Privacy Policy

In this privacy policy (the "Privacy Policy") we, Spring Equity Partners SA (hereinafter "Spring", "we", "us" or "our"), explain how we collect and process some personal data in connection with our activities and your consultation of our website <https://spring-equity.com/> (the "Website") in particular. The Privacy Policy may not cover all of our data processing activities and may be superseded by other specific information.

If you provide us with personal data of other individuals, it is your excusive responsibility to ensure that they are aware of this Privacy Policy and that you provide us with their personal data only if authorized to do so and if such personal data is accurate and up to date.

1. Who are we?

The party responsible as data controller for the processing of your personal data described in this Privacy Policy is Spring Equity Partners SA, Place du Molard 3, 1204 Geneva, Switzerland.

In case of any questions or requests relating to this Privacy Policy or to the processing of your personal data you can contact us at info@spring-equity.com.

2. What personal data do we process?

We primarily process personal data about users of our Website, our customers, potential customers, business partners and private individuals, such as persons reaching out to us with business or general inquiries or further to a specific interest.

In addition to personal data that you have provided directly to us, we may collect personal data from third parties, such as information from public registers, information relating to your position and professional activities, your personal background, information such as your financial history, professional or business background, criminal history, personal reputation and integrity, legal and regulatory compliance and sources of funding, bank details, contact details (e.g. name, address, telephone number, e-mail address, date of birth), information about you found in the media or on the Internet, your possible interests as well as other socio-demographic data and data relating to your use of our Website (such as IP address, MAC address of your smartphone or computer, information about your device and settings, cookies, date and time of your visits, sites and content consulted, applications used, referring website, location data).

3. Why do we process personal data?

In accordance with applicable law and where applicable, SEP may process personal data for the following purposes: (a) to provide and develop our services, products, processes, and websites (including the Website), applications and other platforms which we may operate; (b) to communicate with you and process your requests or inquiries; (c) to process business requests or job applications from prospects; (d) to advertise and market our services and products, as permitted by applicable law, including, as applicable, through sales and marketing communications (unless you are not interested); (e) to conduct market research and understand customer interests (including by creating customer profiles with financial goals and personal preferences) for personalized advice and strengthen customer relationships; (f) for media and press monitoring; (g) to manage administrative and technical aspects of our business and conduct our operations, including our computer systems, websites, apps and other applications, as the case may be; (h) to comply with applicable law and our internal policies; (i) to assert and defend our rights; (j) for network and information security; and/or (k) to ensure the security of our premises, systems, property, and personnel.

4. Do we use cookies, tracking or similar technologies to monitor our Website?

This Website uses cookies to support core functionality (necessary cookies), analyze user interactions by tracking metrics like visitor count and traffic sources (performance cookies), and enhance user experience by remembering preferences and behaviors (functionality cookies). These cookies ensure the Website operates smoothly while improving usability and understanding audience engagement.

5. Do we share your personal data?

In connection with the purposes described above, we may transfer personal data to third parties. These third parties can process data on our behalf or, as the case may be, for their own purposes. Third party data recipients ("recipients") that may receive personal data from us are: (a) service providers and subcontractors, which can be affiliates of SEP or external providers (such as brokers, customer service centers, HR and employment service providers, background screening agencies); (b) IT providers (in particular for CRM and data management, telecommunications, data storage and hosting and IT security); (c) financial institutions and insurance companies or brokers; (d) analytics and reporting vendors; (e) professional advisors, such as legal, tax and financial advisors and auditors; (f) regulatory and compliance services, such as self-regulatory organisations; (g) authorities, courts, regulators and ombudsman; (h) and/or other parties involved in legal proceedings.

SEP is hosting personal data in Switzerland and processes personal data within Switzerland. In principle, recipients are exclusively located in Switzerland. However, if we have to transfer personal data outside of Switzerland to a third country that does not provide an adequate level of data protection, we will take necessary measures. Such measures may typically include implementation of binding corporate rules or standard contractual clauses, in each case as approved by the competent supervisory authority. We may also rely on statutory derogations such as your consent, contract necessity, the recognition, safeguarding or exercise of rights, an overriding public interest, personal data made public without objection and/or the protection of integrity of data subjects.

6. Changes to this Privacy Policy

We can amend this Privacy Policy at any time without prior notice. The current version published on our Website is authoritative. If the Privacy Policy forms part of an agreement with you, we will inform you of any changes by e-mail or other appropriate means.