1. General Information

The protection of your personal data and privacy is of paramount importance to Synchrony Asset Management SA (“Synchrony”). This Notice is intended to describe the processes by which Synchrony collects and processes personal data in the course of its business activities. “Personal data” refers to any information relating to an identified or identifiable natural person. The “processing” of such data encompasses any operation involving personal data—regardless of the means or methods used—including, but not limited to, the collection, recording, use, modification, disclosure, archiving, erasure, or destruction of data.

Other regulations, such as terms of use, terms of sale, or contractual terms relating to specific situations, may apply to certain data processing activities, for example, when entering into a contract with Synchrony or in connection with Synchrony’s web pages.

If you provide us with personal data about other individuals (e.g., family members or coworkers), please ensure that those individuals are aware of this Notice and provide us with their personal data only if you are authorized to do so and if such personal data is accurate.

2. Data Security

Synchrony is committed to protecting personal data and privacy in accordance with the Federal Data Protection Act (FADP) and the Data Protection Ordinance (DPO). To this end, Synchrony will implement various technical and organizational security measures (e.g., access restrictions, firewalls, personalized passwords, encryption and authentication technologies, employee training, etc.) to ensure that the processing of personal data complies with applicable legal requirements regarding data protection.

3. Personal Data

The term “personal data” refers to any information that can be used to identify an individual directly (e.g., first name, last name) or indirectly (e.g., a passport number). Synchrony will primarily process personal data provided by its customers and other business partners, as well as by other individuals in the course of its business relationships with them, or data that Synchrony may collect from users when operating its websites, applications, and other platforms.

Synchrony processes the following types of personal data, among others:

Types of Personal Data

Examples

Identification Data

Name, address, phone number, email address, business contact information, photographs, video and audio recordings

Personal Characteristics

Date, place, and country of birth

Identifiers Issued by Public Authorities

Passport, ID card, tax identification number, social security number

Professional Information

Work experience, powers of representation, any sanctions or proceedings

Financial Information

Account history, bank account information

Transaction or investment-related information

Current and past investments, investment profile, investment preferences, amounts invested, number and value of financial instruments held, role played in a transaction (seller/buyer), transaction details

Technical information

IP address, internal and external identifiers, access logs

Commercial information

Preferences, needs

4. Origin of the personal data 

Synchrony may process personal data from the following sources:

- Personal data provided directly by the data subject, for example when opening a business relationship, in the context of the performance of a contract, to benefit from products and services or on websites.

- Personal data required to benefit from products or services and transmitted to Synchrony by the technical infrastructure or specific processes, in particular in the context of payment transactions, securities trading, e-banking, websites or collaboration with other financial or IT service providers or with marketplaces or stock exchanges.

- Personal data from third-party sources, such as public sources (e.g. UN or EU sanctions lists) or other third parties (e.g. introducer or external asset manager).

5. Purposes of the processing 

We use personal data mainly for the purpose of concluding and performing contracts with our clients and business partners, in particular in the context of the provision of financial services and the acquisition of products and services from our suppliers and subcontractors, as well as to comply with national and international legal obligations.

Personal data are processed by Synchrony for the following purposes in particular:

- Performance of a contractual obligation

- Initiation of the business relationship with Synchrony, including all operations related to the identification of a data subject.

- Any other financial service related to the business relationship, in particular the financial services specifically required by the client.

- The management of collective capital investments, including the services related to such activities.

Performance of a legal or regulatory obligation

- The provision to data subjects of information on Synchrony's products and services.

- The monitoring of compliance with legal obligations regarding financial markets regulation.

- Any form of cooperation with the competent authorities, in particular the prudential supervisory authorities, the authorities in charge of combating money laundering and terrorist financing and the authorities involved in the automatic exchange of information in tax matters (including the Common Reporting Standard and the US Foreign Account Tax Compliance Act [FATCA]).

- Any measure taken regarding the implementation of international sanctions in accordance with the procedures established by Synchrony, which involves in particular the processing of personal data for verification purposes (screening).

- Any measure taken regarding risk management, in particular market risks, credit risks, operational risks, liquidity risks, legal risks and reputational risks.

- The recording of telephone conversations and electronic communications with data subjects for the purposes of combating fraud and other offences.

- The assessment of the risks to which Synchrony is subject and decision-making in matters of risk management.

Legitimate interest of Synchrony:

- Any processing with a view to the development of the business relationship.

- Any processing with a view to improving the company's internal organisation and processes, including in matters of risk management.

- The use of personal data for commercial prospecting (marketing) purposes, unless the data subject has refused the use of their personal data for this purpose.

- Any processing necessary to enable Synchrony to establish, exercise or defend against a current or future claim, or to enable Synchrony to face an investigation by a public authority, in Switzerland or abroad.

- The recording of telephone conversations and electronic communications with data subjects for the purposes of protecting Synchrony's interests, analysing and improving the quality of the services and products provided, training the company's staff and managing risks.

6. Transmission of personal data to third parties and third countries 

Synchrony reserves the right to disclose personal data to:

- Administrative authorities (e.g. prudential supervisory authorities) or judicial authorities or financial market players (e.g. an operator of a financial market infrastructure [such as a stock exchange], a broker, a correspondent bank, a sub-custodian, an issuer, an authority in charge of financial markets supervision or their representatives).

- Subcontractors in the context of outsourcing.

- Synchrony's audit body and certain of Synchrony's service providers.

- Affiliated entities.

In the context of the business relationship, Synchrony may disclose, transfer and/or store personal data abroad (hereinafter the "International Transfer"), in particular in connection with the conclusion or performance of contracts relating, directly or indirectly, to the business relationship, for example in the context of outsourcing. International transfers may include transfers to jurisdictions that guarantee an adequate level of protection of the rights and freedoms of data subjects regarding the processing of personal data or that benefit from a decision establishing the adequacy of their level of data protection.

If such a transfer of personal data is made to a country that does not offer an adequate level (from a Swiss perspective) of personal data protection, Synchrony will ensure, if required by the applicable regulations, that it obtains the client's consent or puts in place appropriate safeguards, in particular contractual commitments. Each data subject may contact Synchrony if they wish to obtain additional information on this subject.

7. "Automated individual decisions" and "profiling" 

Synchrony does not use any automated evaluation or any profiling.

8. Use of the website and cookie policy 

When a person visits Synchrony's web pages, the server automatically records the details of their visit (e.g. the web page from which the visit took place, the visitor's IP address, the content of Synchrony's website consulted as well as the date and duration of the visit). This tracking data serves to optimise Synchrony's web pages and provides information on how the visitor informs themselves about Synchrony's products, services and offers and how they use them. However, it generally does not make it possible to know the identity of the visitor. This technical data, including the IP address, may constitute personal data. Synchrony processes it in order to ensure the operation, security and optimisation of its web pages. If the visitor provides personal data, for example by filling in a registration form or a message field for the newsletter, etc.,

Synchrony may use this data for the following purposes (in addition to the purposes mentioned in point 5):

- the administration of clients and users;

- informing the visitor about the services and products;

- marketing (e.g. sending newsletters);

- the technical "hosting" and development of Synchrony's web pages.

When visiting Synchrony's website, the visitor's data is transmitted via the Internet, an open network accessible to all. Data transmitted electronically (including by e-mail) cannot be effectively protected against access by third parties. This entails in particular the following risks: disclosure of the data or modification of its content, impersonation of the sender's identity (e.g. e-mail) and of the content of the message or manipulation thereof by unauthorised persons, propagation of viruses, technical transmission errors, delays or interruptions, uncontrolled transmission of data abroad where the requirements regarding data protection may be less strict than in Switzerland, etc.

In addition, by using Synchrony's website, a visitor accepts the use of cookies. Cookies are small files that are stored on the visitor's computer in order to track the visit to the corresponding website and navigation between the different pages and/or to record settings (e.g. the chosen language). Cookies serve to collect statistical data on the frequency and duration of visits to the different parts of the website and contribute to the design of tailor-made, useful and user-friendly websites. The visitor may object at any time to the use of cookies by deleting the cookies installed by Synchrony's website. Deletion is possible via the settings of the visitor's Internet browser.

Occasionally, Synchrony uses third-party components (such as plug-ins) to improve the user experience and its online advertising campaigns. These elements may also use cookies for similar purposes. Neither these third parties nor Synchrony have access to the data collected by the other party by means of cookies. Furthermore, Synchrony may use cookies in the context of Synchrony advertisements published on third-party websites with which Synchrony maintains business relationships. If third parties collect anonymised information on the use of Synchrony's website and other websites, Synchrony may use this anonymised data to improve the effectiveness of its advertising actions.

Point 8 of this Notice applies only to the data obtained by Synchrony following the use of Synchrony's website. The Notice does not apply to third-party websites, even if the visitor goes there via links located on a Synchrony web page. Synchrony has no influence on the content of third-party websites or the processing of personal data by these websites and therefore declines any responsibility in this respect.

9. Retention period 

Synchrony retains personal data for as long as necessary to achieve the intended purpose. Synchrony deletes or anonymises personal data when it is no longer necessary to achieve a purpose,

- subject to the legal and regulatory obligations applicable to Synchrony regarding the retention of documents and information; and

- subject to cases in which a longer retention period is necessary to enable Synchrony to establish, exercise or defend against a current or future claim, or to enable Synchrony to face an investigation by a public authority, in Switzerland or abroad (e.g. implementation of a "legal hold").

10. Rights of data subjects 

Within the framework and limits of the applicable regulations, each data subject has the following rights in connection with their personal data:

- the right to access their personal data;

- the right to have their personal data rectified when it is inaccurate or incomplete;

- the right to object to the processing of their personal data;

- the right to request the restriction of the processing of their personal data; and

- the right to request the delivery of their personal data in a commonly used electronic format, or its transmission to another controller, when the legal conditions are met;

- the right to request the deletion of their personal data when it is no longer necessary in relation to the purposes for which it was collected or processed or when the data subject has withdrawn their consent (for cases in which the processing of the personal data concerned is based on the consent of the data subject).

Synchrony specifically draws the attention of each data subject to the fact that the latter may, at any time and without justification, object to the use of their personal data for commercial prospecting (marketing) purposes by Synchrony or by third parties, or that they may, when the processing has consent as its legal basis, withdraw their consent, by writing to Synchrony.

The exercise of some of the rights mentioned above may result in Synchrony no longer being able to provide certain products or services.

11. Additional information 

Synchrony, in its capacity as "controller", may be contacted at the following address:

Synchrony Asset Management SA

Quai de l'Île 17, 1204 Geneva, Switzerland

Tel. +41 (0)22 350 52 00 

info@synchrony.ch 

www.synchrony.ch

If a data subject wishes to obtain additional information on the subjects covered in this Notice, they may contact the above address.

If they are not satisfied with the response provided by Synchrony, they have the right to contact the Federal Data Protection and Information Commissioner.

Synchrony reserves the right to modify this Notice at any time. Last updated: August 2026