PRIVACY POLICY

MARTEL INVESTMENTS (“MARTEL INVESTMENTS”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit or use our website martel-investments.com (the “Website”), contact us, request information about our services, or otherwise interact with us.

MARTEL INVESTMENTS is an independent family-owned investment company providing investment, strategic advisory, wealth management, asset management, real estate-related and financial education services.

This Privacy Policy is intended to provide information in accordance with applicable Swiss data protection law and, where applicable, the European Union General Data Protection Regulation (“GDPR”).

1. DATA CONTROLLER

The entity responsible for the processing of personal data is:

MARTEL INVESTMENTS

Company No.: CH-660.0.930.015-5
VAT No.: CHE-307.775.003
Address: Route des Acacias 34, 1227 Carouge GE, Switzerland
Email: info@martel-investments.com

For questions concerning the processing of personal data or this Privacy Policy, you may contact us using the email address above.

2. PERSONAL DATA WE COLLECT

Depending on how you interact with us, we may collect the following categories of personal data:

2.1 Information you provide to us

When you contact us through the Website, request a consultation, submit an enquiry or otherwise communicate with us, we may collect:

• first and last name;
• email address;
• telephone number, where provided;
• company or organisation;
• information contained in your message or enquiry;
• information concerning your interests in our services;
• any other information you voluntarily provide.

You should avoid providing sensitive or unnecessary personal information through Website forms unless specifically requested by us.

2.2 Technical and usage information

When you access the Website, certain technical information may be automatically collected by the Website or its infrastructure, such as:

• IP address;
• browser type and version;
• operating system;
• device information;
• date and time of access;
• pages visited;
• referring website;
• technical logs and security-related information.

The precise categories of automatically collected information depend on the technical configuration and services used to operate the Website.

2.3 Cookies and similar technologies

The Website may use cookies and similar technologies.

Cookies may be used for purposes such as:

• ensuring the proper functioning of the Website;
• remembering preferences;
• improving Website performance;
• understanding Website usage;
• security and fraud prevention;
• analytics or other purposes, where applicable.

Where legally required, non-essential cookies will only be activated after obtaining the appropriate consent.

For further information, please refer to our Cookie Policy.

3. HOW WE USE PERSONAL DATA

We may process personal data for the following purposes:

• responding to enquiries and requests;
• arranging consultations and communications;
• providing information about our services;
• managing prospective and existing business relationships;
• providing investment, advisory, wealth management, asset management, real estate and related services;
• administering contractual relationships;
• complying with legal and regulatory obligations;
• preventing fraud, abuse and security incidents;
• maintaining and securing the Website;
• improving our Website, services and communications;
• maintaining business records;
• protecting our legal rights and interests;
• communicating with you where you have requested or permitted such communication;
• sending marketing communications where permitted by applicable law and, where required, based on your consent.

We will not process personal data for purposes incompatible with the purposes described above unless permitted or required by applicable law.

4. LEGAL BASES FOR PROCESSING

Where the GDPR applies, we may process personal data on one or more of the following legal bases:

4.1 Performance of a contract

Processing may be necessary to enter into or perform a contract with you or to take steps at your request before entering into a contract.

4.2 Legal obligations

We may process personal data where necessary to comply with applicable legal, regulatory, accounting, tax, anti-money-laundering, compliance or other obligations.

4.3 Legitimate interests

We may process personal data where necessary for our legitimate interests, provided that those interests are not overridden by your fundamental rights and freedoms.

Such interests may include operating and securing our Website, managing business relationships, protecting our property and rights, preventing fraud and improving our services.

4.4 Consent

Where required by law, we will rely on your consent for particular processing activities, such as certain marketing communications or non-essential cookies.

You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

5. DISCLOSURE OF PERSONAL DATA

We may disclose personal data where reasonably necessary to:

• employees and authorised representatives of MARTEL INVESTMENTS;
• professional advisers, such as lawyers, accountants, auditors or consultants;
• IT, hosting, website maintenance and technology service providers;
• communication and email service providers;
• financial, compliance or other professional service providers;
• governmental authorities, regulators, courts or law-enforcement authorities where required or permitted by law;
• other parties where necessary to protect our rights, property, safety or legitimate interests.

Where third-party service providers process personal data on our behalf, we seek to ensure that appropriate contractual and technical safeguards are in place where required by applicable law.

We do not sell personal data to third parties.

6. INTERNATIONAL DATA TRANSFERS

Depending on the service providers and technologies used to operate our business and Website, personal data may be processed or transferred outside Switzerland and/or the European Economic Area.

Where applicable law requires safeguards for international transfers, we will implement appropriate safeguards, which may include:

• a decision recognising an adequate level of data protection;
• standard contractual clauses or other approved contractual safeguards;
• other mechanisms permitted by applicable data protection legislation.

You may contact us using the details in Section 1 to obtain further information concerning applicable safeguards where required by law.

7. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the purposes for which they were collected, including for the purposes of satisfying legal, regulatory, accounting or reporting requirements.

The applicable retention period depends on the type of information and the purpose for which it is processed.

When personal data are no longer required, we will delete, anonymise or securely dispose of them, unless a longer retention period is required or permitted by applicable law.

8. DATA SECURITY

We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, destruction, alteration, disclosure or other unlawful processing.

However, no transmission or storage system can be guaranteed to be completely secure. You should therefore understand that providing information over the Internet involves inherent risks.

9. YOUR DATA PROTECTION RIGHTS

Depending on applicable law, you may have rights concerning your personal data, including:

• the right to request access to personal data we hold about you;
• the right to request correction of inaccurate or incomplete personal data;
• the right to request deletion of personal data;
• the right to request restriction of processing;
• the right to object to certain processing activities;
• the right to withdraw consent where processing is based on consent;
• the right to data portability where applicable;
• the right to lodge a complaint with the competent data protection authority.

These rights are subject to applicable legal conditions and exceptions.

To exercise your rights, please contact:

info@martel-investments.com

We may take reasonable steps to verify your identity before responding to a request.

10. MARKETING COMMUNICATIONS

Where permitted by applicable law, we may use your contact details to provide information about our services, events, activities or other communications that may be relevant to you.

Where consent is required, we will obtain it before sending the relevant marketing communications.

You may unsubscribe from marketing communications at any time by following the instructions included in the communication or by contacting us at:

info@martel-investments.com

Please note that you may continue to receive essential administrative or transactional communications where necessary.

11. CHILDREN

Our Website and services are not intended for children.

We do not knowingly collect personal data from children where prohibited by applicable law. If you believe that a child has provided us with personal data, please contact us so that we can take appropriate action.

12. THIRD-PARTY WEBSITES

The Website may contain links to websites or services operated by third parties.

We are not responsible for the privacy practices, security or content of third-party websites. We recommend reviewing the privacy policies of those websites before providing personal information.

13. AUTOMATED DECISION-MAKING AND PROFILING

Unless otherwise expressly stated, we do not intend to make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects on individuals.

If this changes, we will provide the information required by applicable data protection law.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our services, Website, legal requirements or data processing practices.

The updated version will be published on this page with a revised “Last updated” date.

We encourage you to review this Privacy Policy periodically.

15. CONTACT US

If you have questions, concerns or requests regarding this Privacy Policy or the processing of your personal data, please contact:

MARTEL INVESTMENTS
Route des Acacias 34
1227 Carouge GE
Switzerland

Email: info@martel-investments.com

16. SUPERVISORY AUTHORITY

For matters falling under Swiss data protection law, the competent supervisory authority is the:

Federal Data Protection and Information Commissioner (FDPIC)
Switzerland

Where the GDPR applies, you may also have the right to lodge a complaint with the data protection supervisory authority in your country of residence, place of work or place of the alleged infringement, as applicable.

© MARTEL INVESTMENTS — All rights reserved.