Privacy Policy

This privacy statement applies to HTLC Network Group A.G. and HTLC Network S.A. with registered office address at Corso San Gottardo 16, 6830 Chiasso, Switzerland, and the business entities we own or control (hereinafter “HTLC Network”, “we”, “us” or “our”).

We are committed to protecting your information by handling its responsibly and safeguarding it using appropriate technical, administrative and physical security measures. This privacy statement explains how we will collect, handle, store and protect information about you when:

1. providing services to you or our clients;
2. you use our website; or
3. performing any other activity that form part of the operation of our business.

When we refer to “our website” or “this website”, we mean the specific webpages of www.htlcnetwork.com and www.htlcnetwork.brokerage.com.

In this privacy statement, your information is sometimes called “personal data”. We may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.

We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.

When we provide services to you or our clients (or discuss possible services we might provide), we will process personal data about you. We may also collect personal data from you when you use our Website.

We may process your data because:

1. you give it to us (for instance, in a form on our Website);
2. other people give it to us (for instance, your employer or HR manager, or third-party service providers that we use to help operate our business); or
3. it is publicly available.

We may process personal data from you because we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience of this Website and to make sure that it is working effectively. For example, we (or our service providers) may use cookies (small text files stored in a user’s browser) to collect personal data. More information on how we use these and other tracking technologies – and how you can control them – can be found in our cookie notice.

The personal data we process may include your:

1. name, gender, age and date of birth;
2. contact information, such as address, email, and mobile phone number;
3. country of residence;
4. lifestyle and social circumstances (for example, your hobbies);
5. family circumstances (for example, your marital status and dependents);
6. employment and education details (for example, the organization you work for, your job title and your education details);
7. financial and tax-related information (for example your income, investments and tax residency);
8. postings or messages on any blogs, forums, platforms, wikis or social media applications and services that we provide (including with third parties);
9. IP address, browser type and language, your access times;
10. information in any complaints you make;
11. details of how you use our products and services;
12. CCTV footage and other information we collect when you access our premises; and
13. details of how you like to interact with us, and other similar information relevant to our relationship.

The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:

1. health (for instance, so that we can make it easy for you to access our buildings, products and services); and
2. sexual orientation (for instance, if you provide us with details of your spouse or partner).

We may also process personal data relating to ethnic or racial origin (e.g. any multicultural networks you belong to), or about your political opinions (inferred from information you give us about political associations you belong to or have donated to).

We will typically seek separate permission from you in writing to process these special categories of personal data.

If you choose not to provide, or object to us processing, the information we collect we may not be able to process your instructions or continue to provide some or all of our services to you or our client.

When our client or another third-party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for instance, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.

If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.

We process information about you and/or your business to enable us and other members of HTLC Network Group to provide our services to you or our clients, and to meet our legal or regulatory obligations.

Some of your personal data may be used for other business purposes, including the followings.

Use of personal data to provide services to our clients

We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:

1. you;
2. other third parties or other members of HTLC Network;

• our service providers; or

1. competent authorities.

Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:

1. a client’s employees to help those employees manage their tax affairs and immigration documents when working overseas;
2. a client to help them complete a tax return.

Use of personal data for other activities that form part of the operation of our business

We may also use your personal data in connection with:

1. legal or regulatory requirements;
2. requests and communications from competent authorities;

• client account opening and other administrative tasks;

1. financial accounting, invoicing and risk analysis;
2. relationship management, which may involve:
   1. sending you thought leadership or details of our products and services;
   2. contacting you for feedback on services;
   3. sending you event invitations; and
   4. other marketing or research purposes;
3. recruitment and business development, which may involve:
   1. the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
   2. the use of third-party data sources to help us verify and improve the information we hold about key business.

• services we receive from our professional advisors, such as lawyers, accountants and local consultants;
• protecting our rights and those of our clients.

Use of personal data collected via our Website

In addition to the above, we may also use your personal data collected via our Website:

1. to manage and improve our Website;
2. to tailor the content of our Website to give you a more personalized experience;
3. to draw your attention to information about our products and services that may be of interest to you; or
4. to manage and respond to any request you submit through our Website.

We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:

1. you have explicitly agreed to us processing your information for a specific reason;
2. the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
3. the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
4. the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:
   1. to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
   2. to prevent fraud;
   3. to protect our business interests;
   4. to ensure that complaints are investigated;
   5. to evaluate, develop or improve our services or products; or
   6. to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

1. you have given us your explicit consent to process that data;
2. we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
3. the processing is necessary to carry out our obligations under employment, social security or social protection law;
4. the processing is necessary for the establishment, exercise or defense of legal claims; or
5. you have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

In connection with any of the purposes outlined in the “How we use your personal data?” section above, we may disclose details about you to:

1. other members of the HTLC Network Group or third parties that provide services or online platforms to us;
2. competent authorities (including courts and authorities regulating us and other members of the HTLC Network Group);
3. your employer and/or its advisers, or your HR managers;
4. anyone to whom we may transfer our rights and/or obligations under the Terms of Use;
5. any other person or organization after a restructure, sale or acquisition of any member of the HTLC Network Group, as long as they use your information for the same purposes we did;
6. credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud; and
7. other third parties that reasonably require access to personal data relating to you.

Our Website hosts a blog and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.

Information we hold about you may be transferred to other countries, which may include countries outside the European Economic Area (“EEA”):

1. where we provide services;
2. which are linked to your engagement with us;
3. from where you regularly receive or transmit information; or
4. where our third parties conduct their activities.

These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.

When we, or our permitted third parties, transfer your personal data outside the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.

We may also transfer your personal data when:

1. the transfer is to a country deemed to provide adequate protection of your personal data by the European Commission; or
2. where you have consented to the transfer.

If we transfer your personal data outside the EEA in other circumstances (for example, because we are forced to by law), we will make sure it remains adequately protected.

We may share non-personal, anonymized, and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.

We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:

1. education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
2. administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
3. technological security measures, including fire walls, encryption and anti- virus software; and
4. physical security measures, such as security passes to access our premises.

The transmission of data over the internet (including by e-mail) is never completely secure. Therefore, although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.

We seek to ensure that we only keep your personal data for the longest of:

1. the period necessary for the relevant activity or services;
2. any retention period that is required by law; or
3. the period in which litigation or investigations might arise in respect of the services.

You have various rights in relation to your personal data. Specifically, you have the right to:

1. obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
2. be informed about the processing of your personal data (e.g. for what purposes, what types, to what recipients it is disclosed, storage periods, any third-party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
3. ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
4. ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
5. receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
6. ask us to stop or start sending you marketing messages at any time by using the contact details in section 13 below; and
7. object to our processing of your personal data.

If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavor to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

To help us ensure that your information is up to date, please, let us know if any of your personal details change using the contact details set out in section 12. Moreover, you may also use the contact details in section 12 if you wish to make a complaint relating to your privacy.

We and other members of HTLC Network Group may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of your interest.

You may, at any time, ask us and/or other members of HTLC Network Group not to send marketing information to you by following the unsubscribe instructions in communications from us, or contacting us in the way described the section below.

If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about privacy issues, or you wish to raise a complaint about how we are using your information, you can contact us in the following ways:

1. write to the Data Protection Officer – HTLC Network AG based in Corso San Gottardo 16, 6830 Chiasso, Switzerland.
2. send an email to dataprotection.eu@htlcnetwork.com

You can also complain to the Office of the Federal Data Protection and Information Commissioner, which supervises the use of personal data in the CH: Feldeggweg 1, CH – 3003 Berne. If you are not based in Switzerland, you have a right to complain to the EU Data Protection Authority in your jurisdiction.