Privacy policy of Prio Partners AG

1. Preliminary remarks

In this Privacy Policy, we, Prio Partners AG, Stockerstrasse 12, 8002 Zurich (CHE-349.498.861) (hereinafter ‘Prio Partners’, “we” or ‘us’), explain how we collect and otherwise process personal data. This is not an exhaustive description; other statements, terms and conditions, information sheets or contracts may govern specific matters.Personal data is understood to mean all information relating to an identified or identifiable person.If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please make sure that these persons are aware of this Privacy Policy and only provide us with their personal data if you are authorised to do so and if this personal data is correct. This Privacy Policy is designed to meet the requirements of the Swiss Data Protection Act (‘DPA’). Whether and to what extent these laws are applicable, however, depends on the individual case.

2. Liability

We are liable for the data processing described here, unless otherwise stated in individual cases. If you have any data protection concerns, you can inform us of these at the above contact address, by e-mail to info@priopartners.ch or by telephone on +41 44 201 26 26.

3. Collection and processing of personal data

We primarily process the personal data that we receive from our clients and other business partners in the course of our business relationships with them and other persons involved (e.g. names, addresses, e-mail addresses, passport and ID information or numbers, bank account details, financial and professional circumstances, investment objectives, knowledge and experience in financial matters and other data required for the provision of financial services and compliance with regulatory provisions (such as the Anti-Money Laundering Act). This data includes names, addresses, e-mail addresses, passport and ID numbers, bank account details, financial and professional circumstances, investment objectives, knowledge and experience in financial matters and other data that must be collected for the provision of financial services and compliance with regulatory requirements (such as the Anti-Money Laundering Act) or that we collect from users when operating our website (see examples at the end of this section 3).

In addition to data about you that you transmit to us directly (which may also contain particularly sensitive personal data), the data concerning you may also relate in particular to the following information:

  • Information and data from publicly accessible sources/registers, from authorities or other third parties (e.g. commercial register, land registers, press, Internet);
  • Information that we receive in connection with official and legal proceedings;
  • Information in connection with your professional functions and activities;
  • Information from correspondence and meetings with third parties;
  • Credit information (insofar as we conduct business with you personally);
  • Information about you that people close to you (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. references, CV details, powers of attorney, information on compliance with legal requirements such as anti-money laundering, financial market regulation and export restrictions); or
  • Personal data from the media and the Internet (if this is appropriate in a specific case, e.g. as part of an application or a compliance customer check).
  • Your addresses and, if applicable, data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

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Purposes of data processing and legal basis

We use the personal data we collect primarily to conclude and process our contracts with our clients and business partners, in particular as part of our provision of financial services in the areas of professional asset management and investment advice for individual clients and collective investments, as well as to fulfil our legal obligations in Switzerland and abroad (e.g. financial market regulatory requirements). If you work for such a client or business partner, your personal data may of course also be affected in this function.

  • Where permitted and appropriate, we also process personal data about you and other persons for the following purposes, in the pursuit of which we (and sometimes third parties) have a legitimate interest:
  • Offer and further develop our services;
  • Client verification and background checks (KYC) to fulfil our regulatory requirements;
  • Review and administration of employee applications;
  • Examination and optimisation of procedures for needs analysis for the purpose of customer approach and customer acquisition;
  • Advertising and marketing (including the organisation of events), provided you have not objected to the use of your data in this regard (you can object to the advertising of our services at any time);
  • Assertion and defence of claims in connection with legal disputes and official proceedings;
  • Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analyses to combat fraud);
  • Guarantees of our operations, in particular IT and data security;
  • Video surveillance to safeguard domiciliary rights and other measures for IT, building and facility security and to protect our employees and other persons and assets belonging to or entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone recordings);
  • Purchase and sale of business divisions, companies or parts of companies and other transactions under company law and the associated transfer of personal data.


If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been given can be revoked at any time, but this has no effect on data processing that has already taken place.

5. Cookies / tracking and other technologies in connection with the use of our website

We typically use ‘cookies’ and similar technologies on our website to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. This enables us to recognise you when you return to this website, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website (session cookies), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) (permanent cookies). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies to save your user settings (e.g. language, autologin) so that we can better understand how you use our offers and content and so that we can show you customised offers and advertising. Cookies are set both by us and by contractual partners with whom we work. Blocking cookies may result in limited functionality (e.g. language selection, shopping basket, ordering processes) of our website.

In some of our newsletters and other marketing emails, we also use visible and invisible image elements, where permitted, which enable us to determine whether and when you have opened an email. This also serves to measure and better understand how our offers can be used and customised for our customers.

By using our website and agreeing to receive newsletters and other marketing e-mails, you consent to the use of these techniques. If you do not want this, you must set your browser or e-mail programme accordingly.

We sometimes use Google Analytics or similar services on our website. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as a processor (both ‘Google’), www.google.com), with which we can measure and analyse the use of the website (not personalised). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors to Google in Europe are truncated before being forwarded to the USA and therefore cannot be traced. We have switched off the settings ‘Data transfer’ and ‘Signals’. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

We also use plug-ins from social networks such as Facebook, X, YouTube, Pinterest and Instagram on our website. This is visible to you in each case (typically via corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

6. Data transfer and data transmission abroad

Where necessary, authorised and compatible with the principles of professional secrecy, we also disclose personal data to third parties in the course of our business activities and for the purposes set out in section 4, either because they process the data for us or because they require the data for their own purposes. Data may be transferred to the following persons (the ‘recipients’), among others:

  • Service providers of Prio Partners (e.g. banks, insurance companies), including order processors (e.g. IT providers);
  • Subcontractors and other business partners of Prio Partners or you (e.g. custodian banks, funds, providers of financial instruments);
  • Clients of Prio Partners;
  • Domestic and foreign authorities, official bodies or courts (e.g. the Swiss Financial Market Supervisory Authority FINMA or the supervisory organisation that supervises us in accordance with the Financial Market Supervision Act);
  • Industry organisations, associations, organisations and other bodies;
  • Acquirers or parties interested in acquiring the company or business units; other parties in potential or actual legal proceedings.


These recipients may be located in Germany or abroad and your data may be transferred in particular to other European countries and to the USA, where the service providers we use or their headquarters are located (e.g. Microsoft).

If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection (we use the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption clause. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the fulfilment of a contract requires such disclosure, if you have consented to the transfer or if the data in question has been made generally accessible by you and you have not objected to its processing.

7. Duration of storage of personal data

We process and store your personal data for as long as is necessary for the fulfilment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against Prio Partners and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

8. Data security

We take appropriate technical and organisational security precautions to protect your personal data from unauthorised access and misuse, for example by issuing instructions, selecting suitable IT and network security solutions, access controls and restrictions, encrypting data carriers and transmissions or pseudonymising personal data.

9. Obligation to provide personal data

You should provide us with the personal data that is necessary for the establishment and implementation of your business relationship with Prio Partners and the fulfilment of the associated contractual obligations. Without this data, we will generally not be able to enter into or fulfil a contract with you (or the entity or person you represent).

10. Rights of the person concerned

Within the scope of the data protection law applicable to you, you have the right to information, correction, deletion, restriction of data processing and objection to our data processing as well as to the surrender of certain personal data for the purpose of transfer to another organisation (so-called data portability). However, we reserve the right to assert the restrictions provided for by law, for example if we are legally obliged to store or process certain data, have an overriding interest in doing so or require personal data for the assertion of claims. We will inform you in advance if you will incur costs in connection with the assertion of data protection claims. We have already informed you in section 4 about the possibility of withdrawing your consent to certain data processing. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature cancellation of the contract.

The exercise of claims under data protection law generally requires that you clearly prove your identity (e.g. by means of a copy of your ID, if your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 2.

They also have the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent Swiss data protection authority is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Changes

Prio Partners may amend this privacy policy at any time and without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.