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Legal bases for personal data collection and use

We are authorised to collect and use your personal data in the following cases:


Contract conclusion and execution

We use your personal data to conclude and execute a contract which you have entered into and/or which concerns a related party, and which covers areas like portfolio management, investment fund advisory, administration and distribution and management of subscriptions/redemptions in investment funds.

If providing personal data is a legal obligation, or needed to subscribe and execute contracts with you, any refusal on your part to provide us with these data will prevent us establishing a contractual relationship with you.

Should we require further data during the contract's execution, we may be obliged to terminate the contract if you refuse to comply.

Throughout the life of any contract between you and us, we cannot delete any of your personal data which are required for the execution of the contract you have signed, or which constitute a regulatory obligation for our firm.

Legal obligation

We may have a legal obligation to collect and process your personal data. We have, for example, a duty of care. In some cases, we are legally bound to have the strongest possible grasp of our clients' financial situation so that we can take any changes into account. We may need you, for example, to provide us with details on any changes in your situation and on any transactions which strike us as unusual, whether procedures or amounts, or which appear exceptional compared to your previous dealings.

We may also need to record phone conversations as part of our commercial relationship, or market transactions conducted with external counterparties.

We also have to take steps to fight against fraud, tax evasion, funding of terrorism and money laundering. To comply with these legal obligations, we must, for example, check your identity and keep of a copy of the proof, or ensure that your transactions comply with the information provided when the business relationship was started and that such information is regularly updated.

AAIS or third-party legitimate interests

We may also use your personal data when to do so is in our legitimate interests. When we invoke our legitimate interests to collect and use your personal data, we must ensure that our legitimate interests do not infringe your own legitimate interests, your freedoms or your fundamental rights. We only proceed when we are sure that your interests, rights and freedoms are not jeopardised by our legitimate interests.

When there is a risk that your rights and freedoms might be infringed, we do not use your personal data, unless we have other legal grounds to do so, for example in the conclusion and execution of a contract or for consent.

In some cases, we have a legitimate interest in using your personal data. Examples are:

  • sales proposals;
  • proof of transactions or operations;
  • prevention of fraud and abuse.

When we use your personal data for reasons of legitimate interest, you are entitled to oppose the procedure.


As a general rule, we use your personal data because they are necessary within the scope of the contractual relationship that we have agreed or will agree with you, or by legal obligation, or because or it is in our legitimate interests or those of a third party. In these precise cases, we do not ask for you consent.

In other cases, your consent is needed before your personal data is used. That is why we always recommend you should read any information on personal data use very carefully before giving your consent. It is, however, possible to withdraw your consent at any time.

We always ask for your express consent before processing sensitive data unless legal provisions require us to process this type of data, or allow us to do so, without your consent.