Google Inc. in the US. We will delete or anonymize
the information in accordance with § 10. For opting out of Google
Analytics, please click here. If you do not longer want KeyPeople
adjusting the settings in your browser. For instructions on how to
do this, please check the Help-function of your browser. However,
if you select this setting you may be unable to access certain
(additional) services or features of our website. Please note that
you are also able to delete the cookies on your device.
© Key People AG 2021