1. Introduction
Prim West S.A. ("we," "our," or "us") is committed to protecting the privacy and security
of your personal information. This Privacy Policy explains how we collect, use, disclose,
and safeguard your information when you visit our website or engage with our services.
2. Information We Collect
Personal Information
We may collect the following types of personal information:
- Full legal name
- Email address and phone number
- Country of residence
- Investment experience and financial information
- Source of funds information
- Identity verification documents
Automatically Collected Information
- IP address and browser type
- Device information
- Usage data and analytics
- Cookies and tracking technologies
3. How We Use Your Information
We use collected information for the following purposes:
- Processing shareholder qualification applications
- Verifying identity and conducting due diligence (KYC/AML)
- Managing shareholder accounts and subscriptions
- Providing shareholder portal access and services
- Sending important notices and updates
- Complying with legal and regulatory obligations
- Improving our website and services
- Preventing fraud and ensuring security
4. Legal Basis for Processing (GDPR)
We process personal data based on:
- Contractual Necessity: To fulfill our obligations under shareholder agreements
- Legal Obligation: To comply with AML, KYC, and financial regulations
- Legitimate Interest: To operate our business and prevent fraud
- Consent: Where you have provided explicit consent
5. Information Sharing and Disclosure
We may share your information with:
- Service Providers: Third-party vendors who assist in operations
- Regulatory Authorities: When required by law or regulation
- Legal Advisors: Professional advisors bound by confidentiality
- Business Transfers: In connection with mergers or acquisitions
We do not sell or rent your personal information to third parties.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal
information, including:
- Encryption of data in transit and at rest
- Secure server infrastructure
- Access controls and authentication
- Regular security assessments
- Employee confidentiality obligations
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes outlined
in this policy, comply with legal obligations, resolve disputes, and enforce agreements.
Shareholder records are retained in accordance with Swiss financial regulations.
8. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access: Request access to your personal information
- Correction: Request correction of inaccurate data
- Deletion: Request deletion of your data (subject to legal obligations)
- Portability: Request transfer of your data
- Objection: Object to certain processing activities
- Withdrawal: Withdraw consent where applicable
To exercise these rights, contact us at: [email protected]
9. Cookies and Tracking
We use cookies and similar technologies to enhance user experience, analyze usage, and
improve our services. You can control cookie preferences through your browser settings.
10. International Data Transfers
Your information may be transferred to and processed in countries outside your country
of residence. We ensure appropriate safeguards are in place for such transfers in
compliance with applicable data protection laws.
11. Children's Privacy
Our services are not directed to individuals under 18 years of age. We do not knowingly
collect personal information from children.
12. Changes to This Policy
We may update this Privacy Policy periodically. Changes will be posted on this page with
an updated "Last Updated" date. Continued use of our services constitutes acceptance of
the updated policy.
13. Contact Information
Data Protection Officer
Email: [email protected]
Address: Geneva, Switzerland
If you have concerns about our data practices, you have the right to lodge a complaint
with your local data protection authority.