Privacy Policy

1. What does this Notice cover?

Fides Treasury Services AG (hereinafter referred to as “Fides” or “we”) only collects and uses personal data insofar as this is necessary for the provision of a functional website as well as for the provision of the relevant content and services of FIDES.

2. What types of Personal Data do we collect?

The personal data we process about you includes:

Your IP-address, information about the devices you use (if available) and/or name and contact details (for example name, address, phone number or email address) if you contact us via contact request form or per e-mail.

We equally process your birth and family data, professional profile data, financial and transaction information and potential conviction and offences data for compliance purposes.

2.1 Provision of the website and creation of log files

We or vendors on our behalf also collect certain information by automated means when you visit the Websites. The personal information collected may include usage information, such as the numbers and frequency of users to the Websites, pages visited, social networking activities; device information, such as operating system, browser type, and IP address; and similar data. The data is also stored in the log files of our system.

The temporary storage of the IP address by the system is necessary in order to enable the website to be delivered to the user’s computer. For this reason the IP address of the user must remain stored for the duration of the session.

The data is stored in log files in order to ensure the functionality of the website. In addition, the data help us to optimize the website and to ensure the security of our information technology systems. Data collected in this way will not be evaluated for marketing purposes.

The data will be erased as soon as they are no longer required in order to achieve the purpose for which they were collected. Where data is collected for the provision of the website, this occurs when the respective session ends.

The collection of data for the provision of the website and the storage of data in log files is absolutely essential for operation of the website.

2.2 Use of cookies

Our website uses cookies. Cookies are text files that are stored in the web browser, or by the web browser on the user’s computer system. When a user visits a website, a cookie may be stored on the user’s operating system. This cookie contains a distinct character string that enables the unique identification of the browser the next time the user visits the website.

We use cookies in order to make our website functional. Some elements of our web page need Cookies in order to identify the browser again after the user has visited another page. For example the language settings are stored and transmitted in cookies.

We also use cookies on our website that enable an analysis of the user’s browsing behavior. By the use of these cookies, the following data is usually transmitted to us: (1) Search terms entered, (2) Frequency of page views, (3) Use of website functions. When accessing our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of personal data used in this context is usually obtained.

Technically necessary cookies are used in order to make it easier for the user to browse the website. Some of the functions of our web pages may not be available unless cookies are used. For these functions it is essential that the browser is detected again after the user has visited another page.

We need cookies for the following purposes:

(1)        Applying language settings

(2)        Storing search terms

The user data collected by technically necessary cookies will not be used in order to create user profiles.

Cookies are stored on the user’s computer and transmitted by it to our website. As a user, therefore, you have full control over the use of cookies. You can disable or restrict the transmission of cookies by providing for the corresponding settings in your web browser. Cookies already stored can be deleted at any time. This may also be done automatically. If cookies for our website are disabled, it may no longer be possible to make full use of all functions of the website.

The transmission of flash cookies cannot be disabled by settings on the browser, but may be disabled by changes to the Flash Player settings.

For more information about the tracking technologies applied, please see the table in the Appendix I.

2.3 Contact forms and email contact

Our website provides contact forms that can be used to make contact electronically with us. If a user makes use of this option, the data entered in the input screen will be transmitted to us and stored.

The following data will also be saved at the time the message is sent:

(1)        The IP address of the user;

(2)        The date and time of registration;

(3)        The input at Google ReCaptcha.

Alternatively, you can make contact using the email addresses provided by us, namely: privacy@fides.ch. In this case the user’s personal data provided with the email will be stored in our systems.

We process the personal data provided by you in the input screen solely in order to handle the contact request. In the case of contact by email, this also establishes the necessary legitimate interest for us in processing the data. The other personal data processed during the send process is used to prevent any misuse of the contact form and ensure the security of our information technology systems.

The data will be erased as soon as they are no longer required in order to achieve the purpose for which it was collected. For the personal data from the input screen of the contact form and the personal data that was sent by email, this is the case when the respective conversation with you has ended. The conversation has ended if the circumstances suggest that the relevant matters have been finally clarified.

2.4 Web-tracking services

We are constantly aiming at enhancing our website. For this reason, we collect information through the website, i.e. domain name, tracking the pages you visit and the time spent on pages. Among others, Google Analytics supports us in this regard. They collect and process information through your browser when visiting this website. The user usually consents when visiting our website by accepting our Cookie Banner.

The respective information is used for statistical and marketing purposes only. The data will be erased as soon as it is no longer required in order to achieve the purpose for which they were collected. The data may also be stored without timely limitation, if it is only stored in an anonymized manner.

The collection of data for the enhancement of the website and its use for statistical and marketing purposes supports the operation of the website.

2.5 Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. For further details on Hotjar’s treatment of your personal data, please see: https://www.hotjar.com/privacy/.

2.6 Social-Media-Plugins

Our website uses social media plugins (“plugins”) from social networking sites such as Linkedin, XING etc. If you access our website using such a plugin, your browser will contact the server of the underlying social networking site, load the visual presentation of the plugin, and present it to you. While this is happening, the social networking site receives information concerning your visit to our website, as well as further data such as your IP address.

We have no influence on the amount of data that social networking sites collect via an active plugin. For more information, please consult the relevant data privacy notice under the following hyperlinks:

LinkedIn

XING

Youtube

The respective plugins are provided in order for visitors of this website to voluntarily follow us on the respective social networks.

2.7 HubSpot

For online marketing activities, we use HubSpot. This is an integrated software solution with which covers various aspects of our online marketing, including Content management (website and blog), Email marketing (newsletters and automated mailings, for example for the provision of downloads), Reports and Analytics, Contact management (CRM), Landing pages and contact forms.

With our registration service, we enable our website visitors to learn more about our company, download content and provide their contact information and other demographic information. This information is stored on servers of our software partner HubSpot within the European Area. We may use this information to contact visitors to our website and to determine which of our company’s services are of interest to them. All information collected by us is subject to this Privacy Policy. For more information about HubSpot’s privacy policy, please visit the HubSpot website: https://legal.hubspot.com/privacy-policy.

3. For which purposes we process your data and what legal basis we rely on?

3.1 Purposes of processing

We use your personal data for:

Client Onboarding:

• to verify your identity and assess your application. For legal and regulatory compliance checks (for example, to comply with anti-money laundering regulations, and prevent fraud).

Client Relationship Management:

• to manage our relationship with you, including communicating with you in relation to the products and services you obtain from us and from our business partners, handling customer service-related queries and complaints, facilitating debt recovery activities, making decisions regarding credit or your identity, tracing your whereabouts, and closing your account (in accordance with applicable law) if it remains dormant and we are unable to contact you after a period of time;
• to help us to learn more about you as a client, your preferences on the products and services you receive, and other products and services – including those offered by us and our business partners – you may be interested in receiving, based on the processing of your personal data, for instance by looking at the types of applications, platforms, products and services that you use from us, information we obtain via tracking technology and how you like to be contacted;
• to collect and analyze your individualized and personal or anonymous and group-based activity and potential interests in the use of our products and services, of our websites.

Engaging in prospecting and business development and / or protecting and enhancing our brand:

• to evaluate whether and how we may offer products, services and events – including those offered by us and our other business partners – that may be of interest to you;
• to contact you for direct marketing purposes about products and services we think will be of interest to you, including those offered by us and our other business partners;

Compliance and Risk Management and / or Crime Prevention, Detection and Investigation:

• to carry out legal and regulatory compliance checks as part of the onboarding process, including to comply with anti-money laundering regulations and fraud prevention;
• to meet our on-going regulatory and compliance obligations, apply a risk classification to ongoing business relationships, disclosures to tax authorities, financial service regulators and other regulatory, judicial and governmental bodies or in proceedings and investigating or preventing crime;
• to receive and handle complaints, requests or reports from you or third parties made to our designated units;
• to reply to any actual or potential proceedings, requests or the inquiries of a public or judicial authority;
• to prevent and detect crime, including fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks.

3.2 Basis for processing of Personal Data

We process your personal data within the applicable legal framework. Where required and depending on the purpose of the processing activity, the processing of your personal data will be one of the following grounds:

• when necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract;
• when required to meet our legal or regulatory responsibilities, including when we conduct the legal and regulatory compliance checks;
• necessary for our legitimate interests, without unduly affecting your interests or fundamental rights and freedoms and to the extent such personal data is necessary for the intended purpose;
• in some cases, we have obtained your consent (for instance where required by law) or processed, where required under applicable laws or regulations, with your explicit consent in the case of special categories of personal data); or
• in some cases, necessary for the performance of a task carried out in the public interest.

A legitimate interest is in particular considered in the following instances. The processing is necessary to:

• to manage our relationship with you and to help us to learn more about you as a client, the products and services you receive, and other products and services you may be interested in receiving;
• to evaluate whether and how we may offer products, services and events that may be of interest to you;
• to prevent fraud or criminal activity, misuses of our products or services as well as the security of our information, IT systems, architecture and networks and security of our premises;
• to receive and handle complaints, requests or reports from you or third parties made to our designated units;
• to take steps to improve our products and services and our use of technology and to conduct market research;
• to cooperate with a request made in any actual or potential proceedings or the inquiries of a public or judicial authority;
• to exercise our rights under Articles 26 and 27 of the Federal Constitution of the Swiss Confederation, including our freedom to conduct a business and right to property;
• to meet our accountability for prudent operational management and regulatory requirements around the world; and

Where the personal data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this personal data there is a possibility, we may be unable to on-board you as a client or provide products or services to you (in which case we will inform you accordingly).

To the extent that we process any special categories of data relating to you, we will do so because:

• the processing is necessary for the establishment, exercise or defense of a legal claim;
• the processing relates to personal data which are manifestly made public by you; or
• you have given your explicit consent to us to process that information (where legally permissible).

4. How we protect your personal data

All FIDES employees accessing Personal Data must comply with our internal rules and processes in relation to the processing of your personal data to protect them and ensure their confidentiality. We have also implemented adequate technical and organizational measures to protect your personal data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing.

5. Who we may share your personal data with

We may share your personal data with trusted third parties. For the purposes set out and where necessary, we may share personal data with courts, regulatory authorities, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavors to notify you before we do this, unless we are legally restricted from doing so.

5.1 Countries we transfer your personal data to

We may transfer your personal data to recipients abroad, including in countries that do not provide the same level of protection as your jurisdiction. Before we do so we will implement appropriate measures to protect your personal data, for example by requiring the recipient to agree to data processing agreements (if you would like to receive a copy of these agreements, please contact us at the address indicated above. These agreements are usually based on standard contractual clauses (SCCs). We may also transfer personal data with your explicit consent and in certain other situations as permitted by applicable law. Your personal data may be stored in the following territories: Switzerland, European Union, India.

6. How long do we store your data?

We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose.

As far as necessary, we will keep your data for the duration of our relationship subject to applicable legal and regulatory requirements. In addition, we might process your data after the termination of our relationship for compliance or risk management in accordance with the applicable laws as well as pursuant to various retention and documentation obligations or if it is in FIDES’ legitimate interest.

If you wish to have your Personal Data removed from our databases, you can make a request as described below, which we will review as set out therein.

7. What are your rights and how can you exercise them?

You have a right to access and to obtain information regarding your personal data that we process. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction of your personal data.

You also have the right to:

• object to the processing of your personal data;
• request the erasure of your personal data;
• request restriction on the processing of your personal data; and/or
• withdraw your consent where we obtained your consent to process personal data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

When personal data is processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing.

Where we process your personal data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your personal data be transferred to you (known as the ‘data portability’ right). You also have the right to ask us for information regarding some or all of the personal data we collect and process about you.

We will honor such requests, withdrawal or objection as required under applicable data protection rules but these rights are not absolute: they do not always apply and exemptions may be engaged. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.

In certain circumstances we may process your personal data through automated decision-making. Where this takes place, you will be informed of such automated decision-making that uses your personal data and be given information on criteria and procedures applied. You can request an explanation about automated decision making carried out and that a natural person reviews the related decision where such a decision is exclusively based on such processing.

7.1 Exercising your rights

To exercise the above rights, please contact:

Fides Treasury Services Ltd.
Data Privacy
Räffelstrasse 28
8045 Zurich
Switzerland
Email: privacy@fides.ch
Website: www.fides.ch

8. Updates and Versions

We may update this privacy policy from time to time. Latest policy update 03/2026.

Appendix I

List of Cookies / Tracking Technologies

Appendix II

Data protection under the EU/UK General Data Protection Regulation (GDPR)

This appendix applies to any and all forms of use of the personal data of clients domiciled in the EU and UK by FIDES.

As part of our commitment to protect your personal data in a transparent manner, we want to inform you about:

• the lawful basis for the use of your personal data; and
• what your rights are in relation to such processing and how you can exercise them.

1. Legal basis for the processing of personal data

 Depending on the purpose of the processing activity, the legal basis for the processing of your personal data will be one of the following:

• necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as when we use your data for some of the purposes;
• required to meet our legal or regulatory responsibilities, including when we conduct the legal and regulatory compliance checks and make the disclosures to authorities, regulators and government bodies such as when we use your data for some of the purposes;
• in some cases, necessary for the performance of a task carried out in the public interest;
• necessary for our legitimate interests, without unduly affecting your interests or fundamental rights and freedoms and to the extent such personal data is necessary for the intended purpose (such as when we use your data for some of the purposes;
• in limited circumstances, and as may be requested from you from time to time, we have obtained prior consent (for instance where required by law) or processed with your explicit consent in the case of special categories of personal data.

Examples of the “legitimate interests” referred to above are:

• manage our relationship with you and to help us to learn more about you as a client, the products and services you receive, and other products and services you may be interested in receiving;
• evaluate whether and how we may offer products, services and events that may be of interest to you;
• prevent fraud or criminal activity, misuses of our products or services as well as the security of our information, IT systems, architecture and networks and security of our premises;
• receive and handle complaints, requests or reports from you or third parties made to designated units;
• take steps to improve our products and services and our use of technology and to conduct market research;
• to cooperate with a request made in any actual or potential proceedings or the inquiries of a public or judicial authority;
• when we make the disclosures referred to in this policy, providing products and services and assuring a consistently high service standard, and keeping our clients, employees and other stakeholders satisfied; and
• exercising our rights under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property;

in each case provided such interests are not overridden by your privacy interests.

To the extent we have obtained your consent to process ordinary personal data in the past in any product-specific terms and conditions for the purposes of data protection law only, we will no longer rely on such consent, but instead will rely on lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests (as specified in this Notice), and our ability to rely on that consent is hereby waived or extinguished. For the avoidance of doubt, any consent given for any other reason, for instance (and if applicable) e-Privacy (including direct marketing), banking secrecy, decisions based solely on automated processing remains unaffected by this paragraph.

Where the personal data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this personal data there is a possibility we may be unable to onboard you as a client or provide products or services to you (in which case we will inform you accordingly).

To the extent that we process any special categories of data relating to you, we will do so because:

• the processing is necessary for the establishment, exercise or defense of a legal claim;
• the processing is necessary for reasons of substantial public interest;
• the processing relates to personal data which are manifestly made public by you; or
• you have given your explicit consent to us to process that information (where legally permissible).

2. What are your rights and how can you exercise them?

You have a right to access and to obtain information regarding your personal data that we process. If you believe that any information, we hold about you is incorrect or incomplete, you may also request the correction of your personal data.

You also have the right to:

• object to the processing of your personal data;
• request the erasure of your personal data;
• request restriction on the processing of your personal data; and/or
• withdraw your consent where we obtained your consent to process personal data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

When personal data is processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketing by clicking the “unsubscribe” link in any of our emails to you, or by emailing us at any time.

Where we process your personal data based on your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your personal data be transferred to you (known as the ‘data portability’ right). You also have the right to ask us for information regarding some or all of the personal data we collect and process about you.

We will honor such requests, withdrawal or objection as required under applicable data protection rules but these rights are not absolute: they do not always apply and exemptions may be engaged. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.

In certain circumstances we may process your personal data through automated decision-making. Where this takes place, you will be informed of such automated decision-making that uses your personal data and be given information on criteria and procedures applied. You can request an explanation about automated decision making carried out and that a natural person reviews the related decision where such a decision is exclusively based on such processing.

If you are not satisfied with our response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work. The contact details of each Data Protection Authority can be found at the following website: https://edpb.europa.eu/about-edpb/board/members_en

3. Additional information on data retention pursuant to the GDPR

Where the GDPR applies, personal data are generally retained depending on the type of data, the stage of the application process and the duration of the contractual relationship.

These periods may be extended where statutory or regulatory retention obligations apply or where overriding legitimate interests so require.

Where the GDPR applies, data subjects are required to provide the personal data necessary for the establishment and performance of a business relationship and for compliance with legal obligations.
Without such personal data, we will generally not be able to establish or continue a business relationship.

Additional contact details for representatives pursuant to the GDPR:

EU Representative: Email : fides.treasury.dataprivacy@swissinfosec.de
UK Representative: Email: fides.treasury.dataprivacy@swissgrc.uk.com