This Notice explains how Euler companies including Euler ILS Partners Ltd, Euler ILS Europe GmbH, and Euler ILS Partners Holding AG, its officers, employees, affiliates and related parties (“Euler”, “we”, “our” or “us”) collect, use, store and disclose personal data.
1. What does this Notice cover?
This Notice applies to anyone who interacts directly or indirectly with us in a professional or business capacity including: former, current and prospective clients, investors, shareholders, beneficial owners, officers, employees, applicants, contractors, service providers, advisors, consultants, agents, representatives, business partners, trading counterparties, and other business relationships with the Euler and its affiliates and related entities (“data subjects”, or “you”).
This Notice is designed to comply with the Swiss Federal Act on Data Protection (“FADP”), and where applicable the EU General Data Protection Regulation (“GDPR”), and other applicable Swiss and international data protection related laws.
We value transparency and want to ensure that you understand how we handle your data, why we collect it, and what rights you have. If you have any questions, please contact us using the details provided in the "Contact Information" section below.
2. What types of Personal Data do we collect?
We collect and process different types of personal data depending on our relationship with you and the nature of our interactions. The categories of personal data we may collect includes the following categories but not limited to:
Identification and contract information: name, date of birth, nationality, home and work addresses, email addresses, phone numbers government-issued identification (e.g. passport, ID, permit), and other identification and contact information.
Financial and investment information: bank account details, payment information, contractual agreements, financial data, investment and transaction history and preferences, contract data, due diligence and financial background check data, creditworthiness data, and other financial and investment information.
Professional and employment data: application and recruiting data, employment contract, terms and conditions of employment, job title, employer details, professional qualifications, employment history and references, HR and payroll data, compensation records, tax and social security contributions, benefits and entitlements, background screening, compliance and disciplinary records, and other professional and employment data.
Communication data: emails, letters, call recordings, message exchanged with us and any other interaction with us through any different means, and other business communication data.
Technical and website usage data: IP addresses, browser type, device information, cookies and online tracking technologies, log files and analytics data, and other technical and website usage data.
Special categories of data (only where necessary and legally permitted): criminal background checks (if relevant for regulatory compliance), health information (if relevant for HR/payroll purposes), and other special categories data.
The categories of data collected vary based on the nature of the relationship with the Companies.
We may also collect information about your directors, representatives, employees, shareholders or beneficial owners. Before providing us with this information, you should inform those persons accordingly and provide a copy of this notice to them.
We collect data directly from you or third parties, such as governmental agencies, public and licensed databases, screening services, intermediaries that facilitate data portability where appropriate.
We may use cookies, tracking technologies and other means (e.g., web beacons, pixels, gifs, tags, unique identifiers) to collect and process the above information from different channels and devices you use, including email and devices that you use to interact with us to access the Euler’s website, its extended platforms, products, services and applications for mobile devices.
We may use Personal Data for analytics and measurement (incl. machine learning) to process the above information, including profiling based on the processing of your Personal Data, for instance by looking at information we obtain via cookies and tracking technologies.
3. For which purposes do we process your Personal Data and what legal basis do we rely on?
We process personal data based on various legal grounds, including contractual necessity, legal obligations, legitimate interests, and consent. The primary purposes for which we process personal data include:
Contractual Obligations: to establish and maintain business relationships, to provide services, to process transactions, investments, and payments, to fulfill our contractual duties to clients, employees, and service providers, and other third parties, etc.
Legal and Regulatory Compliance: Compliance with anti-money laundering (AML) and know-your-customer (KYC) laws, regulatory compliance and audit obligations, compliance with tax, employment, and corporate governance laws, etc.
Legitimate Interests:business and operation management, risk management and fraud prevention, internal and external reporting, data analysis, and business planning, managing internal communication, IT systems and business operations, improving our services and interactions, organization of events, etc.
Consent: where legally required, such as for marketing communications, processing sensitive data in specific situations, etc.
Where we rely on consent, you have the right to withdraw it at any time, subject to applicable laws and regulations.
We use both automated (including artificial intelligence) and manual methods to process your Personal Data for these purposes. Our automated methods often are related to and supported by our manual methods. For example, our artificial intelligence systems may analyze your data to identify patterns and trends, which are usually manually reviewed and interpreted by humans.
4. How do we protect Personal Data?
We take data security seriously and implement strict safeguards to protect personal data from unauthorized access, alteration, loss, or misuse. Our security measures include:
Technical Safeguards: Encryption, firewalls, access controls, and intrusion detection systems, etc.
Organizational Measures: Strict access policies, confidentiality agreements, and staff training, etc.
Physical Security: Secure office premises, restricted access to servers, and secure disposal of data, etc.
While a Data Protection Officer (DPO) is not legally required, a designated privacy contact is available to address data protection inquiries. Please refer to the "Contact Information" section below.
We have implemented policies and procedures to respond to data breaches, in accordance with applicable privacy laws. Affected individuals and regulators will be notified as required by law in case of a significant data breach. We regularly assess cybersecurity risks and implement best practices to protect Personal Data.
5. Who has access to Personal Data and with whom are they shared?
We only share personal data when necessary and in compliance with data protection laws. Recipients may include:
Governmental agencies and regulatory authorities: Financial market regulatory bodies and agencies, tax authorities, social security institutions, compliance agencies, AML/KYC monitoring entities and other governmental and administrative agencies.
Clients: collective investment schemes, investment vehicles, management companies, and their service providers, contractors, advisors, representatives and other business partners related directly or indirectly to Euler.
Financial institutions and brokers: Banks, custodians, brokers, investment platforms, collective investment schemes, trading counterparties, risk transformers, fronters, clearing houses, insurance companies and other financial institutions.
Service providers and contractors: IT providers, payroll processors, pension funds, financial advisors, sub-distributors, consultants, contractors, advisors, reserving actuaries, valuation agents, external auditors, governmental, tax and administrative agencies, and other direct and indirect service providers, vendors and contractors.
Affiliates and business Partners: officers, shareholders, corporate affiliates, related parties and other business partners.
Legal and compliance professionals: External legal counsel, compliance officers, risk officers, enforcement agencies, courts, mediation and other authorities and agencies.
We transfer Personal Data internationally, including to the European Union, Switzerland, the United Kingdom, and the United States. Data transfers comply with applicable safeguards, and other legally recognized mechanisms. If necessary, explicit consent may be obtained to ensure compliance with data protection requirements.
Data transfers to third parties are conducted in accordance with applicable legal safeguards and other recognized mechanisms.
In some instances, we also share Personal Data with our suppliers, who are contractually bound to confidentiality, such as IT hardware, software and outsourcing providers, logistics, mail, courier, printing services and storage providers, marketing and communication providers, facility management companies, market data service providers, transportation and travel management providers and others. When we do so we take steps to ensure they meet our data security standards, so that your Personal Data remains typically secure. Where we transfer your data to service providers processing data on our behalf, we take steps to ensure they meet our data security standards, so that your Personal Data remains secure. Service providers are thereby typically mandated to comply with a list of technical and organizational security measures, irrespective of their location, including as relevant measures relating to:
information security management;
information security risk assessment and
information security measures (e.g., physical controls; logical access controls; malware and hacking protection; data encryption measures; backup and recovery management measures).
If required from time to time, we disclose Personal Data to public authorities, regulators or governmental bodies, courts or party to proceedings, where we are required to disclose information by applicable law or regulation, under a code of practice or conduct, at their request, or to safeguard our legitimate interests.
We may need to disclose Personal Data to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others;
A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of the Companies’ businesses or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
Any other legitimate recipient required by applicable laws or regulations.
Subject to any agreement applicable to your business relationship with us (including the General Conditions), the Personal Data transferred within or outside Euler as set out herein, is in some cases also processed in other countries. We only transfer your Personal Data abroad to countries which are considered to provide an adequate level of data protection, or in the absence of such legislation that guarantees adequate protection, based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission or another statutory exemption) provided by local applicable law. A copy of these measures can be obtained by contacting Euler using the details provided in the "Contact Information" section below.
If and to the extent required by applicable law, we implement the necessary legal, operational and technical measure and/or enter into an agreement with you before such transfers.
Euler and third-party service providers are required by law or contract to comply with the corresponding confidentiality obligations. Access to client identifying data will be safeguarded by appropriate technical and organizational measures.
6. How long do we store your data?
We retain Personal Data only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws and regulations (e.g. 10 years).
Once our relationship with you has ended, we will only keep your personal data for a period that is appropriate, which in many cases is up to 10 years after our relationship ended. The period we keep information for is often linked to the amount of time available to bring a legal claim, required by law or regulations, or for compliance and risk management or for audit purposes. We will keep your personal data after this time if we have to do so by law and regulation, if there are existing or potential claims or complaints that will reasonably require us to keep your information, or for regulatory reasons. If we do need to keep your information for a longer period, we will continue to protect that information. However, if you wish to have your Personal Data removed from our databases, you can make a request as described below, which we will review as set out therein. Due to requirements laid down by the Swiss Financial Market Supervisory Authority ("FINMA"), we are also obliged to record external and internal telephone calls of all employees engaged in securities trading. We must furthermore store all electronic correspondence (e-mails, communication via Bloomberg, etc.) and evidence of the calls made on business telephones by these employees for a certain period. We must also make this information available to FINMA on demand. This applies also to employees identified by a risk-based assessment as being highly exposed to information that has relevance to market supervision.
7. What are your rights and how can you exercise them?
You have various rights which may, subject to applicable laws and regulations, include:
Access: Request a copy of your personal data
Correction: Request corrections to inaccurate data
Erasure: Request deletion of data (subject to legal exceptions)
Restriction: Limit how we process your data
Objection: Object to processing based on legitimate interests
Data portability: Request transfer of data to another provider
Withdraw consent: Revoke consent where processing is based on it
To exercise your rights, contact us at the details below.
When Personal Data is processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketing by clicking the "unsubscribe" link in any of our e-mails to you, or by emailing us at the addressed indicated herein at any time.
Where we process your Personal Data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your Personal Data be transferred to you (known as the ‘data portability’ right), subject to applicable laws and regulations. You also have the right to ask Euler for information regarding some or all of the Personal Data we collect and process about you, subject to applicable laws and regulations.
We will honor such requests, withdrawal or objection as required under applicable data protection rules but these rights are not absolute: they do not always apply and exemptions may be engaged. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
8. Changes to your Personal Data
To ensure accuracy, please inform us promptly if your personal data changes. Keeping your information up to date allows us to serve you better and meet regulatory requirements.
9. Updates to this Notice
This Notice was updated in March 2025. We reserve the right to amend it from time to time without further notice.
10. Contact Information
For any questions or requests regarding your personal data, please contact us at:
Email: legal.notice@euler.ltd