Forth Capital Genève Sàrl

Privacy Notice

Forth Capital Genève Sàrl is a company registered in Switzerland and is part of Forth Capital Group which consists of regulated entities who are authorised and regulated in their respective jurisdictions. We provide financial advice to individuals and businesses and in doing so we are committed to protecting and respecting your privacy.

This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us for financial advisory services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

In the course of our engagement with you we may collect and process the following data:
• Identity data – name, date of birth, national insurance number, marital status
• Contact data – address, email, phone number
• Financial data – income, assets, liabilities, tax status
• Tax Data – tax residency, tax identification numbers (TIN), FATCA/CRS information
• Health data – relevant medical information (e.g. for insurance advice)
• Behavioral data – investment risk tolerance, objectives, preferences
• Documentary data – ID documents, proof of address
• Communication data – records of meetings, calls, emails

We may also collect data from third parties such as product providers, credit agencies, or other professional advisers (with your consent).

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We will use your information collected from the website to personalise your repeat visits to the site.

Information about connected individuals

We may need to gather personal information about your close family members and dependants to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

Why do we need to collect and use your personal data?

We must have a lawful basis to process your personal data. Under the Swiss Data Protection Act and EU General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

We have a contractual obligation
This is the primary legal basis that we intend to use for processing your data. The personal information that we collect about you is essential for us to be able to effectively carry out the services that we have agreed to deliver to you.

We have a legal/regulatory obligation
Sometimes, collecting personal data is needed to meet our legal and regulatory obligations. For example, AMLA legislation may require us to collect personal information to verify your identity.

We have a legitimate interest
We rely on legitimate interest in retaining relevant data for the purpose of assessing the appropriateness of our services, defending future complaints and meeting our Professional Indemnity Insurer’s expectations.

We will obtain your consent
Special category data, such as that relating to health matters, is often required to provide our services. When this is required, we’ll obtain your explicit consent to collect and process this information.

From time to time, we may wish to contact you to offer additional products or services which may be of interest to you. To do this, we will obtain your consent.

You may withdraw your consent at any time by notifying us at our main business address.

How will we use the information about you?

We collect information about you to provide you with the services for which you engage us. This includes: -

• Provide financial advice and ongoing service (performance of a contract)
• Process product applications (e.g. pensions, investments, insurance)
• Comply with legal obligations (e.g. anti-money laundering checks)
• Contact you about reviews, changes, or regulatory updates
• Provide you with updates in relation to your policy and financial news (as confirmed by you)
• Fulfil our obligations under Swiss data protection law

Who might we share your information with?

If you agree, we may email you about other products or services that we think may be of interest to you.

If you agree, we will pass on your personal information to our group of companies so that they may offer you their products and services.

We won’t share your information for marketing purposes with companies outside our group of companies / other companies unless it is necessary in the course of providing our services to you, or with your consent.

To deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. We implement security measures including:
• Secure cloud-based storage
• Encryption of sensitive files
• Staff access controls and training
• Regular reviews of systems and compliance

To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes. If data is transferred outside of Switzerland or the EEA we ensure that any transfer are to countries with adequate or equivalent data protection laws.

How long do we keep hold of your information?

During the course of our relationship with you, we will retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods. In accordance with Swiss Law, we must retain your data for as long as necessary to maintain our relationship with you, comply with legal retention obligations (typically 10 years) and to defend legal claims or respond to regulatory enquiries.

After this period data will be securely deleted or anonymised. However, there may be occasions where we are required to retain data for a longer period to comply with international financial services regulations e.g. pension transfer and opt out business relating to UK based pensions.

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

Your Rights Under Swiss Data Protection Act and EU GDPR

You have the right to:
• Request access to your personal data
• Request rectification of inaccurate data
• Request deletion (where legally permitted)
• Object to processing or request restriction
• Withdraw consent at any time
• Object to certain types of data processing
• Data portability

To exercise your rights, you should contact us on the below contact details.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below.

When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing

We would like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you have agreed to receive marketing information, you may opt out later. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post using the contact details below.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity. For further information visit http://www.allaboutcookies.org

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

For more information, please refer to our Cookies Policy and our Website Terms of Use.

Other websites

Our website may contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You have a right to lodge a complaint with the supervisory authority for data protection (Federal Data Protection and Information Commissioner (FDPIC). However, in the first instance we would ask you to reach out to us on using the contact details below so that we can try and rectify any concerns with you.

Changes to our privacy policy

We keep our privacy policy under regular review, and we will place any updates on our website www.forthcapital.com/ch and/or inform you of any changes when they occur.

This privacy policy was last updated on 24 July 2025.