Data Protection and Professional Confidentiality

Table of Contents

• General information
• What personal data does AXA IM collect and process?
• How do we use your personal data for communications?
• On what basis is your data collected and used and for what purposes?
• What happens if you do not provide us with the personal data requested?
• Who has access to your personal data?
• Do we transfer your personal data abroad?
• How long do we keep your personal data?
• What are your rights?
• Will there be any changes to this policy?
• Professional Confidentiality

General information

Scope

This data privacy policy ("Policy") is addressed to all customers, prospects, their representatives, directors, officers or beneficial owners, suppliers, contact persons and other individuals ("Data Subjects", "you") of or in contact with AXA Investment Managers Switzerland Ltd. ("AXA IM", "us", "we"). It is meant to help you understand what personal data we collect, why we collect it, and how you can exercise your data protection rights.

This Policy does not replace the specific privacy notice you shall receive for specific processing activities carried out by AXA IM entities.

Data Controller

The data controller means the company (legal person) who determines the purposes and means of the processing of your personal data. For the overarching processing activities described in this data privacy notice, AXA IM is data controller. In addition, any affiliate of AXA IM that processes personal data might become a controller or joint controller of such data.

AXA Investment Managers Switzerland Ltd.
Ernst-Nobs-Platz 7
8004 Zurich

Data Protection Officer

We have appointed a Local Data Protection Officer. You can contact this person and the team at any time:

AXA Investment Managers Switzerland Ltd.
Data Protection Officer
Ernst-Nobs-Platz 7
P.O. Box 1078
CH-8021 Zurich
E-Mail: dataprivacy@axa-im.com

What personal data does AXA IM collect and process?

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified directly (e.g. by name and surname) or indirectly (e.g. by a telephone number or an identifier such as a client number, postal or e-mail address, but also by voice).

AXA IM takes care to minimise the collection of personal data, to keep it up to date and to ensure its security. Technical and organisational measures are implemented to ensure that your data is adequately protected against unauthorised access, loss, destruction, modification or disclosure.

Some or all of the following personal data will be processed depending on your relationship with AXA IM:

Information you provide:

This is information that is collected directly from you when you complete forms, fund applications or when you communicate with us by telephone, email and generally in connection with the services we provide to you.

The personal data we may collect depends on the specific services, activities or products we offer, but generally includes the following personal information

• name, title, business contact details, tracking of our interactions (including email and telephone - some calls may be recorded);
• data relating to business operations, investments and monitoring of the business relationship;
• physical access data, relating to details of your visits to our premises;
• any dietary preferences you may have (e.g. where we wish to offer you lunch at a meeting);
• profile and usage data, including passwords to AXA IM websites or password-protected platforms or services, your preferences for receiving marketing information from us, your communication preferences, and information about how you use our websites, including the services you accessed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-over), opening of emails;
• technical data, including information collected during your visits to our website(s), Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform.

To learn more about our use of cookies or similar technologies, please see our cookies policy available on our website.

In order to comply with our legal obligations to combat money laundering and the financing of terrorism, and for the application of national and international financial sanctions, the data necessary to assess the risk presented by the business relationship and/or the third parties for whom it is acting and/or the beneficial owner of the transaction in question, the transaction requested or the contract entered into may be collected:

Information relating to identity:

- For natural persons: surname, first name(s), status code, pseudonym(s), nationality and date and place of birth, a copy of one or more valid official documents bearing his/her photograph, the following information: nature, date and place of issue of the document(s) and the name and capacity of the authority or person who issued the document(s) and, where applicable, authenticated it (them).

- For natural persons representing legal persons: mandates and powers of attorney, identity of managers, partners and agents, copy of any deed or extract from an official register dated less than three months establishing the identity of the partners and managers or their equivalents under foreign law.

• address and proof of address up to date at the time the information is collected;
• professional, economic and financial situation: socio-professional category, UID code, profession, name of employer, nature and level of income or turnover, proof of economic activity, resources or assets in the form of an undertaking on the person's honour or proof of the truthfulness of the information declared;
• account operation, financial transactions or products purchased: account or contract number, date of opening of the account, subscription of the contract or entry into the relationship, origin, valuation and composition of the assets and funds involved in the transaction, amount and nature of the operations planned and carried out, planned operation of the account, currency handled, origin and destination of the funds (geographical origin, financial institution acting as intermediary, number of accounts credited or debited), identity of the person benefiting from the transaction or contract, declared economic justification for the operation, identity of the actual originator, economic justification declared by the customer;
• assets: elements for assessing assets;
• tax status;
• suspicious transaction reports: existence and content.

In the context of the fight against fraud, AXA IM may collect the following additional information:

• data relating to personal, family and professional situation;
• economic and financial information relating to the conclusion of contracts;
• data relating to anomalies, inconsistencies and reports that may indicate fraud;
• data relating to investigations, the examination of the fraud file and the evaluation of the scope and nature of the presumed or proven fraud and its consequences;
• data relating to risk assessment, determination or evaluation of damage;
• data relating to financial movements, means of payment, transactions/operations (including financial transactions).

Finally, as part of the requirements of the Federal Act on Financial Services (FinSA), in order to be able to recommend suitable investment services and financial instruments, when providing investment advice or portfolio management services, AXA IM will need to collect the necessary information regarding:

• the client's or potential client's investment knowledge and experience in relation to the specific type of product or service;
• the financial situation of the client or potential client, including the client's capacity to incur losses;
• their investment objectives, including their risk tolerance.

Information we generate:

This is information and statistics relating to your investments and preferences in our products and services.

Information we collect from other sources:

Some of the personal data we collect as part of our anti-money laundering, anti-terrorist financing, and national and international financial sanctions enforcement checks may come from external sources (e.g. public data or sanctions lists).

Similarly, where you have invested in our funds or have been introduced to us by a financial adviser or broker, some of the personal data listed above may be provided to us by them.

How do we use your personal data for communications?

Where you have separately confirmed to us that you are willing to receive marketing communications relating to our products and services, we may also process your name, address, email address and IP address for these purposes. You may withdraw your consent at any time. Instructions on how to withdraw such consent will be provided in the marketing communications you receive, or you can withdraw such consent by contacting us via the contact details provided within this Notice.

For us to be able to send you information on our services and products that are relevant to you or your business, we may undertake some behavioural data analysis based on your past behaviour (for example, your attendance at events or opening of emails sent by us or on our behalf).

On what basis is your data collected and used and for what purposes?

Your personal data may be collected and processed by AXA IM on the following legal bases and for the following purposes:

(a) To enable the opening of your account, to manage and administer your holdings in our funds and any related accounts on an ongoing basis, including subscription, redemption, conversion or transfer requests and the distribution of payments;

(b) To comply with our applicable legal, tax or regulatory obligations:

1. Fund legislation: sending you notices or other communications relating to our funds, convening investor meetings;

2. Anti-money laundering and anti-terrorism legislation, and the application of national and international financial sanctions measures:

Implementing monitoring appropriate to the risks of money laundering and terrorist financing throughout the business relationship, detecting funds and economic resources subject to a freezing measure or a sanction measure, identifying risks inherent in the business relationship, placing certain accounts under surveillance, contracts or customers, identification of politically exposed persons, in particular by linking the business relationship file with an external database used as a reference file, identification of funds that should be subject to a freezing measure (taking into account asset freezing lists, OFAC, etc.);

3. Tax regulation and evasion: we are required to collect certain information about your tax arrangements. Please note that in certain circumstances we may be legally obliged to share this and other financial information relating to your interests in our funds with the relevant tax authorities;

4. Market abuse: taking appropriate steps to identify and prevent market abuse;

5. Recording, retaining and using records of telephone calls you make and receive from us for the purposes of processing and verifying instructions, managing and administering your account(s) and any other matters relating to your investment in our funds;

(c) To pursue our legitimate interests, which include:

1. conducting statistical analysis and market research;

2. sharing information with legitimate third parties such as auditors, regulatory or tax authorities and our technology providers in the day-to-day operation of our products

3. processing complaints and claims;

4. customer relationship management, which involves: (i) sending you information about AXA IM products and services that we think may be of interest to you; (ii) contacting you to receive feedback about AXA IM products or services; (iii) contacting you for other marketing or research purposes; and (iv) sharing information about upcoming events and (v) performing marketing analysis and profiling on the basis of combined data (e.g., your participation in events, the number of visitors to AXA IM's website, the number of visitors to AXA IM’s website and the number of visitors to AXA IM's website). (e.g., your participation in events, opening of emails);

5. tailoring and personalising the information we distribute, by combining and analysing the data we collect, so that we can send you information about our services and products that are relevant to you or your business to provide a tailored and relevant experience;

6. anti-fraud: anomaly detection, analysis and alert management, as well as building lists of proven fraudsters.

What happens if you do not provide us with the personal data requested?

If you do not provide the personal data we need to accept your application, manage and administer your holdings in our funds or provide you with other investment services, we will not be able to accept your application or provide you with investment services or, where appropriate, we may be required to terminate our relationship with you.

We also encourage you to inform us as soon as possible of any changes to your personal data.

Who has access to your personal data?

AXA IM takes all necessary measures to ensure the security and confidentiality of the data it collects, i.e. that only authorised persons have access to it.

Only persons authorised by virtue of their activity in the relevant AXA IM departments in charge of the processing concerned have access to your information, and only within the scope of their authorisation.

AXA Investment Managers Group companies (subsidiaries and branches), our service providers and our partners may also have secure access to your information to the extent necessary for the performance of their services or our partnerships.

Your information will also be provided to certain authorities (tax, financial and other) in accordance with applicable law and regulations. 

Do we transfer your personal data abroad?

Due to the global organisation of the AXA IM group and the use of international service providers (technology or financial), some of your personal data may be located, accessed and/or stored in Switzerland, the European Economic Area (EEA), the UK, the USA, India or any other country in the world.

However, in order to ensure an equivalent or substantially equivalent level of protection for your data and as required by the Federal Act on Data Protection, AXA IM has put in place EU standard contractual clauses, binding corporate rules (Cyber Security and Data Privacy | AXA) and other necessary measures (as the case may be) that govern all transfers of personal data to these Third Countries.

For any further information, including if you wish to obtain a copy of the documents used to protect your data, please contact us at dataprivacy@axa-im.com.

How long do we keep your personal data?

We and our service providers retain your personal data for no longer than is reasonably necessary to fulfil the purpose for which we are processing your personal data and as long as required by applicable legal and regulatory requirements. 

What are your rights?

Under the conditions defined by the Federal Act on Data Protection, you have the right to access, rectify, oppose, limit, delete and – as far as applicable – port your personal data, which you can exercise by contacting the AXA IM Data Protection Officer (DPO) at the following address: dataprivacy@axa-im.com.

In addition, any marketing email can be stopped at any time and without reason by clicking on the link provided in our communications, or by contacting our Data Protection Officer.

If you feel that your request has not been dealt with correctly, you can lodge a complaint with

AXA Investment Managers Switzerland Ltd.
Data Protection Officer
Ernst-Nobs-Platz 7
P.O. Box 1078
8021 Zurich
E-Mail: dataprivacy@axa-im.com

Will there be any changes to this policy?

This policy is up to date and dates from February 2025. It may be amended from time to time and is available on our website.

Please check back frequently to see any updates or changes to this Notice. Alternatively, please contact us using the details provided within this Policy.

Professional Confidentiality

The investor acknowledges that the professional confidentiality according to art. 69 para. 1 lit. a-c Financial Institutions Act (FinIA) may not be preserved in its entirety in each case of a delegation abroad.

Furthermore, optimal customer care, namely sales activities, may require the exchange of information between AXA Investment Managers Schweiz AG and other companies within the AXA Group, both domestically and internationally.

As far as an exchange of customer identity and data within the AXA Group is necessary for fund and asset management, especially for sales activities or the delegation of partial services abroad, AXA Investment Managers Schweiz AG is released from its professional confidentiality duty.

Always reserved are the fiduciary duty, due diligence and duty to inform of the Fund Management Company according to art. 20 CISA, the data protection according to the law and the arrangement stated above as also any existing confidentiality obligations.