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Privacy Policy

GAM Holding AG and its affiliates (hereinafter referred to as ‘GAM’, ‘we’ or ‘us’) is committed to protecting and safeguarding the personal information of current, prospective and former clients in accordance with applicable laws. This privacy policy (the ‘Policy’) describes the ways in which we collect, process and, in certain circumstances, may share such information.

The terms of this Policy are without prejudice to any contractual terms you may enter into with us, which will take precedence over the terms of this Policy.

Processing of data

If you are a client of GAM we may collect, use and disclose personal data about you, including personal data you may voluntarily disclose to GAM in any manner, so that GAM can (i) carry out its obligations under the Site Terms of Use; (ii) carry out its everyday business activities and dealings with you; (iii) compile statistical analysis of the pages of the Site visited; (iv) monitor and analyse its business; (v) participate in crime prevention, legal and regulatory compliance; (vi) market and develop other products and services; (vii) transfer any of GAM's rights or obligations.

GAM will not obtain or require disclosure of sensitive personal data (such as ethnic origin, religion or medical records) but if you choose to provide such sensitive personal data, GAM may assume such sensitive data is provided with your consent and can be processed by GAM as it sees fit, unless otherwise notified by you to GAM in writing.

GAM will not disclose any personal data it collects about you to third parties except: (i) to the extent that it is required to do so by any applicable law or regulation; (ii) where there is a duty to the public to disclose; (iii) where GAM's legitimate business interests require disclosure; or (iv) at your request or with your consent or to persons described below.

GAM may, subject to applicable law, disclose personal data about you to those who provide services to GAM or act as GAM's agents, to any person to whom GAM transfers or proposes to transfer any of its rights or obligations under the Site Terms of Use and to licensed credit reference agencies or other organisations that help GAM and others make credit decisions and reduce the incidence of fraud or in the course of carrying out identity, fraud prevention or credit control checks.

GAM may record or monitor telephone conversations and email correspondence between you and GAM for security, compliance with the law, training purposes and to maintain and improve the quality of GAM services.

Data Security

Within GAM your personal data will be transmitted and stored in a protected environment. We will take all reasonable steps in order not to allow your personal data to be seen by any third parties other than those which have been engaged by GAM to provide services to you. We will only disclose your data to other third parties, if compelled to do so for legal or regulatory purposes. We will not supply any information about you to anyone unless we believe it is lawful to do so.

Data Transfer

GAM may transfer personal data collected and held about you to any country, including countries outside the European Economic Area which may not have data protection laws, for any of the purposes described above. By accepting the Site Terms of Use, you consent to such transfer.

Data Retention

GAM will only retain your personal information for as long as it is needed in accordance with applicable laws.

Internet Privacy

If you register with us on the Site then your registration data will be used to determine which funds and services are available to you in accordance with your professional status and country of residence. GAM does not collect personal data relating to you from the Site except when specifically and knowingly provided by you.

GAM has various security provisions in place to ensure the privacy of your personal information however GAM accepts no responsibility or liability for the security of your data whilst in transit via the internet to us. In order to protect your privacy we would like to remind you that you may choose another means of communication with us, where you deem it appropriate.

The Site may include hyperlinks to other third party Sites that are not operated or controlled by GAM. Once you leave our Site GAM is not responsible for the content or the privacy practices of third party websites.

Cookies

A cookie is a small text file that is sent to your computer, or other device, by the sites that you visit. They are widely used to monitor traffic to sites, and to enable certain functionality such as personalising sites to your interests or preferences.

To understand how GAM uses cookies and how you can alter your cookie settings please refer to the separate Cookies Notice.

Email marketing

Opt-in process. In addition to one-to-one email messages from client managers or other contacts you have at GAM, you may also be subscribed to our centralised mailing lists. This will only happen if your explicit permission has been given, which will have been expressed in writing or verbally.

Opt-out process. You can unsubscribe from our mailings at any point. Every email has several options to unsubcribe at the end of the message. Alternatively, you can ask your GAM contact to remove you from specific mailings.

Types of centralised mailings. If you are a client of GAM or invested in a GAM fund, you may receive fund reporting mailings (e.g. fund fact sheets, holding reports, risk reports, performance updates). From time to time, we may also send you marketing or event-related messages.

Tracking. We track recipient response to the mailings we send out. This data will be collected and stored securely, and may be used to compile statistics on an aggregated and individual basis. We will only use this information to improve the quality and relevance of our email communications. If you wish to opt-out from tracking, please click here and send the email that is generated.

Tracking data storage. All data collected via email communications will be stored in accordance with applicable legal and regulatory requirements.

Data access

If you are a client and have further queries or wish to check that your personal information is correct and up to date please contact your Client Relationship Manager directly or via email at info@gam.com

Privacy Policy updates

Please note that GAM reserves the right to amend this Policy at any time. Your continued use of this Site shall signify your agreement with and understanding of any additional or modified terms or conditions.