We collect and process personal data for the purposes (hereinafter the “Purposes”) and based on the legal bases set forth herein.
As a general comment, we essentially base our Processing on (i) the 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 obligation to comply with a legal or regulatory obligation, (iii) the pursuit of our legitimate interest (including that of other Pictet Group entities) and (iv) the 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 the performance of a contract to which you are a party and/or a Related Person is related, which includes the following Processing Operations (which may also be based upon 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;
- the management, administration and distribution of investment funds, including any ancillary services related to these activities; or
- the processing of subscription, conversion and redemption requests in investment funds, as well as for maintaining the ongoing relationship with respect to holdings in such investment funds.
We also collect and process personal data in relation to 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 on markets in financial instruments;
- 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 combatting terrorism financing (“AML-CTF”)), for the 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 the 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 on-going basis in accordance with our AML-CTF procedures, as well as to retain AML-CTF and other required records for screening purposes;
- deal with active intra-group risk management pursuant to which risks in terms of markets, credit, default, processes, liquidity and image as well as operational and legal risks must be identified, limited and monitored;
- 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 foregoing Processing Operations may rely on other lawful bases and eventually do substantially rely on the performance of a task carried out in the public interest.
Furthermore, we may process personal data in relation to legitimate interests we pursue in order to:
- assess certain characteristics of the Data Subjects on the basis of personal data processed automatically (profiling) (see also Section 5 below);
- develop our Business Relationship with you;
- improve our internal business organisation and operations, including for risk management;
- use this information in the Pictet Group entities for market studies or advertising purposes, unless Data Subjects have objected to the use of their personal data for marketing;
- assess our risk and take related business decisions in case of risk management;
- communicate personal data to other Pictet Group entities, in particular to guarantee an efficient and harmonised service and inform Data Subjects about the services proposed by the Pictet Group 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.
To the extent one or more of our Processes of personal data presupposes that you give your prior consent thereto, we will reach out to you and ask for your consent in due time.
The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a Business Relationship with, and/or from rendering our services to you.