Privacy Policy
J. Lamarck Asset Management SA

In accordance with the Federal Act on Data Protection (FADP), we hereby provide you with the necessary information regarding the processing of personal data provided during your visit and navigation on the website of J. Lamarck Asset Management. This information does not bind other third-party websites that may be accessible through this website.

1. Personal data, processing, and data subject

1.1. Personal data
All information concerning an identified or identifiable natural person.

1.2. Processing
Processing means any operation related to personal data, regardless of the means and methods used, including collection, recording, storage, use, modification, communication, archiving, deletion, or destruction of data.

1.3. Data subject
The data subject is the natural person whose personal data is processed.

2. Data controller and data protection officer

2.1. Data Controller
The individual or entity who, alone or jointly with others, determines the purposes and means of processing.
In this instance, the data controller is:
J. Lamarck Asset Management
Via Greina 3
6900 Lugano
Telephone: +41 91 911 00 10
Email: info@jlamarck.com

2.2 Data protection consultant
J. Lamarck Asset Management is not obligated to appoint a data protection consultant and, if necessary, relies on experienced consultants. For any information regarding this notice and the processing of Personal Data by J. Lamarck Asset Management, you can contact the company at the address mentioned in point 2.1 above.

2.3. Data processors / joint controllers
Any data processors, i.e., third parties processing personal data on behalf of the data controller, are companies with which J. Lamarck Asset Management has contractual relationships in Switzerland. An internal list of J. Lamarck Asset Management’s contractual partners is constantly monitored by the Company.

3. Purposes of data processing

a) The data collected through this website are used exclusively for the following purposes:Visit and navigation: Navigation data, such as IP addresses, domain names, URI/URL addresses of requested resources, request times, and other parameters related to the user’s operating system and computer environment, are acquired for the proper functioning of the website during the visit and navigation. This data is not stored beyond the user’s browsing session.
b) Handling contact requests: Data provided by users through the contact form is used solely to respond to user requests and for direct communication purposes with the user. This data will not be shared with third parties or used for purposes other than direct communication with the user, except for the use of Google reCAPTCHA. Please note that the use of reCAPTCHA may involve the collection and sharing of some data with Google. This data is subject to Google’s privacy policy and terms of service.

4. Navigation Data

The computer systems responsible for the operation of this website acquire some personal data, normally used by Internet communication protocols, for their operation. This category of data includes IP addresses or domain names of computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of requested resources, request times, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters related to the user’s operating system and computer environment.

5. Contact Form and User Data

The contact form on the website requires users to provide their email for responding to their requests. This data will be used exclusively to respond to user requests and will not be shared with third parties or used for purposes other than direct communication with the user, except for the use of Google reCAPTCHA, which we use to prevent spam. This service helps confirm that the form submission is made by a real user and not an automated program. Please note that the use of reCAPTCHA may involve the collection and sharing of some data with Google. This data is subject to Google’s privacy policy (https://policies.google.com/privacy) and terms of service (https://policies.google.com/terms).

6. Legal basis for processing

The legal basis for processing for the navigation of this website is the overriding interest of J. Lamarck Asset Management.

Meanwhile, the processing of data provided through the contact form is justified by the performance of pre-contractual and contractual measures.

7. Data retention

The data retention period is limited to the duration of the user’s browsing session for navigation data. Data provided by users through the contact form is stored in the email inbox related to the contact email address provided by J. Lamarck Asset Management and has a minimum retention period of 6 months.

8. Communication of data

8.1. Communications to third parties

The data subject’s personal data may be communicated to recipients, who will process the data in their capacity as data controllers, as natural persons acting under the authority of the data controller and data processor, for the purposes listed above:

  • entities providing services for the management of the information system used by J. Lamarck Asset Management and communication means (including email);
  • entities supporting J. Lamarck Asset Management in managing web platforms;
  • firms or companies in the context of assistance and consultancy relationships;
  • competent authorities for compliance with legal obligations and/or orders from public authorities, upon request.

The list of Data Controller is regularly updated and available at the Data Controller’s office.

8.2. Transfer abroad
Personal data may only be communicated abroad if the Federal Council has determined that the legislation of the recipient state or international organization guarantees adequate data protection.
J. Lamarck Asset Management relies solely on certified and secure service providers that (i) are established in Switzerland or (exceptionally) in the European Union and (ii) process personal data in Switzerland or (exceptionally) in the European Union. Therefore, communications of personal data to states that do not adequately protect data under Swiss and European law are excluded, except for communications based on the prior explicit consent of the data subject or on their explicit instruction or executed due to a legal obligation.

9. Profiling

Currently, our website does not use profiling processes or automated decisions for the analysis of user personal data. However, we may implement such practices in the future to improve our services and communications with users. In that case, we will provide additional information and request consent, if necessary, before initiating any form of profiling.

You have the right to object to any form of profiling or automated decision that we may implement in the future. To exercise this right or for further information, please contact us through the contact form on the website.

10. Rights of data subject

According to the FADP, the data subject has, in particular, the following rights (non-exhaustive list):

  • right to information about the possible processing of personal data concerning the data subject;
  • right of access, including:
    • obtaining the correction of inaccurate or outdated personal data;
    • being informed in writing and free of charge whether their personal data is processed;
    • withdrawing consent to the processing of data given in the past;
    • expressing an opinion on an individual automated decision or requesting it to be reconsidered by a natural person;
  • right to receive data or demand its transmission to third parties;
  • requesting that data processing be blocked, preventing its communication to third parties, or that personal data be corrected or destroyed.

In addition to any other administrative and judicial recourse, if the data subject believes that the processing of their data violates the provisions set out by the LPD, they have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).
The exercise of rights by the data subject may be made either by sending them to J. Lamarck Asset Management’s address or, if appointed, to the Data Protection Advisor using J. Lamarck Asset Management’s address.

11. Amendments to this Privacy Policy

Lamarck Asset Management reserves the right to update this Policy at any time updating the Privacy Policy on our website: https://jlamarck.com/.

Version: June 2024