Data protection declaration (Privacy policy)

Thank you for your interest in our company. Data protection is important to us and this privacy policy is intended to explain how we collect and process personal data, i.e. data concerning an identified or identifiable natural person, such as name, address, nationality, e-mail address, interests and hobbies, user behaviour on websites. This privacy policy is based on the EU General Data Protection Regulation (GDPR).

1 Controller, data protection officer and representative
(1) First Advisory Trust reg., Wuhrstrasse 6, Vaduz, is the controller under data protection law.
(2) The contact details of the data protection officer are as follows:
e-mail: datenschutzbeauftragter(at)first.li,
Telephone: +423 236 30 00

2 Collection of personal data and purposes of the processing
(1) We limit the processing of personal data primarily to data which we receive in connection with our products and services from our customers, our cooperation partners or other parties involved, or which we collect from users on our websites, apps and other applications.

(2) In particular, we collect the following personal data from you, based on the specific purpose (see below):

Title
First name, last name
Address
e-mail address
Telephone number(s)
Date of birth
Nationality
Hobbies / personal interests
Family relationships
Tax identification number
Bank details

(3) If permitted and appropriate, we also obtain and process other specifically relevant data from publicly accessible sources (e.g. land register, trade register, media, internet, World-Check) or receive this data from other group companies, authorities and institutions and your personal environment such as family and legal advisor or from third parties.

(4) We need the data mainly for the following purposes:

To identify you as a customer, cooperation partner or user of our website
To correspond with you
To comply with our duty of care
To comply with other legal regulations
To enter into and process service agreements, e.g. incorporation order, mandate agreements, license agreements
To enter into and process purchase and sale contracts, e.g. for purchase of products from suppliers or sale to prospective customers
To invoice
To provide other services from our organisation or in cooperation with third parties when appropriate
To provide the best possible customised services to you and to further develop our range of products and services
To communicate with third parties
To assess and respond to applications
To promote and market our products and services (unless you have raised an objection to this use of your data)
To assert legal claims or defend our position in general
To safeguard our business in general (e.g. IT, websites, apps)
To use CCTV as a security element for access management (including visitor lists or other access controls)
To maintain other security aspects

(5) We only process your personal data if we have a legal or contractual basis for doing so or if processing of the data is necessary to perform a duty which is in the public interest or is exercised under public authority. Otherwise we only process data if we have your permission and no refusal exists, or if a legitimate interest of our own is overriding (e.g. continued delivery of newsletters to existing customers, again only if no refusal exists). Permission may be withdrawn at any time.

3 Recipients of personal data and international data transfer
(1) We only transmit your personal data to recipients or third parties in connection with the purposes described above, if permitted and appropriate. They may particularly include:

Group companies
Service providers such as banks, asset management companies, insurance companies, IT providers, print shops
Customers of ours
Suppliers, dealers, transport companies, subcontractors or other cooperative partners
Authorities, state institutions, courts
Societies, public interest institutions

(2) This type of data transmission is based on a legal obligation (e.g. data transfer under the Automatic Exchange of Information), performance of a contract (e.g. foreign asset manager), permission by you, a public interest or a legitimate interest of our own, unless your interests or fundamental rights and freedoms in respect of protection of personal data are overriding.

(3) Recipients may be in this country or abroad. Your attention is drawn in particular to the fact that we may exchange personal data within our group companies or transmit personal data to countries where service companies from which we obtain services (e.g. Microsoft, Thomson Reuters) are located.

If recipients outside our company are located in the EU/EEA or in countries with recognised data protection adequacy (e.g. Switzerland), we ensure data protection by entering into an outsourced data processing agreement – if necessary and appropriate.

If we transfer personal data to third party countries without adequate legal data protection, we ensure an adequate level of protection in accordance with legal requirements, for example, on the basis of standard EU contract clauses or other instruments (e.g. binding corporate rules, US privacy shield).

4 Use of our website(s)
In addition to the above, we inform you when you use our websites about the use of cookies, analytics/tracking and other technologies, as follows:

(1) If your use of the website is purely for information (i.e. you do not log in, register or provide us with other information to use the website) we do not collect any personal data with the exception of data communicated by your browser to enable you to visit the website, which may include the following specific data:

IP address
Date and time of inquiry
Time zone difference from Greenwich Mean Time (GMT)
Content of request (actual webpage)
Access status/HTTP status code
Data volume transferred
Website from which the request comes
Browser used
Operating system and its interface
Browser software language and version

(2) Our website uses ‘cookies’. These are small text files that are placed on your device through the browser. Cookies are not harmful.

We only use them to make our offering more user friendly. Some cookies remain stored on your device until you delete them. They allow us to recognise your browser when you next visit.

If you do not want this, you can set your browser to let you know if cookies are placed and only allow this in exceptional cases. We must point out that in this case you may not be able to use all the functions on our websites fully.

(3) We use Google Analytics on our websites. Google Analytics is a web analytics service provided by Google Inc. in the USA which uses cookies. Web analytics means the collection, compilation and analysis of data on visitor website behaviour. Among other things, a web analytics service generates data on the website from which a particular person has reached a website, which subpages of the site have been accessed or how often and for how long a subpage has been viewed. Web analytics are mainly used to optimize a website and for cost-benefit analysis of online advertising.

The purpose of Google Analytics is to analyse visitor numbers on our website. Google’s use of the data and information obtained includes analysis of the use of our website to compile online reports for us which indicate the activity on our website and provision of other services associated with use of our sites. Google may combine your behaviour with other websites visited by you. If you are a registered Google account holder, Google will recognise you. The Google data protection regulations will then apply to further processing of personal data. Using the cookies, personal information such as access time, place from which access originated and frequency of visits to our website by the person concerned will be stored. On every visit to our websites, the personal data, including the IP address of the internet connection used by the person concerned, will be transmitted to Google in the USA. Google may also transmit the personal data collected via the technical process to third parties.

As described above, the person concerned can prevent cookies being placed through our website at any time by selecting the appropriate settings on the browser used and permanently refusing their use. Setting the browser in this way can also prevent Google placing a cookie on your device (e.g. computer, notebook, tablet). A cookie already placed by Google Analytics can also be deleted at any time via the browser or other software programs.

For more information please contact Google directly, on the following links:
www.google.de/intl/de/policies/privacy/
www.google.com/analytics/terms/de.html
www.google.com/intl/de_de/analytics/

(4) We use Google AdWords on our websites. Google AdWords is an online advertising service which allows advertisers to place ads in both the Google search engine results and the Google advertising network. Google AdWords enables an advertiser to predefine specific key words by which an ad is then only displayed in the Google search engine results if the user uses the search engine to access a search relevant to the key word. In the Google advertising network the ads are distributed across subject relevant websites by means of an automatic algorithm and by recognising the predefined key words.

The purpose of Google AdWords is to promote our website by insertion of interest based advertising on the websites of third companies and in the Google search engine results, and insertion of external advertising on our website.

If a person accesses our website via a Google ad, Google places a conversion cookie on that person’s IT system. We have explained above what cookies are. A conversion cookie ceases to apply after thirty days and is not used to identify the person concerned. If the conversion cookie has not yet expired, it is used to track whether specific subpages, such as the basket of an online shopping system, have been accessed on our website. Through the conversion cookies both we and Google can track whether someone who accesses our website via an AdWords ad has generated a sale, i.e. has completed or discontinued a purchase.

The data and information collected via the conversion cookie is used by Google to produce visitor statistics for our website. We then use these statistics to determine the total number of users routed to us via AdWords ads and therefore the success or failure of each AdWords ad, and to optimise our AdWords ads for the future. Neither our company nor other advertising customers of Google AdWords receive information from Google which could identify the person concerned.

Personal information such as the websites visited by the person concerned is stored by the conversion cookie. Whenever our websites are visited, personal data, including the IP address of the internet connection used by that person, is transmitted to Google in the United States of America. The personal data is then stored by Google in the USA. Google may also transmit the personal data collected via the technical process to third parties.

The person concerned also has the option of refusing interest based advertising by Google. To do this, the person must go to the link www.google.de/settings/ads from each of the internet browsers he uses and then enter the required settings.

5 Data protection in applications and application processes
We collect and process personal data from applicants in order to progress the application process. The processing may be on paper or electronically by e-mail or by completing an online form. If a contract of employment is concluded with an applicant, the personal data received is processed to administer the employment, in accordance with the legal regulations. Otherwise the application documents are deleted three months after rejection, unless deletion is contrary to legitimate interests of our own, for example in connection with a burden of proof in relation to equal treatment. If you give permission, we can keep application documents for a longer period so that they can be considered for any subsequent vacancy.

6 Storage period
We only keep your personal data for as long as necessary for the purposes for which it is collected according to this privacy policy. It may be the case that we are obliged by law to store specific data for a longer period. In this case we make sure that your personal data is handled for the whole period in accordance with this privacy policy.

7 Your rights
(1) You have the right to ask us free of charge at any time about the personal data that we hold about you and its origin, the recipients or categories of recipients to whom the personal data is transferred and the purpose of its storage.

(2) You also have the right to ask us at any time for rectification, deletion or restriction of the processing of your personal data. You also have the right to data portability.

(3) You also have the right at any time to refuse to allow us to process your personal data.

(4) If you have given us permission to use personal data, you may withdraw this at any time without giving reasons.

(5) If you wish to exercise the above rights, please contact the address given in paragraph 1.

8 Data security
We maintain the latest technical facilities to guarantee data security and in particular to protect your personal data against risks in data transfers and from disclosure to third parties. These facilities are always upgraded to the state of the art.

9 Changes
As part of the technical development of our service offering and within the legal framework, we will also continuously adapt our privacy policy. Changes to the policy will be published on our website. Please read the current version of this privacy policy at regular intervals. Subject to the legal provisions in force, all changes to the privacy policy enter into force as soon as the updated policy is published.

10 Web analysis and optimization 
Together with Google Analytics, we use Leadfeeder, a web analytics service and evaluation tool provided by Liidio Oy / Leadfeeder (Mikonkatu 17 C, 00100 Helsinki). Leadfeeder collects the IP address of visitors and links it to information about the companies found on the Internet.

(1) You can prevent Leadfeeder from storing a user profile or data about your use of our website by using an opt-out option, see: https://yourdata.leadfeeder.com/

(2) Further information about Leadfeeder and the data collected can be found at: https://www.leadfeeder.com/privacy/

(3) For information about Leadfeeder and compliance with the GDPR, please visit: https://help.leadfeeder.com/en/articles/1521996-is-leadfeeder-ready-for-gdpr

Vaduz, April 2022