Legal notice

CORPORATE IDENTITY

KEYS INVESTMENT PARTNERS
20, rue Adrien Lachenal
1207 Geneva

SWITZERLAND
Tel.:+41(0) 228 400 348
E-mail: clientservice@keys-am.com

The Keys Investment Partners website is a site presenting the products and services offered by Keys Asset Management. The visitor who accesses these web pages acknowledges having had the opportunity to read the legal notices while browsing the website. The Information contained on this website is subject to regular checks and we endeavour to keep it updated without undue delay. However, if, despite all our efforts, errors may have occurred, please accept our sincere apologies. In any case, we invite you to check all data with our team. Moreover, Keys Asset Management reserves the right to modify at any time the content and/or the conditions of use of these web pages and/or withdraw access to these pages at any time.

PERSONAL DATA PROTECTION

In general, personal information about the user, such as first and last names, postal address and e-mail address, may be requested, particularly in the context of a request for documentation or the insertion of an e-mail message. Such personal information may occasionally be used for commercial purposes. And, unless you expressly state otherwise, Keys Investment Partners may make information about you available to partners. In accordance with the French Data Protection Act of 6 January 1978, amended in 2004, you have the right to access and rectify information concerning you, which you can exercise by contacting Keys Asset Management Group – 25B, Boulevard Royal L-2449 Luxembourg – clientservice@keys-am.com. On legitimate grounds, you may also object to the processing of data concerning you.

INTELLECTUAL PROPERTY, WARNINGS AND RESTRICTIONS ON WEBSITE ACCESS

The information contained on this website in the form of texts, photographs, illustrations, graphics, plans, is not contractual and may be modified at any time without notice. Keys Investment Partners holds the website copyright. This includes: images, texts, photos and all information that can be retrieved from this website. Any reproduction, partial or total representation of this website, by any means whatsoever, is strictly prohibited without the permission of Keys Asset Management. In any case, Keys Asset Management and its principals cannot be held responsible for any possible direct, indirect, technical or special damage that may result.

Any example or simulation of financing is only given as an example and as a reference value and Keys Investment Partners does not give any guarantee in terms of result. It is up to the user to check that they meet the legal and fiscal conditions to access financing or tax exemption from any professional of their choice (bank, solicitor, administration, etc.). Access to the funds on the site may be restricted to certain persons or countries. The funds may not be marketed, directly or indirectly, to US persons and/or any entity owned by one or more US persons as defined by the US Foreign Account Tax Compliance Act (FATCA) regulations.

Furthermore, the funds presented on this website may only be subscribed to in jurisdictions in which their marketing and promotion is permitted.

NO OFFER

The content published on Keys Investment Partners’ website is for information purposes only. It does not constitute an incentive, an offer or a recommendation.

Keys Investment Partners does not intend to provide investment, legal or tax advice through its website. Nor does it guarantee that the funds or strategies presented are suitable for a specific investor.

PERFORMANCES

Past performance is not a guide to future performance and is not constant over time.

COOKIES

Keys Investment Partners uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users navigate the site. The information generated by cookies about your use of the website (including your IP address) will be transmitted to and stored by Google on servers hosted in the United States. Google will use this information to assess your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf, including the publisher of this website. Google will not associate your IP address with any other data held by Google. You can disable the use of cookies by selecting the appropriate settings on your browser. However, such deactivation may prevent the use of certain features of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

DATA PROTECTION

  1. Data protection

At Keys Investment Partners, we take data protection very seriously. We apply a set of very high data protection standards, thereby fostering transparency in personal data collection and processing. This notice contains general information regarding personal data collected and processed by Keys Investment Partners in Switzerland.

As part of our commitment to ensure transparency in personal data protection, we would like to inform you of the following:

  • how and why Keys Investment Partners collects, uses and stores your personal data;
  • the legal basis for processing your personal data;
  • and your rights and our responsibilities for such processing

2. What type of personal data de we collect?

Keys Investment Partners in Switzerland (“Keys Investment Partners”, “we” and “our”) will collect and process your personal data. This includes:

  • Personal information such as your first and last names, telephone number, postal and e-mail address and the company you run/work for;

When you access our website, the data is transmitted by your browser and automatically saved by our server. This includes: the date and time of access, the file name accessed, the volume of data sent and access performance, your web browser, the browser language, requester domain name as well as the IP address. Additional data will only be saved via our website if it is disclosed of your own accord, e.g. when making a registration or a request. When visiting a Keys Investment Partners-related website, the latter will contain additional information as regards how we use your information during the time you consult our website;

3. Legal basis and our purpose when processing your personal data

3.1 Legal basis for processing your personal data

Depending on the purpose, your personal data will be processed as follows:

(i) Necessary for the legitimate interests of Keys Investment Partners and its business development, without unduly affecting your interests or fundamental rights and freedoms.

3.2 Processing purposes

We always process your personal data for a specific purpose and only process personal data relevant to that purpose. More specifically, we process personal data for the following reasons:

  1. a) Replying to your requests and messages;
  2. b) Scheduling your newsletter subscription.

3.3 Who has access to your personal data and who is your personal shared with?

The Personal Data is only intended for authorised personnel working within the marketing department who are responsible for answering requests for information. In this context, data may be shared within the Keys Asset Management Group.

  1. Public and regulatory authorities

As and when required, we disclose personal data to public authorities, regulators or government agencies. This applies as and when required by law or regulation, under a code of practice or conduct, or when we are required to do so by such authorities or agencies.

5. Personal data hosting

KEYS Investment Partners uses applications that may host Personal Data outside the European Union (EU) published by companies that have successfully completed the process of self-certification to the EU-US data protection shield (“Privacy shield”) or that have adopted standard contractual clauses that comply with federal laws on data protection. A copy of such clauses is stored by KEYS Investment Partners and is available for your perusal upon request.

6. How long do we keep your personal data?

Personal Data is kept for a three-year period from the date of its collection or, if you are already a client of KEYS Investment Partners, from the end of our business relationship. At the end of this period, KEYS Investment Partners will contact you to find out if you wish to continue receiving our newsletter and latest news. In the absence of an explicit positive response, your Personal Data will be deleted.

7. Your rights

You have the right to ask Keys Investment Partners to correct inaccurate personal data that we collect and process. You also have the right to request the limitation of your personal data until such a request is considered.

With your consent, we process your personal data. In doing so, you have the right to revoke such consent.

Under applicable data protection laws, you may write to the following email address: dpo@keys-am.com and:

  • request that your personal data be sent to you or another processing officer;
  • request that Keys Investment Partners send you a copy of all or part of your personal data that we collect and process.

You may also object, for reasons relating to your particular situation, to the processing of your Personal Data, by writing to dpo@keys-am.com or by using the “Unsubscribe” link included in the e-mails sent to you by KEYS Investment Partners.

For security reasons and to avoid fraudulent requests, KEYS Investment Partners reserves the right to ask you for proof of identity to exercise these rights. Such proof will be destroyed within one (1) year of collection.

8. Exercising your rights and filing your claims

Your may exercise your personal data rights by writing to dpo@keys-am.com or the postal address below:

Data protection officer, Keys REIM, 11 rue Jean Mermoz, 75008 Paris France

To avoid any delays in processing your request, please include a copy of your passport or personal ID with your signed letter.

If you are not satisfied with our response, you have the right to file a complaint with the data protection authority in your country of residence, or work, or wherever the source of your data-related problem lies.

9. Changes to your personal data

We are committed to keeping your personal data accurate and up-to-date. Please inform us as soon as possible if your personal data changes.

10. Other Switzerland-specific arrangements

List of Keys Asset Management entities in charge of data processing:

Keys Asset Management, L-2449 Luxembourg;

Keys REIM, 75008 Paris;

Keys Investment Partners, 1207 Geneva.