CFO Enrollment Privacy Notice

1)  Who is responsible for your personal data and whom can you contact?

We process information and personal data relating to you and/or any Related Person of yours [Related Person(s) and you together hereafter the “Data Subject(s)”]. We essentially do so in connection with our existing and/or prospective business relationships, including your use of our websites (together hereafter the “Business Relationship”). We can do so either as controller or as joint controller (hereafter the “Controller”).

A “Related Person” means an individual or entity whose information you or a third party provides to us and/or which otherwise comes to our knowledge in connection with our Business Relationship. A Related Person may include, but is not limited to: (i) a director, officer or employee of a company; (ii) a trustee, settlor or protector of a trust; (iii) a nominee or beneficial owner of an account; (iv) a substantial interest owner in an account; (v) a controlling person; (vi) a payee of a designated payment; (vii) a representative or agent (i.e. with a power of attorney or a right to information on an account); or (viii) an employer or contractor.

In this regard, we ask you to liaise with any and all of your Related Persons and transmit to them this Privacy Notice and the information contained therein.

Should you have any questions about this Privacy Notice, your Controller or, more generally, the processing of your (or your Related Persons’) personal data, you can contact your relationship manager or our Data Protection Officer at any of the following addresses:

2) How do we handle your personal data?

We are subject to certain confidentiality and/or secrecy obligations, e.g. arising under data protection, contract, professional or banking secrecy, as the case may be. Personal data we process are also subject to said obligations.

This Privacy Notice deals with the way we process (i.e. collect, use, store, transmit or otherwise handle or process, operations collectively defined hereafter as the “Processing” or “Processing Operations”) personal data. This Privacy Notice does not replace, and is subject, to our applicable contractual terms and conditions.

We may conduct our Processing Operations either directly or indirectly, through other parties that process personal data on our behalf (hereafter the “Processors”). We are responsible only for the Processing of personal data as per this Privacy Notice.

3) What personal data do we process?

“Personal data” include any information that makes it possible to identify a natural person directly (e.g. first name, surname) or indirectly (e.g. passport number or data combination).
Personal data of Data Subjects we process may include:


  • identification data, e.g. names, addresses, telephone numbers, email addresses, business contact information;
  • personal characteristics, e.g. date of birth, country of birth;
  • professional information, e.g. employment and job history, title, professional skills, powers of attorney;
  • identifiers issued by public bodies, e.g. passport, identification card, tax identification number, national insurance number, social security number, work permit;
  • financial information, e.g. financial and credit history information, bank details, record from the debt collection enforcement office;
  • transaction/investment data, e.g. current and past investments, investment profile, investment preferences and invested amount, number and value of shares held, role in a transaction (seller/acquirer of shares), transaction details;
  • management and security data, e.g. records of presence on our premises, reputation checks and background checks;
  • cookie information, e.g. cookies and similar technologies on websites and in emails (please also see our Cookie Policy).

4) For what Purposes and on what legal bases do we process personal data?

We collect and process personal data for the purposes (hereafter the “Purposes”) and based on the legal bases set out in this Privacy Notice.

As a general comment, we essentially base our Processing on: (i) performance of a contract to which you are a party or a Related Person is related (as well as to take pre-contractual steps at your or a Related Person’s request); (ii) our duty to comply with a legal or regulatory obligation; (iii) the pursuit of our legitimate interest (including that of other CFO Enrollment entities); and (iv) performance of a task carried out in the public interest (e.g. to prevent or detect offences).

More specifically, we collect and process personal data as necessary for performance of a contract to which you are a party and/or a Related Person is related, which encompasses the following Processing Operations (which may also be based on other lawful bases):

  • the opening and management of your and/or Related Person’s account or Business Relationship with us, including all related operations for your identification;
  • any other related services provided by any service provider of the Controller(s) and Processors in connection with our Business Relationship;
  • management, advisement and distribution of financial statements including any ancillary services related to these activities;
  • management of requests for proposals and/or due diligence, the provision of services (including the invoicing and payment of fees) and management of the Business Relationship and related communication with you.

We also collect and process personal data in connection with compliance with legal and regulatory obligations to which we are subject, including to:

  • provide offering documentation to Data Subjects about products and services;
  • comply with legal obligations relating to accounting, compliance with legislation , outsourcing, federal and state activities and qualified participation;
  • carry out any other form of cooperation with, or reporting to, competent administrations, supervising authorities, law enforcement authorities and other public authorities [e.g. in the field of anti-money laundering and combating terrorism financing (AML-CTF)], for prevention and detection of crime under tax law [e.g. reporting of name, address, date of birth, tax identification number (TIN), account number and account balance to tax authorities under the Common Reporting Standard (CRS) or Foreign Account Tax Compliance Act (FATCA) or other tax legislation to prevent tax evasion and fraud as applicable];
  • prevent fraud, bribery, corruption and the provision of financial and other services to persons subject to economic or trade sanctions on an ongoing basis  in accordance with our AML-CTF procedures, as well as to retain AML-CTF and other required records for screening purposes;
  • record conversations with Data Subjects (such as telephone and electronic communications), in particular to document instructions or detect potential or actual frauds and other offences.

The Processing Operations outlined above may rely on other lawful bases and potentially do substantially rely on the performance of a task carried out in the public interest.

Furthermore, we may process personal data in connection with legitimate interests we pursue in order to:

  • develop our Business Relationship with you;
  • improve our internal business organisation and operations, including for risk management;
  • use this information in CFO Enrollment entities for market studies or advertising purposes, unless Data Subjects have objected to use of their personal data for marketing;
  • assess our risk and take related business decisions with regard to risk management;
  • communicate personal data to other CFO Enrollment entities, in particular to guarantee an efficient and harmonised service and inform Data Subjects about services offered by CFO Enrollment entities;
  • establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings;
  • record conversations with Data Subjects (such as telephone and electronic communications) to verify instructions, enforce or defend our interests or rights, assess, analyse and improve the quality of our services, train our employees and manage risks.
  • conduct audits and/or regularly reviews on you or your Related Person.

To the extent one or more of our Processes of personal data presupposes that you give your prior consent thereto, we will contact you and seek your consent in due time.

The provision of personal data may be mandatory, e.g. with regard to our compliance with legal and regulatory obligations to which we are subject. Please be aware that failing to provide such information may preclude us from pursuing a Business Relationship with, and/or from rendering our services to, you.

5) Do we rely upon profiling or automated decision making?

We may assess certain characteristics of the Data Subjects on the basis of personal data processed automatically (profiling) in particular to provide Data Subjects with personalised offers and advice or information on our products and services or those of our affiliates and business partners. We may also use technologies that allow us to identify the level of risks linked to a Data Subject or to activity on an account.

Furthermore, we generally do not use automated decision-making in connection with our Business Relationship and/or Data Subjects. Should we do so, we will comply with applicable legal and regulatory requirements.

6) What sources do we use to collect personal data?

To achieve the Purposes, we collect or receive personal data:


  • directly from the Data Subjects, e.g. when contacting us or through (pre ) contractual documentation sent directly to us; and/or
  • indirectly from other external sources, including any publicly available sources [e.g. US ,  Specially Designated Nationals (SND) lists], information available through subscription services (e.g. Bloomberg, World Compliance PEP list) or information provided by other third parties.

7) Do we share your personal data with third parties?

If necessary or useful to achieve the Purposes, we reserve the right to disclose or make accessible the personal data to the following recipients, provided this is legally or otherwise authorised or required:

  • public/governmental administrations, courts, competent authorities (e.g. financial supervisory authorities) or financial market actors (e.g. third-party or central depositaries, brokers, exchanges and registers);
  • CFO Enrollment entities or third-party Processors that process personal data on our behalf and/or to which we outsource certain tasks of ours (outsourcing);
  • auditors or legal advisors.

We undertake not to transfer personal data to any third parties other than those listed above, except as disclosed to Data Subjects from time to time or if required by applicable laws and regulations applicable to them or by any order from a court, governmental, supervisory or regulatory body, including tax authorities.

8) What are your rights in conneciton with data protection?

You have the right, subject to applicable local data protection legislation, to:

  • request access to, and receive a copy of, the personal data we hold;
  • if appropriate, request rectification or erasure of the personal data that are inaccurate;
  • request that personal data be erased when the Processing is no longer necessary for the Purposes, or is not or no longer lawful for other reasons, subject however to applicable retention periods (see Section 9  below);
  • request a restriction of Processing of personal data where the accuracy of the personal data is contested, the Processing is unlawful, or if the Data Subjects have objected to the Processing;
  • object to the Processing of personal data, in which case we will no longer process the personal data unless we have compelling legitimate grounds to do so (e.g. the establishment, exercise or defense of legal claims);
  • receive the personal data in structured, commonly used and machine-readable format (data portability right);
  • obtain a copy of, or access to, the appropriate or suitable safeguards which we may have implemented for transferring the personal data outside the European Union or Switzerland;
  • complain to our Data Protection Officer (see Section 1 above) in relation to the Processing of personal data and, failing any satisfactory resolution of the matter, file a complaint in relation to the Processing of personal data with the relevant data protection supervisory authority.

Even if a Data Subject objects to the Processing of personal data, we are nevertheless allowed to continue the same if the Processing is: (i) legally mandatory; (ii) necessary for performance of a contract to which the Data Subject is a party; (iii) necessary for performance of a task carried out in the public interest; or (iv) necessary for the purposes of the legitimate interests we pursue, including the establishment, exercise or defence of legal claims. We will not, however, use the Data Subject’s personal data for direct marketing purposes if the Data Subject asks us not to do so.

Subject to the limitations set forth in this Privacy Notice and/or in applicable local data protection laws, you can exercise the above rights free of charge by contacting our Data Protection Officer.

9) How long are your personal data kept or stored?

As a matter of principle, we retain personal data for as long as we need the same to achieve the Purposes. By the same token, we will delete or anonymise personal data (or equivalent) once they are no longer necessary to achieve the Purposes, subject however: (i) to any applicable legal or regulatory requirements to store personal data for a longer period; or (ii) to  stablishing, exercising and/or defending actual or potential legal claims, investigations or similar proceedings, including legal holds, which we may enforce to preserve relevant information.