PRIVACY POLICY

Novum Capital Partners SA (“Novum” or “we” or “us”) takes the protection of your personal data very seriously. Whether you are a former, prospective or current client or simply a visitor to our website, the confidentiality and security of your personal data are fundamental requirements to which we are committed.

You will find hereinafter important information for you to understand what kind of data Novum may collect from you and how Novum deals with the data it collects.

This Privacy Policy may be updated at any time. As a result, we invite you to consult it regularly. The date of the most recent update is indicated at the bottom of this document.

TYPES OF INFORMATION WE COLLECT AND PURPOSE OF DATA COLLECTION

Novum collect data that you provide to us voluntarily when filling our online form. These data are your last name, first name, e-mail address and country of domicile. The specific purpose of this data collection and process is to allow you to access our Weekly Market Flash, which shall provide you with financial markets information and markets outlooks.

We also collect personal data from you in the process of opening a business relationship with you or in the course of a business relationship entered into by you with Novum. In this context, we collect personal data about you from various questionnaires you may complete and agreements you may sign with us. The information collected may include data about you (name, company name, title, address, country of domicile, e-mail address, telephone number), your financial situation, professional and personal background, knowledge and experience in finance, investment objectives and risk tolerance. Your personal data are collected for the specific purpose of providing you with the services contemplated or agreed with you.

In addition to the specific purpose for which your personal data are collected, as stated above, Novum may use your personal data for the following purposes:

Complying with our legal and regulatory obligations;
Exercising and/or defending our legal claims;
Improving our services;
Proposing new services or products to you;
Sending you marketing materials and/or financial information;
Inviting you to marketing presentation or events organised by Novum or by a third party.

We do not use your personal data for other purposes than those mentioned above.

THIRD PARTIES WITH WHO WE MAY PROCESS YOUR PERSONAL DATA

For the purposes outlined above, Novum may share your personal data with third parties, in particular:

Supervisory and governmental authorities to which Novum is required to communicate certain personal data relating to its clients (e.g. agreements signed by the client, beneficial owners of the assets under management or advisory, transactions, bank accounts);
Judicial or administrative authorities;
Third parties such as auditors, custodian banks, external lawyers, consultants;
Sub-contractors, i.e. any services provider appointed by Novum for the purposes of assisting it in the execution of its obligations (e.g. for storage, administrative or operational purposes).

When appointing sub-contractors, Novum ensures that these sub-contractors are contractually bound by commitments regarding the protection, security and confidentiality of data pursuant to Swiss data protection legislation or equivalent legislation, should they have access to your personal data.

SECURITY OF YOUR PERSONAL DATA

Novum takes the necessary security measures (e.g. firewalls or anti-virus software), notably organizational and technical, to ensure confidentiality, integrity and availability of your personal data, as well as the security of our data processing, in order to protect your personal data against unlawful processing (access, disclosure, use) and against loss, destruction, accidental damage and alteration.

The following organisational and technical measures have been implemented:

Our employees only access your personal data if that is relevant to their duties and they each are bound by strict professional duty of discretion and confidentiality concerning your personal data;
Our premises and access to our server is protected.

DATA TRANSFER

Your personal data are stored in our server, which is located in Switzerland. If your are domiciled outside of Switzerland, you hereby consent to the transfer of your personal data from your jurisdiction of domicile to Switzerland and you hereby confirm that such a transfer is legally valid under the laws of your country of domicile.

Novum draws your attention to the fact that data transferred via a public network, such as the internet or a non-secured e-mail service are not protected, so that third parties may access the information and use it without your consent or your data may be lost. Also, even if both the sender and the recipient of a message are located in the same country, data may be transferred without controls through these public networks to other countries, including to countries that do not offer the same level of protection as the one applying in your country of domicile. Even if we take all steps currently possible in order to mitigate these risks, Novum cannot guarantee the confidentiality and the security of messages or documents transferred through public networks (including third-party networks); as a result, Novum cannot be held liable for any direct or indirect losses incurred by you as they result from the use of such networks. Please note that you can use other means of communication to transfer data to Novum if you deem this to be necessary or appropriate to protect your personal data.

DATA STORAGE

Novum retains your personal data in accordance with applicable data protection laws as long as it is needed for the purposes mentioned above. As a result, we erase your personal data when retention thereof is no longer reasonably necessary to achieve the purposes of data processing, or if you ask us to erase your data, unless retention thereof is required by operation of law.

COOKIES

This website does not use any cookie.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You have the following rights regarding your personal data collected by Novum:
Right to access your personal data, including the right to request a copy thereof from us;
Right to obtain a rectification of any inaccurate personal data;
Right to request erasure of your personal data (subject to any legal or regulatory duty to retain your personal data);
Right to restrict the processing of your personal data by Novum;
Right to object to the processing of your personal data, including to the processing of your personal data for marketing purposes (e.g. you may refuse to receive our market news);
Right to withdraw at any time your consent to the processing of your personal data, being specified that such withdrawal does not invalidate the lawfulness of the processing based on your consent prior to the withdrawal;
Right to lodge a complaint with Swiss Data Protection Authorities.

You can exercise your rights by using the contact information set out below.

Please however note that in certain circumstances, we may be unable to grant you any of the rights mentioned above, in part or in full, when the processing of your personal data is still required, among other things, to prevent fraud, to meet our legal obligations, to retain evidence, to keep a record of transactions or to exercise and/or defend our legal claims.

CONTACT INFORMATION

You can exercise your rights relating to your personal data by sending a written request either by post mail, at Novum Capital Partners SA, Rue des Alpes 7, 1201 Genève for the attention of the Compliance service or by e-mail at info@novumcapitalpartners.com.

APPLICABLE LAW AND JURISDICTION

This Privacy Policy and all issues resulting from or relating to it shall be governed by Swiss substantive laws. Any dispute, difference of opinion or objection arising out of or in relation to this Privacy Policy shall fall under the exclusive jurisdiction of the ordinary courts of the Canton of Geneva, which shall be without prejudice to any right of appeal to the Swiss Federal Supreme Court.