1 Contact details of Kaeberg and the Data Protection Advisor
Questions about the processing of personal data can be addressed to the Kaeberg Data Protection Advisor at support@kaeberg.com.
2 Which personal data is collected and processed by Kaeberg?
Kaeberg collects and processes personal data that it receives from you and that it generates as part of the business relationship with you. Personal data includes data that directly identifies you as an individual (e.g. name, address, telephone number); or personal data on a person related to a fiduciary structure (e.g. settlors, beneficiaries, investment advisors, and protectors); or data that allows for identification when used in connection with other information (e.g. name of a fiduciary structure).
In addition to personal data received directly from you, Kaeberg also collects and processes personal data about you from public sources (e.g. the internet, social media, debtor directories, land registers, trade and association registers, the media), or data it receives from third parties.
Kaeberg collects and processes in particular the following personal data about you and/or other persons related to a fiduciary structure:
- personal details (e.g. name, address, contact data, date and place of birth, nationality, passport, ID documents, personal situation, occupation, interests and preferences, business connections);
- professional details (e.g. job title and experience, knowledge of and experience in investment matters);
- family situation (e.g. marital status and children);
- authentication data (e.g. specimen signature);
- request data (e.g. distribution requests, letters of wishes);
- personal data arising from the preparation, execution, and performance of contracts and the fulfilment of obligations, particularly in relation to services or transactions;
- information regarding your financial situation (e.g. origin of assets);
- advertising and sales data;
- personal data relating to contacts (e.g. correspondence, enquiries, minutes of consultation, contact notes);
- account details, recordkeeping data, information regarding your personal background and financial situation (e.g. information relating to compliance and/or regulations, such as credit reports, origin of wealth and funds, financial knowledge, and experience), and/or company-related data (such as its business activities, purpose, ownership and organisational structure, and number of employees);
- sensitive personal data, such as biometric data; information regarding religious, ideological, or political views or activities; information relating to health; and information on convictions or sanctions under administrative or criminal law;
- personal data regarding related third parties such as beneficial owners, beneficiaries, employees, family relatives, authorised signatories, agents, and/or representatives;
- personal data on related corporates, trusts, partnerships, and foundations; and personal data on key individuals, such as controllers, shareholders, settlors, protectors, beneficiaries, foundation officials, and underlying policyholders;
- personal data that is transmitted and automatically collected during the use of websites, mobile applications, or other electronic services provided by Kaeberg. This data includes date and time of access, name of files downloaded, as well as the amount of data transmitted and the access result, your web browser, the browser language, and the requesting domain and IP address;
- other personal data comparable to the categories outlined above.
Kaeberg is required under Swiss anti-money laundering legislation:
- to verify certain information in relation to parties to a structure with Kaeberg, including their source of wealth. Kaeberg may utilise open source intelligence available using public search engines, information recorded on public media sites, as well as other commercially available, subscription-based sources in order to do this. This open source information may contain special category data such as references to political opinions and affiliations, religious or philosophical beliefs, or to offences committed or alleged to have been committed;
- to screen the names of parties to a structure against international sanctions lists.
3 For what purpose and on what legal basis does Kaeberg use your personal data?
a) To fulfil contractual obligations or take steps prior to entering into a contract
The processing of your personal data allows Kaeberg to provide you with the contractually agreed services, to perform contracts with you, and to take steps prior to entering into a contract. Data processing is primarily driven by the wealth planning services requested by you. Kaeberg uses your personal data, among other purposes, for the analysis of any potential needs; to identify individuals; verify documents; provide advice, wealth planning, and financing; for trading and to support the execution of transactions; as well as to settle contractual relationships. Where applicable, further details can be found in your contract documents or in Kaeberg’s General Terms and Conditions of Business.
b) On the basis of regulatory requirements and legal obligations
Kaeberg’s activities are subject to various regulations (e.g. the Swiss Anti-Money Laundering Act, the Federal Act on Financial Institutions, FINMA regulations, self-regulatory and supervisory organisation regulations, tax laws). The processing of personal data is used, among other things, for the verification of identity, and age; prevention of fraud and money-laundering; the fulfilment of tax-related, monitoring, and reporting obligations; as well as the assessment, investigation, analysis, and management of risks by Kaeberg.
c) To pursue and protect legitimate interests of Kaeberg
To pursue and protect its legitimate interests, Kaeberg will also process your personal data for the following purposes (examples):
- communication with you in relation to your enquiries or your potential interests;
- initiation of a business relationship and contact;
- prevention and investigation of breaches of contract, criminal acts, and other non-compliance issues;
- identification and analysis of your potential needs, and optimisation of the client contact;
- risk management within Kaeberg;
- assertion of rights and legal claims, and defence in legal disputes, e.g. in relation to tax, civil, criminal, or administrative claims or attachments on deposited assets;
- managerial oversight, consolidation, and maintenance of data relating to you that Kaeberg processes (single client view);
- consultation and exchange of data by or with information agencies (e.g. debt collection registers, credit rating agencies, land registries) for the determination of creditworthiness or default risks in the credit business;
- business development, advertising, marketing, market research, or surveys;
- safeguarding of Kaeberg’s IT security and IT operations;
- outsourcing of Kaeberg functions and services to service providers and agents appointed by Kaeberg;
- measures to ensure the security of buildings and systems.
d) On the basis of your consent
In particular cases, your consent is requested for the processing of your personal data. Provided your consent has been obtained, Kaeberg may process personal data for the specific purposes where indicated. You may withdraw your consent at any time. Please note that the withdrawal of consent has no retroactive effect on the processing of your personal data.
e) Recording and storage of communication
Kaeberg records and retains:
- phone calls to the extent required by the applicable laws and regulations;
- metadata of phone calls such as phone numbers, time, and duration; and
- electronic communication (e-mails, chat messages, etc.).
The communication retained by Kaeberg as set out above may be reviewed and used for security and evidence purposes (e.g. evidence of instructions received, advice given, compliance with legal and regulatory requirements).
4 Who can access your personal data?
a) Disclosure to business partners and other third parties
Kaeberg may disclose personal data to contractual partners and other third parties, as this is deemed necessary, e.g. for legal and regulatory purposes, for efficiency gains or internal management purposes, for the performance of the contract with you, and/or for the settlement of transactions (e.g. payment orders, foreign exchange and precious metals transactions, commodities, derivatives, or any other financial instruments).
Recipients may include agents and advisors (including legal and other professional advisors) in any jurisdiction for the purpose of establishing and administering a fiduciary structure (e.g. third-party trust company and service providers), and regulatory bodies or any other authorities.
b) Disclosure to third-party service providers
Kaeberg may disclose personal data to third-party service providers and their subcontractors (Service Providers) retained to provide services for Kaeberg, or to which it outsources functions and business areas. The relevant services or functions may concern in particular the following areas: IT services (e.g. data hosting and processing; IT development, support, operation); the use of internet-based services (e.g. online commercial registers); compliance services (adherence to anti-money laundering laws, transaction monitoring, regulatory reporting, including suspicious activity reporting, compliance supervision and reviews, and training and the like); the processing of transactions and services (e.g. payments); wealth management services and ancillary activities; services related to the administration, trading, execution, and processing of financial instruments and other financial assets; risk management functions; accounting (financial accounting and controlling), and compliance with obligations and duties under the Common Reporting Standards (CRS), the Foreign Account Tax Compliance Act (FATCA), and other reporting regimes (e.g. Beneficial Owners Registers, local tax filings); financing and credit services; marketing and sales-related activities; reporting, logistics, printing services, debt collection, as well as other back and middle office activities. Where the Service Providers have access to your personal data, Kaeberg requires them to comply with appropriate confidentiality, data protection, and data security requirements.
c) Disclosure to authorities and courts
Where required by law or regulation, or necessary to protect its legitimate rights and interests, Kaeberg may disclose your personal data to third parties. This may, among others, include public bodies and institutions (e.g. the Swiss National Bank, financial authorities, law enforcement authorities, supervisory authorities, courts, or other competent bodies).
5 Does Kaeberg transfer personal data across borders?
Kaeberg may disclose personal data to recipients outside of Switzerland, including to the EU/EEA member states and countries with an adequate level of data protection as specified by the European Commission, or other jurisdictions around the world where any of the third parties as outlined under section 4 above are located or where Kaeberg executes transactions or provides services.
The specific countries where the recipients of your personal data are located may vary as they correspond with the applicable services and the respective purpose(s) defined in this privacy notice.
Recipients of personal data may potentially forward the information to their branches, Service Providers, or to other market participants or authorities within and/or outside of their jurisdiction.
Individual countries to which Kaeberg transfers your personal data may potentially not have laws that afford the same degree of protection to personal data as in Switzerland. In these cases, Kaeberg will generally ensure an adequate level of data protection by e.g. contractual, organisational, and technical measures. The contractual measures applied by Kaeberg include agreements that have been approved by the European Commission and the Swiss Federal Data Protection and Information Commissioner (FDPIC), known as standard contractual clauses. You can request an example of a data transfer agreement usually employed by Kaeberg by contacting the Data Protection Advisor.
6 How long will your personal data be stored?
Kaeberg processes and retains your personal data for as long as it is required for the specific purpose for which it was collected, or to comply with legal or regulatory requirements.
If your personal data is no longer required for said purposes, Kaeberg might still retain and process your personal data based on your consent, if required by applicable laws or regulations, or for further processing. Examples for this would be:
- the fulfilment of retention obligations under applicable law;
- the fulfilment of specific regulations that require Kaeberg to retain the data;
- under automatic exchange of information agreements and Organisation for Economic Cooperation and Development (OECD) common reporting standards;
- for compliance or risk management in accordance with applicable laws (including the proper law of the trust or the jurisdiction of the company);
- the exercise of Kaeberg’s rights in relation to claims and any type of legal or regulatory action; or
- if it is in Kaeberg’s legitimate interest.
7 What are your rights under data protection law?
The applicable data protection legislation grants you the following rights:
- to request that information on personal data that Kaeberg holds on record be shared with you;
- to demand that information be rectified should it be incorrect;
- to ask that your personal data be deleted if Kaeberg is not permitted or is not legally obliged to retain the personal data;
- to demand that the processing of your personal data shall be restricted if
- you have disputed its accuracy, for the duration needed to verify the accuracy of your personal data, or
- its processing may lack a legal basis and you prefer a restriction of processing to the deletion of your personal data;
- to object to the processing by Kaeberg if
- Kaeberg only processes personal data based on its legitimate interests — in this case, it will cease the processing unless this is outweighed by its own interests or it needs to process the data in order to exercise its rights, or
- the processing is based on your consent (e.g. for direct marketing);
- to demand that your personal data which you have provided to Kaeberg be transferred to a third party indicated by you in a generally useable, machine-readable, and conventional format;
- to demand that an individual automated decision be reviewed by a natural person. You also have the right to state your view.
You also have a right of appeal (as far as this affects you) to the respective data protection supervisory authority.
8 What personal data are you required to supply?
Kaeberg requires you to provide the personal data necessary for the acceptance and execution of a business relationship and for the fulfilment of the associated contractual and/or legal obligations. Unless it obtains this data from you, Kaeberg will most likely be unable to enter into a contractual relationship with you and/or provide the agreed services.
Under the regulations on combating money laundering and the financing of terrorism, in particular, Kaeberg is obligated to verify your identity based on your identification document and, in this context, to collect and store your address, nationality, name, date and place of birth, as well as identification data prior to the commencement of a business relationship (and to renew such identification upon expiry of the underlying document). Furthermore, Kaeberg is obligated to verify the identity of the beneficiaries, protectors, and other parties on the basis of their identification document and, in this context, to collect and store such parties’ address, nationality, name, date and place of birth, and identification data prior to the commencement of a business relationship (and to renew such identification upon expiry of the underlying document). In order for Kaeberg to comply with these regulations, you are required to supply it with the necessary information. If this information changes during the business relationship, you are obliged to notify Kaeberg without delay. If you do not provide Kaeberg with the necessary information, it will not be able to commence or continue a business relationship with you.
9 Does Kaeberg use automated decision-making?
As a basic principle, Kaeberg does not use fully automated decision-making for commencing and conducting its business relationships. If Kaeberg does apply this procedure in exceptional cases, it will inform you accordingly where this is a statutory requirement.
10 Is your data processed automatically and used for profiling?
Kaeberg may process your personal data automatically in certain areas with the aim of evaluating certain personal criteria. Kaeberg may use your personal data for profiling. Profiling is any type of automated processing of personal data. This consists of using the personal data to evaluate certain personal aspects relating to you, in particular to analyse or predict aspects concerning the economic situation, personal preferences, interests, reliability, behaviour, and location or change of location. Kaeberg may use, process, and combine publicly available data as well as third-party data about you for this purpose. Profiling may take place, for example, in the following cases:
- to comply with the legal and regulatory obligations of Kaeberg or Service Providers and agents engaged by Kaeberg;
- to check the client relationship and to combat money laundering, terrorist financing, and asset-threatening crimes (including in payment transactions). These measures serve to protect you and to fulfil legal obligations;
- in order for Kaeberg to use assessment tools to provide you with relevant and appropriate information on its products and services. This enables it to carry out demand-based communication and advertising, including market and opinion research.
11 How can you contact Kaeberg?
Should you have any questions about the treatment of your personal data, please contact your relationship manager, or Kaeberg’s Data Protection Advisor at support@kaeberg.com, who will be pleased to assist you.
Kaeberg reserves the right to amend this privacy notice from time to time and will inform you of such an amendment in an appropriate manner.
Geneva, May 2026