1.  Introduction
‍In this privacy policy, we, 2trade group ltd (hereinafter referred to as "we" or "us"), explain how we collect and process personal data. We provide asset management services as well as real estate management services for you. 
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The aim of this information is 
· to provide you with comprehensive information about how we process your personal data;
· to explain your rights in connection with the processing of your personal data; 
as well as
· to provide you with the contact details of the office responsible for processing your personal data.

Your trust is important to us, which is why we take the issue of data protection seriously and ensure appropriate security. We are committed to handling your personal data responsibly. It goes without saying that we comply with the provisions of the Federal Act on Data Protection (FADP), the Ordinance to the Federal Act on Data Protection (FADP), the Telecommunications Act (TCA) and, where applicable, other provisions of data protection law.

So that you know what personal data we collect from you and for what purposes we use it, please take note of the information below.

‍2.  What personal data do we process and for what purpose?
‍Depending on your activity, we process the following personal data:

2.1  Visiting the website
When you visit our websites, our servers temporarily store each access in a log file. The following data is collected without your intervention and stored by us until automated deletion (after 12 months at the latest):
· the IP address of the requesting computer (shortened);
· the name of your Internet access provider (usually your Internet access provider);
· the date and time of access;
· the name and URL of the file accessed;
· the page and address of the website from which you were redirected to our websites and, if applicable, the search term used;
· the country from which our website was accessed;
· the operating system of your computer and the browser you are using (provider, version and language);
· the transmission protocol used (e.g. HTTP/1.1).

This data is collected and processed for the purpose of enabling the use of our websites (connection establishment), ensuring system security and stability on a permanent basis, enabling the optimization of our website and for internal statistical purposes. 

Only in the event of an attack on the network infrastructure or suspicion of other unauthorized or improper website use will the IP address be evaluated for the purpose of clarification and defense and, if necessary, used in criminal proceedings to identify and take civil or criminal action against the users concerned.

Finally, we use cookies and other applications based on cookies when you visit our websites. You can find further information on this in the "Cookies" chapters.

‍2.2  When opening and maintaining a customer relationship
‍When opening a customer relationship, we process the following personal data:
· Name, first name*
· Address*
· Date of birth*
· Telephone number*
· Gender*
· Passport/ID*
· Risk Assessment*
· KYC Form/Customer Profile*
  - Register of the beneficial owner
  - Business activity
  - Professional status
  - Property status
  - Assets
  - Reputation
· Power of attorney*

This data processing is necessary to enter into a contractual relationship with us. 
Certain data are mandatory (marked with *). If you do not provide us with the mandatory information, it is not possible to open a customer account.
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We are required by law to make further inquiries when entering into and maintaining customer relationships. In particular, we are subject to an extensive identification obligation with regard to new and existing customers and are also subject to Swiss money laundering legislation. 
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Furthermore, this data is used to maintain the business relationship with you, to provide our services and to invoice you. 

Finally, this personal data is also used to open an account for you with a custodian bank.

‍2.3  Money Laundering Act
‍The following data is collected as part of audits for compliance with the Money Laundering Act:
· Name, first name*
· Address*
· Date of birth*
· Telephone number*
· Gender*
· Passport/power bill/other proof of address*
· Risk assessment*
· KYC form/register of beneficial owners/passport/proof of address*
· Register of Directors/KYC form/passport/proof of address*
· Name and contact information of managing director or authorized representative *
· Name of directors and officers*
· Nationality*
· Civil Status*
· Marital status*
· Tax status*

The purpose of this data processing lies in the legal obligation to comply with the provisions of the Anti-Money Laundering Act. It is therefore necessary for the fulfillment of the legal obligations. 

Certain data are mandatory (marked with *). If you do not provide us with the mandatory information, we will not be able to complete the verification of compliance with the Anti-Money Laundering Act.


‍3.  From which sources do we collect your personal data? 
‍In principle, we collect personal data directly from you (e.g. via forms, in the course of communication with us, in connection with contracts, when using the website, etc.). 

Unless this is inadmissible, we also take data from publicly accessible sources (e.g. business registers, land registers, commercial registers, media or the Internet including social media) or receive data from other companies, from authorities and from other third parties (such as data collections on criminal activities (such as Risk Check).

The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities, information about you in correspondence and meetings with third parties, creditworthiness information so that we can conclude or process contracts with you or involving you (e.g., information on compliance with legal requirements, and information on the use of your personal data). e.g., information to comply with legal requirements such as those relating to fraud, money laundering, terrorism and export restrictions, information about you from the media and the Internet).


‍4.  Location where data is stored
‍Your personal data will be stored in Switzerland.


‍5.  Will the personal data be forwarded to third parties?
‍We share your personal data with the following categories of recipients:

· Service providers: we work with service providers in Switzerland who process data about you on our behalf or in joint responsibility with us or who receive data about you from us in their own responsibility (e.g. IT providers, banks and trustees). 
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The central IT service provider for us is TTP Consulting AG in Erlenbach.
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We disclose to these service providers in each case the data required for the services, which may also concern you. These service providers may also use such data for their own purposes, e.g. information about outstanding debts and your payment history in the case of credit agencies or anonymized information to improve services. In addition, we enter into contracts with these service providers that include provisions to protect your personal information. Our service providers may also process data about how their services are used and other data that arise in the course of using their services as independent data controllers for their own legitimate interests (e.g., for statistical analysis or billing). Service providers provide information about their independent data processing in their own data protection statements.

· Authorities: We may pass on personal data to offices, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The authorities then process this data on their own responsibility.
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All these categories of recipients may in turn involve third parties, so that your data may also be made available to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).

We also allow certain third parties to collect personal data from you on our website and at our events (e.g. media photographers, providers of tools that we have integrated on our website, etc.). Insofar as we are not decisively involved in these data collections, these third parties are solely responsible for them. If you have any concerns or wish to assert your data protection rights, please contact these third parties directly.

6.  Transmission of personal data abroad
‍Your personal data will be processed in Switzerland.


‍7.  Your rights
‍You may object to data processing at any time. You also have the following rights:

‍Right to information: you have the right to request at any time, free of charge, to inspect your personal data stored by us when we process it. This gives you the opportunity to check what personal data we are processing about you and that we are using it in accordance with applicable data protection regulations.

‍Right to rectification: You have the right to have inaccurate or incomplete personal data rectified and to be informed about the rectification. In this case, we will inform the recipients of the data concerned of the adjustments made, unless this is impossible or involves a disproportionate effort.

‍Right to erasure: You have the right to have your personal data erased under certain circumstances. In individual cases, the right to deletion may be excluded.

‍Right to restrict processing: Under certain circumstances, you have the right to have us restrict the processing of your personal data.

‍Right to data transfer: Under certain circumstances, you have the right to receive free of charge the personal data you have provided to us in a machine-readable format.

‍Right of withdrawal: In principle, you have the right to withdraw your consent at any time with effect for the future. Processing activities based on your consent in the past will not become unlawful as a result of your revocation.


‍8.  Retention period
‍We retain personal data for as long as it is needed for the purpose for which it was collected, or for a period for which we are obligated by applicable laws, regulations or contractual agreements, and for as long as we have an overriding interest in retaining it. Afterwards, the data will be deleted.

Retention obligations, which oblige us to retain data, result from accounting regulations and tax regulations. According to these regulations, business communication, concluded contracts and accounting vouchers must be stored for up to 10 years. Likewise, certain data must be retained for up to 10 years after termination of the business relationship in accordance with money laundering legislation.


‍9.  Data security
‍We take appropriate technical and organizational security measures to protect personal data from unauthorized access and misuse. These include IT and network security solutions, access restrictions, encryption of data carriers and transmissions, instructions, protection and controls.
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If third parties have access to our data, special measures are taken which are regulated in the order processing contract.


10.  Contact
‍If you have any questions about data protection, would like information, would like to object to data processing or would like to have your data deleted, please contact us by sending an email to info@2trade.ch. 
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You can also send a letter to the following address:
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2trade group ltd.
Seefeldstrasse 277
8008 Zürich


‍11.  Customization
‍This privacy policy is not part of any contract with you. We can adapt this data protection declaration at any time. The version published on www.2trade.ch is the current version. 

Last update: 01.09.2023