Privacy Policy

This Privacy Policy explains how JAR (Switzerland) SA (hereinafter “we” or “our company”), a wealth management firm licensed by FINMA, collects, processes, stores and protects your personal data in compliance with the Swiss Federal Act on Data Protection (FADP), the Financial Services Act (FinSA), and, where applicable, the European General Data Protection Regulation (GDPR).

1. Legal Framework

  • Swiss Federal Act on Data Protection (FADP, RS 235.1)
  • Ordinance to the FADP (OFADP)
  • General Data Protection Regulation (GDPR – EU 2016/679), applicable to EU residents or when cross-border financial services are involved

2. Personal Data We Collect

We process personal information to enable us to provide financial services and advice, maintain our own accounts and records and in certain instances to promote our services. For this reason, the information processed may include

  • Identification data: name, surname, date of birth, nationality
  • Contact data: postal address, email, phone number
  • Financial data: income, wealth, investment objectives
  • KYC/AML data: identity documents, tax information, corroborating documents
  • Any other information required for compliance with legal obligations

3. How we collect your personal information

We may collect your personal information from the following sources: When you provide us with Data directly:

  • During the account opening process, we will complete a number of forms to allow us to
    build a picture of you and your needs
  • When you talk to us on the phone
  • In emails and letters
  • In customer surveys
  • During annual reviews where we update your information and details

Data we collect when you use our services:

  • Payment and bank details when you provide them to us. Including when we are involved in setting up any accounts you instruct us to with external parties including custodians.
  • Transactional data
  • Profile and usage data. We may gather data from devices you use to connect to our services using cookies and other internet tracking software

Data from third parties we work with:

  • Companies or individuals that introduce you to us
  • Information service providers – we are required to undertake screening against negative media, PEP and sanctions lists as part of client due diligence. For that JAR use online tools which may provide us with personal data.
  • Other professional bodies
  • Regulators and Law enforcement agencies
  • Public information sources including Companies House and other business/directorship searches.

4. Purposes of Processing

  • Establish, manage and execute contractual relationships (management mandate, advisory, etc.)
  • Fulfill legal obligations regarding anti-money laundering, tax, and regulatory compliance (FinSA, AMLA, FINMA)
  • Comply with legal recordkeeping obligations
  • Communicate with you in the context of our business relationship
  • Ensure the security of our information systems and website
  • Direct marketing, subject to your consent where required

5. Legal Grounds for Processing

  • Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR / Art. 31(2)(a) FADP)
  • Legal or regulatory obligation (Art. 6(1)(c) GDPR / Art. 31(2)(c) FADP)
  • Legitimate interest (Art. 6(1)(f) GDPR / Art. 31(1) FADP)
  • Explicit consent (Art. 6(1)(a) GDPR / Art. 31(1) FADP)

6. Data Recipients

At all times we will respect you wishes regarding sharing any of your personal data. There may be instances where it is necessary for JAR to share your information in order to provide you with a product or service or to fulfil a legal obligation. As such your information could be shared with members of the JAR group in the course of managing your account and providing you with a service. During the course of our activities we may also be required to share your information with regulators, professional advisers and consultants, service providers, credit reference agencies and business associates as well as companies that introduce you to us and companies you ask us to share your data.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of JAR Geneva S.A. our customers, or others we will only do so to the extent that is required to fulfil our obligation. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

7. Data Transfers Abroad

We operate internationally and may transfer information to countries outside the European Economic Area (EEA) for the purposes described in this policy. For example, we deal with a number of custodians in other jurisdictions and as such would be required to share your details with them during the account opening process and on an ongoing basis. We rely on multiple legal bases to lawfully transfer personal information internationally.

8. Data Retention

  • As long as necessary for the purposes described above
  • In compliance with minimum legal retention periods
  • Your data are stored in Switzerland

9. Your Rights

  • Right to access your personal data
  • Right to rectify inaccurate or incomplete data
  • Right to request erasure of your data, within legal limits
  • Right to restrict processing
  • Right to object (especially to marketing-related processing)
  • Right to data portability (where applicable)
  • Right to withdraw consent at any time with future effect
  • Right to lodge a complaint with a supervisory authority (e.g., FDPIC in Switzerland, CNIL in France)

10. Data Security

  • We implement appropriate technical and organizational measures to ensure the security, confidentiality, and integrity of your personal data, including encryption, firewalls, and restricted access.

11. Use of Cookies

  • Our website may use technical and analytical cookies. For more information or to manage your preferences, please consult our Cookie Policy.

12. Changes to the Policy

  • We reserve the right to amend this privacy policy at any time. The current version published
    on our website at the time of access shall apply.

13. Communication

  • For any inquiries or concerns regarding our Privacy Policy, or to report a complaint about how your personal data is processed
  • Contact Person:
    – Name: Nicolas Stampfli
    – Email: nicolas.stampfli@jarcapital.swiss
    – Phone: +41796806232
    – Address: Rue du Rhône 14, 1204 Geneva