Privacy policy Delta1trader Technology AG

1. Introduction
In this privacy policy we, the Delta1trader Technology AG, Grafenaustrasse 15, 6003 Zug (hereinafter
we or us), explain how we collect and further process personal data. We provide wealth management
services to you.
The aim of this information is
comprehensive information about the processing of your personal data by us;
the explanation of your rights in connection with the processing of your personal data; and
providing the contact details of the entity responsible for processing your personal data.
Your trust is important to us, which is why we take the issue of data protection seriously and ensure
appropriate security. We are committed to handling your personal data responsibly. It goes without
saying that we comply with the provisions of the Federal Act on Data Protection (FADP), the Ordinance
to the Federal Act on Data Protection (OFADP), the Telecommunications Act (TCA) and, where
applicable, other provisions of data protection law.
So that you know what personal data we collect from you and for what purposes we use it, please take
note of the information below.
2. What personal data do we process and for what purpose?
Depending on your activity, we process the following personal data:
2.1 Visit the website
When you visit our websites, our servers temporarily save each access in a log file. The following data
is collected without your intervention and stored by us until automatic deletion (at the latest after 12
months ):
the IP address of the requesting computer (shortened);
the name of your internet access provider (usually your internet access provider);
the date and time of access;
the name and URL of the retrieved file;
the page and address of the website from which you were redirected to our websites and, if
applicable, the search term used;

the country from which our website is accessed;
the operating system of your computer and the browser you use (provider, version and
the transmission protocol used (e.g. HTTP/1.1).
The collection and processing of this data is carried out for the purpose of enabling the use of our
websites (connection establishment), to ensure system security and stability on a permanent basis, to
enable the optimisation of our internet offer as well as for internal statistical purposes.
Only in the event of an attack on the network infrastructure or suspicion of other unauthorised or
abusive website use will the IP address be evaluated for the purpose of clarification and defence and,
if necessary, used as part of criminal proceedings to identify and take civil or criminal action against
the users concerned.
Finally, we use cookies and other applications based on cookies when you visit our websites. You will
find further information on this in the "Cookies" chapters.
2.2 When opening and maintaining a client relationship
When opening a client relationship, we process the following personal data:
Name, first name*
Date of birth*
Phone number*
Passport/electricity bill/other proof of address*
Risk assessment*
KYC form/register of beneficial owners/passport/proof of address*
Register of Directors/KYC Form/Passport/Proof of Address*
Name and contact information of the managing director or authorised representative*
Name of directors and officers*
Power of Attorney*
Criminal record extract
This data processing is necessary in order to enter into a contractual relationship with us.

Certain data are mandatory (marked with *). If you do not provide us with the mandatory information, it
is not possible to open a client relationship.
Furthermore, this data is used to maintain the business relationship with you, to provide our services
and to invoice you.
Finally, your e-mail-address will be used to send you a regular market commentary. You can
unsubscribe to this at any time.
2.3 When opening a client account
When opening a client account (e.g. with a custodian bank or broker), we process the following
personal data:
Name, first name*
Date of birth*
Phone number*
Passport/electricity bill/other proof of address*.
Register of Directors/KYC Form/Passport/Proof of Address*.
Name of directors and officers*
Power of Attorney*

Certain information is mandatory (marked with *). If you do not provide us with the mandatory
information, it will not be possible to open a client account.
We are legally obliged to carry out further clarifications when entering into and maintaining client
relationships. In particular, we are subject to an extensive duty of identification with regard to new and
existing clients and are also subject to Swiss money laundering legislation.

2.4 Money Laundering Act
The following data is collected as part of audits for compliance with the Money Laundering Act:
Name, first name*

Date of birth*
Phone number*
Passport/electricity bill/other proof of address*.
Risk assessment*
KYC form/register of beneficial owners/passport/proof of address*.
Register of Directors/KYC form/passport/proof of address*.
Name and contact information of the managing director or authorised representative *
Name of directors and officers*
Criminal record extract
The purpose of this data processing lies in the legal obligation to comply with the provisions of the
Money Laundering Act. It is therefore necessary for the fulfilment of the legal obligations.
Certain data is mandatory (marked with *). If you do not provide us with the mandatory information,
we will not be able to complete the verification of compliance with the Anti-Money Laundering Act.

3. From which sources do we collect your personal data?
In principle, we collect personal data directly from you (e.g. via forms, in the course of communication
with us, in connection with contracts, when using the website, etc.).
Unless this is inadmissible, we also take data from publicly accessible sources (e.g. debt enforcement
registers, land registers, commercial registers, the media or the internet incl. social media) or receive
data from other companies within our group, from authorities and from other third parties (such as
data collections on criminal activities (such as Risk Check).
The categories of personal data that we receive about you from third parties include, in particular,
information from public registers, information that we obtain in connection with official and legal
proceedings, information in connection with your professional functions and activities, information
about you in correspondence and meetings with third parties, creditworthiness information,
information about you that people close to you provide to us so that we can conclude or process
contracts with you or involving you (e.g. information for compliance with legal requirements such as
for combating fraud, money laundering and terrorism and export restrictions, information about you
from the media and the Internet (where this is appropriate in the specific case).e.g. information to
comply with legal requirements such as those relating to combating fraud, money laundering and
terrorism and export restrictions, information about you from the media and the Internet).

4. Location
Your personal data is stored on our servers locally and on the servers of our IT-providers.
5. Is the personal data passed on to third parties?
We share your personal data with the following categories of recipients:
 Service providers: We work with service providers in Switzerland and abroad who process
data about you on our behalf or in joint responsibility with us or who receive data about you
from us in their own responsibility (e.g. IT providers, accountants, brokers, trading venues).
Central service provider in the IT area for us is TTP Consulting AG. Our main broker is
Ironbeam, Inc, Chicago, United States. Our main trading venues are EUREX and the Chicago
Mercantile Exchange.
We disclose to these service providers the data required for their services, which may also
concern you. These service providers may also use such data for their own purposes, e.g.
information about outstanding debts and your payment history in the case of credit agencies
or anonymised data to improve services. We also enter into contracts with these service
providers that include provisions to protect your personal data. Our service providers may also
process data about how their services are used and other data arising from the use of their
services as independent data controllers for their own legitimate interests (e.g. for statistical
analysis or billing purposes). Service providers inform about their independent data
processing in their own data protection statements. More information on how Microsoft, for
example, processes data can be found here:
de/privacystatement; for the use of Microsoft Teams in particular here:
 Authorities: We may pass on personal data to offices, courts and other authorities in
Switzerland and abroad if we are legally obliged or entitled to do so or if this appears
necessary to protect our interests. The authorities then process this data on their own

All these categories of recipients may in turn involve third parties, so that your data may also be made
accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by
other third parties (e.g. authorities, banks, etc.).

6. Transmission of personal data abroad

The personal data is processed in Switzerland and in the USA.
If a recipient is located in a country without adequate legal data protection, we contractually oblige the
recipient to comply with the applicable data protection (for this purpose, we use the revised standard
contractual clauses of the European Commission, which are available here: https://eur-, insofar as they are not already subject to a legally
recognised set of rules to ensure data protection and we cannot rely on an exception. An exception
may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public
interests or if the performance of a contract requires such disclosure, if you have consented or if it is a
matter of data that you have made generally accessible and you have not objected to its processing.

Please also note that data exchanged via the internet is often routed via third countries. Your data can
therefore end up abroad even if the sender and recipient are in the same country.

7. Note on data transfers to the USA
Some of the third-party service providers mentioned in this privacy policy are based in the USA. For the
sake of completeness, we would like to point out for users resident or domiciled in Switzerland that
there are surveillance measures in place in the USA by US authorities which generally allow the
storage of all personal data of all persons whose data has been transferred from Switzerland to the
USA. This is done without any differentiation, limitation or exception based on the objective pursued
and without any objective criterion that would make it possible to limit the access of the US authorities
to the data and their subsequent use to very specific, strictly limited purposes that are capable of
justifying the interference associated with both access to and use of this data. Furthermore, we would
like to point out that in the USA, data subjects from Switzerland do not have any legal remedies that
allow them to obtain access to the data concerning them and to obtain their correction or deletion, or
that there is no effective judicial legal protection against general access rights of US authorities. We
explicitly draw the attention of data subjects to this legal and factual situation so that they can make
an appropriately informed decision to consent to the use of their data.
We would like to point out to users who are resident in Switzerland that the USA does not have a
sufficient level of data protection from the point of view of Switzerland – among other things due to the
issues mentioned in this section. Insofar as we have explained in this data protection declaration that
recipients of data are based in the USA, we will ensure that your data is protected at an appropriate
level with our partners through contractual arrangements with these companies as well as any

additional appropriate guarantees required, which protect the rights of persons whose personal data is
transferred to a third country.
8. Your rights
You can object to data processing at any time. You also have the following rights:
Right of access: You have the right to request access to your personal data stored by us at any time
and free of charge if we are processing it. This gives you the opportunity to check what personal data
we are processing about you and that we are using it in accordance with applicable data protection
Right to rectification: You have the right to have inaccurate or incomplete personal data rectified and
to be informed of the rectification. In this case, we will inform the recipients of the data concerned of
the adjustments made, unless this is impossible or involves disproportionate effort.
Right to erasure: You have the right to have your personal data erased under certain circumstances. In
individual cases, the right to erasure may be excluded.
Right to restrict processing: Under certain circumstances, you have the right to have us restrict the
processing of your personal data.
Right to data transfer: In certain circumstances, you have the right to receive the personal data you
have provided to us free of charge in a machine-readable format.
Right of withdrawal: In principle, you have the right to withdraw your consent at any time with effect
for the future. Processing activities based on your consent in the past do not become unlawful as a
result of your revocation.

9. Retention period

We retain personal data for as long as it is needed for the purpose for which it was collected, or for a
period of time that we are obliged to retain it under applicable laws, regulations or contractual
agreements, as well as for as long as we have an overriding interest in retaining it. After that, the data
will be deleted.
Retention obligations that oblige us to retain data result from accounting regulations and tax
regulations. According to these regulations, business communication, concluded contracts and

accounting vouchers must be kept for up to 10 years. Likewise, certain data must be retained for up to
10 years after termination of the business relationship in accordance with money laundering

10. Data security
We take appropriate technical and organisational security measures to protect personal data from
unauthorised access and misuse. These include IT and network security solutions, access restrictions,
encryption of data carriers and transmissions, instructions, training and controls.
If third parties have access to our data, special measures are taken which are regulated in the order
processing contract.
11. Contact
If you have any questions about data protection, would like information, would like to object to data
processing or would like to have your data deleted, please contact us by sending an e-mail to or Please send your request by letter to the following address:
Delta1trader Technology AG
Grafenaustrasse 15
6300 Zug
12. Adaptation
This Privacy Policy does not form part of any contract with you. We may amend this privacy policy at
any time. The version published on is the current version.
Last updated: 1st of September 2023