Privacy Policy

1. Introduction

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1.1 Our Commitment to Privacy

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BlynkX AG ("we," "us," "our," or "the Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website www.blynkx-ag.com (the "Website") or engage with our services.

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1.2 Data Controller

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BlynkX AG acts as the data controller for personal information processed in connection with our services. Our contact details are provided in Section 12 of this Policy.

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1.3 Scope of This Policy

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This Policy applies to:

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• Personal information collected through our Website

• Personal information collected during client onboarding and service provision

• Personal information processed by our appointed data processors

• Both individual personal data and corporate contact information

 

2. Legal Basis for Processing

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2.1 Governing Legislation

 

Our data processing activities are governed by:

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• Switzerland: Federal Act on Data Protection (FADP, SR 235.1) and the revised Federal Act on Data Protection (revFADP)

• European Union: General Data Protection Regulation (GDPR, Regulation 2016/679)

• Other jurisdictions: Applicable local data protection laws where we operate

 

2.2 Regulatory Framework

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BlynkX AG operates as an asset manager under the supervision of SO-FIT (Organisme de Surveillance pour Intermédiaires Financiers & Trustees), a supervisory organisation approved by the Swiss Financial Market Supervisory Authority (FINMA). Our data processing activities comply with the regulatory requirements applicable to supervised asset managers in Switzerland.

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2.3 Lawful Bases for Processing

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We process personal information based on the following lawful bases:

Consent (Article 6(1)(a) GDPR / Article 31(1) FADP):

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• Marketing communications (where required)

• Cookie preferences

• Specific processing activities requiring explicit consent

 

Contract Performance (Article 6(1)(b) GDPR / Article 31(2)(a) FADP):

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• Client onboarding and due diligence procedures

• Provision of asset management services

• Processing of investment instructions and portfolio management

• Managing client relationships and communications

 

Legal Obligation (Article 6(1)(c) GDPR / Article 31(2)(b) FADP):

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• Anti-money laundering (AML) and know-your-customer (KYC) requirements under Swiss AMLA

• Regulatory reporting obligations to SO-FIT and other authorities

• Tax reporting under Common Reporting Standard (CRS) and FATCA

• Sanctions screening and compliance

• Record-keeping requirements under Swiss financial market regulations

 

Legitimate Interests (Article 6(1)(f) GDPR / Article 31(1) FADP):

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• Website security and fraud prevention

• Business development and relationship management

• Internal administration and record-keeping

• Legal claims and regulatory investigations

 

3. Information We Collect

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3.1 Information You Provide Directly

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Website Enquiries:

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• Name and contact details (email, telephone, address)

• Company information (for corporate enquiries)

• Nature of enquiry and communication preferences

• Any other information you choose to provide in contact forms or correspondence

 

Client Onboarding (Individual Clients):

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• Full name, date of birth, nationality, and citizenship

• Residential and correspondence addresses

• Identity documents (passport, national ID, driving licence)

• Contact information (email, telephone, mobile)

• Employment and professional information

• Financial information including income, net worth, assets, and investment experience

• Source of wealth and source of funds documentation

• Investment objectives, risk tolerance, and time horizon

• Politically exposed person (PEP) declarations

• Tax residency and identification numbers

• Bank account and custodian information

 

Client Onboarding (Corporate and Institutional Clients):

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• Company name, registration number, and incorporation details

• Registered office and business addresses

• Corporate structure and beneficial ownership information

• Authorised signatories, directors, and board members

• Regulatory licences and permissions

• Financial statements and corporate tax information

• Ultimate beneficial owner (UBO) identification

• Corporate resolutions and signing authorities

• Investment policy statements and mandate parameters

 

Qualified Investor Verification:

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• Documentation to verify status as a qualified investor under Swiss law

• Professional investor certifications or declarations

• Evidence of financial sophistication and investment experience

 

3.2 Information We Collect Automatically

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Website Usage Data:

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• IP address and geolocation information

• Browser type, version, and operating system

• Pages visited, time spent, and navigation patterns

• Referral sources and exit pages

• Device information and screen resolution

 

Cookies and Tracking Technologies:

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• Essential cookies for website functionality

• Analytics cookies for usage statistics

• Preference cookies for user settings

• Security cookies for fraud prevention

• Details of our cookie usage are provided in our Cookie Policy

 

3.3 Information from Third Parties

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Due Diligence Providers:

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• Identity verification results

• Enhanced due diligence reports

• Sanctions and PEP screening results

• Adverse media and reputational checks

 

Public Sources:

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• Corporate registry information

• Regulatory databases and licensing records

• Court records and legal proceedings

• Media reports and public announcements

 

Financial Intermediaries:

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• Information from custodian banks and prime brokers

• Transaction confirmations and settlement information

• References from existing financial service providers

 

Professional Advisers:

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• References from lawyers, accountants, and other advisers

• Verification of professional qualifications

• Confirmation of client relationships

 

4. How We Use Your Information

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4.1 Service Provision

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• Providing discretionary and advisory asset management services

• Conducting client onboarding, due diligence, and suitability assessments

• Executing investment decisions and managing portfolios

• Processing subscriptions, redemptions, and other investment transactions

• Preparing client reports and performance statements

• Managing client relationships and communications

• Maintaining accurate client records

 

4.2 Legal and Regulatory Compliance

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• Fulfilling anti-money laundering (AML) obligations under Swiss AMLA

• Conducting know-your-customer (KYC) and know-your-business (KYB) procedures

• Verifying qualified investor status under Swiss financial market regulations

• Sanctions screening and ongoing monitoring

• Regulatory reporting to SO-FIT, FINMA, and other authorities as required

• Tax reporting under CRS, FATCA, and other international agreements

• Responding to regulatory enquiries and examinations

• Maintaining records as required by Swiss financial market regulations

 

4.3 Business Operations

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• Website administration and security

• Internal record-keeping and administration

• Risk management and compliance monitoring

• Business development and relationship management

• Legal claims and dispute resolution

• Audit and regulatory examinations

• Investment research and market analysis

 

4.4 Communications

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• Responding to enquiries and providing information

• Sending service-related communications and transaction confirmations

• Providing regulatory updates, important notices, and material changes

• Distributing investment reports and market commentary

• Marketing communications (with appropriate consent where required)

 

5. Data Sharing and Disclosure

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5.1 Third-Party Service Providers

 

Custodian Banks and Prime Brokers:

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• Safekeeping of client assets

• Trade execution and settlement

• Corporate actions processing

 

Technology Providers:

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• Website hosting and cloud storage providers

• Portfolio management and reporting systems

• Email and communication service providers

• Document management and storage systems

• Analytics and website performance tools

 

Due Diligence and Compliance Providers:

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• Identity verification and KYC service providers

• Sanctions screening and monitoring services

• Background check and due diligence providers

 

Professional Advisers:

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• Legal counsel for regulatory and compliance matters

• Auditors and compliance consultants

• Tax advisers for reporting obligations

• Other professional service providers as required

 

5.2 Regulatory and Legal Disclosures

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We may disclose personal information to:

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• SO-FIT (our supervisory organisation)

• Swiss Financial Market Supervisory Authority (FINMA)

• Money Laundering Reporting Office Switzerland (MROS)

• Tax authorities under CRS, FATCA, and other reporting obligations

• Law enforcement agencies and regulatory authorities

• Courts and legal proceedings as required by law

• Other authorities as required by applicable laws and regulations

 

5.3 Business Transfers

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In the event of a merger, acquisition, reorganisation, or sale of assets, personal information may be transferred to the acquiring entity, subject to appropriate safeguards, regulatory approvals, and notification requirements.

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5.4 Consent-Based Sharing

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We may share personal information with third parties where you have provided specific consent for such sharing.

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6. International Data Transfers

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6.1 Transfer Mechanisms

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Personal data may be transferred to countries outside Switzerland in connection with our business operations. Such transfers may include:

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European Union:

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• EU-based service providers, custodians, and technology platforms

• Transfers based on adequacy decisions and Standard Contractual Clauses

 

Other Jurisdictions:

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• Service providers and counterparties in other countries as required for investment activities

• Appropriate safeguards implemented including Standard Contractual Clauses

• Assessment of adequacy and data protection standards

 

6.2 Safeguards for International Transfers

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We implement appropriate safeguards for international data transfers including:

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• Standard Contractual Clauses approved by Swiss and EU authorities

• Adequacy decisions recognising equivalent protection

• Binding corporate rules for multinational service providers

• Specific consent where required by applicable law

• Regular review of transfer mechanisms and safeguards​

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