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Aneni – Answering all your financial aspirations

Privacy Statement

Last Modified on June 21, 2023

The following privacy statement will give you an overview of the collection and processing of your personal data:

With the following information, we (the entities listed in section 8. below) would like to provide you with an overview of their processing of your personal data and your rights under Israeli data protection legislation. Which data is individually processed and how it is used largely depends on the nature of the business relationship.

What sources and data do we use?
We process personal data that we obtain from our current, prospective and former clients, service providers as well as other persons which are or might be involved in the future in a relationship with us (“you”) as part of our current, possible or former business relationship. In order to provide our services, we also process personal data that we obtain from publicly accessible sources (e.g. debt registers, land records, commercial and association registers, the press, internet) or that is legitimately transferred to us by other companies within Aneni Capital or from other third parties (e.g. a credit agency, investment house, bank).

Relevant personal data includes, e.g., personal information (name, address and other contact data, date and place of birth, and nationality), identification data (e.g. ID data), and authentication data (e.g. specimen signature). Furthermore, this can also include order data (e.g. payment order), data from the fulfillment of our contractual obligations (e.g. sales data in payment transactions), information about your financial situation (e.g. creditworthiness data, scoring/ rating data, origin of assets), marketing and sales data (including advertising scores), documentation data (e.g. consultation protocol), and other data similar to the categories mentioned above.

  1. Why do we process your personal data (purpose of processing) and on what legal basis?

    We process personal data in accordance with the provisions of the Israeli data protection act : Data Protection in Israel is governed primarily by the Protection of Privacy Law, 5741-1981 (‘the Privacy Law’) and enforced by the Privacy Protection Authority (‘PPA’). The Privacy Law covers collection and use of personal data and sensitive data, sets the rights and obligations of the parties collecting and using the data, including security requirements with respect thereto, and sets the rights afforded to individuals whose data is collected and used.

a. For the fulfillment of contractual obligations

Data is processed to provide banking business and financial services as part of the execution of our contracts with our clients or for the execution of pre-contractual measures.
The purposes of data processing are based first and foremost on the specific product (e.g. account, credit, saving with building societies, securities, deposits, client referral) and may include, among other things, needs analyses, advice, asset management and support, as well as the execution of transactions. You can find further details on the data processing purposes in the relevant contract documents and terms and conditions.

 b. In the context of balancing of interests

If necessary, we process your data beyond the actual fulfillment of the contract to preserve our legitimate interests or those of a third party. Examples:

  • Consultation and data exchange with data collection agencies (e.g. debt registers) to investigate creditworthiness and credit risks in the credit business and the need for a basic account or account maintained with a basic non-seizable balance;
  • Review and optimization of procedures for needs analysis for the purpose of direct client contact;
  • Advertising or market and opinion research, provided you have not objected to the use of your data (see section 9 below);
  • Assertion of legal claims and defense in case of legal disputes;
  • Safeguarding of IT security and the IT operation;
  • Prevention and investigation of criminal activity;
  • Measures For Building And System Security(e.g.access controls);
  • Measures for business management and further development of services and business goals and products;
  • Risk control;
  • Mergers, acquisitions and reorganizations including by providing information to future purchasers or transferees;

In addition, we obtain personal data from publicly available sources for client acquisition purposes.

c. As a result of your consent

We process your personal data for specific purposes if you have given us your consent. The consent given can be revoked. Revocation will be effective for the future from the point of revocation. Processing carried out prior to the revocation will therefore not be affected.

The processing of personal data as referred to above can include all details related to you as a current, prospective or former client, the existence of a relationship between you and us and/or the business partner and groups , and details on any beneficial owners, controlling persons, beneficiaries, authorized agents and representatives, guarantors, and other individuals or businesses involved in the use of your information.

2. Am I obliged to provide my data?

As part of our business relationship, you must provide the personal data necessary for the initiation and execution of a business relationship, as well as for the fulfillment of the associated contractual obligations, or that we are legally obliged to collect. Without this data, we will generally not be in a position to enter into or execute a contract with you.

In particular, we are obligated under anti-money laundering regulations to identify you prior to establishing a business relationship on the basis of your identity document and, in doing so, to collect and record your name, address, nationality, date of birth, place of birth, and ID information. To enable us to meet these statutory obligations, you must provide us with the necessary information and documents in accordance with the Anti-Money Laundering Act, and you must also immediately notify us of any changes over the course of the business relationship. If you do not provide us with the necessary information and documents, we are not allowed to enter into or continue the business relationship you desire.

3. Who receives my data?
Access to your data is given to Colin Wellins, Reg No.  328937065
, Aneni Capital and partners to fulfill our contractual and legal obligations and to preserve our legitimate interests.
Other data recipients may be recipients for which you have provided us with your consent.

4. For how long will my data be stored?
We only process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations. In this context, it should be noted that our business relationship is a continuing obligation that spans years.

If the data is no longer required for the fulfillment of contractual or legal obligations, it is regularly deleted unless limited continued processing is necessary for the following purposes:

Fulfillment of obligations to preserve records according to commercial and tax law. This includes, in particular, the Swiss Code of Obligations, the Federal Act on Value-Added Tax, the Direct Federal Taxation Act, the Federal Act on the Harmonization of Direct Cantonal Taxation and Direct Community Taxation, the Federal Stamp Tax Act, and the Federal Withholding Tax Act;6

5. What data protection rights do I have?

Every affected individual has the right to information according to Article 8 FADP, the right to correction according to Article 5 FADP, the right to erasure according to Article 5 FADP, the right to restrict processing according to Articles 12, 13, 15 FADP, the right of objection and – if applicable – the right to data portability. Furthermore, if applicable to you, there is also a right to lodge a complaint with an appropriate data privacy regulatory authority.

6. To what extent does automated decision-making take place?

To establish and execute a business relationship, we fundamentally do not use any fully automated decision-making. If we use this process in individual cases, we will inform you of this separately, provided this is legally required.

7. For what purposes will profiling take place?

We process your personal data automatically in certain instances, to evaluate certain personal aspects of you (profiling), for example:

  • Due to legal or regulatory requirements, we are obligated to prevent money laundering, terrorist financing and asset-threatening criminal offenses. In doing so, data analyses (including in payment transactions) are carried out. These measures also serve to protect you;
  • We use scoring as part of the assessment of your creditworthiness. In doing so, the probability that a client will meet their payment obligations pursuant to the contract is calculated. This calculation may be influenced by the client’s earning capacity, expenses, pending liabilities, occupation, employer, term of employment, experience from the business relationship thus far, contractual repayment of previous credits, and information from credit information offices, for instance. Scoring is based on a mathematically and statistically recognized and established process. The calculated scores help us to make decisions in the context of product sales and are incorporated into ongoing risk management.

8. Who is responsible for data processing and who can I contact?

The entity that you have a business relationship with, is responsible for the processing of your personal data. This will include but is not limited to: ( * Banks , Forex trading establishments , Investment Houses / Institutions ,  Insurance companies , Legal advisors, CPA’s, Tax experts, Real Estate Companies )

Entity / Establishment

Colin Wellins Registered sole trader reg. no. 328937065

You can contact us at:

colin@anenicapital.com             

For entities listed above marked with an * The aforementioned contact acts as the designated Data Protection Officer.

9. Applicability and additional clauses

This privacy statement applies to all entities listed in section 10 above that act as controllers.

Thank you for your attention. Yours sincerely

Information on your right of objection

Right of objection to profiling for marketing purposes
You may at any time object to the evaluation of certain personal aspects of you (profiling) for marketing related purposes as set out in Art. 16 e) of the General Conditions of CREDIT SUISSE AG/CREDIT SUISSE (SWITZERLAND) LTD.
To the extent that you object to profiling for marketing purposes, we will no longer process your data and you will no longer benefit from customized marketing. We may, however, continue to process your data for purposes of direct marketing.

Right of objection against data processing for purposes of direct advertising
In individual cases, we will process your personal data to carry out direct advertising. You have the right to object at any time to the processing of your personal data for the purposes of such advertising.
If you object to processing for direct marketing purposes, we will no longer process your personal data for such purposes, and you will no longer benefit from direct advertising.

The objection should be addressed whenever possible:

Your service providers Relationship Manager or Client Services at Aneni:
contact@anenicapital.com

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