Last Updated: June 30, 2025

Data Protection Compliance

AltFunds Global AFG AG (“AltFunds Global,” “we,” or “us”) is committed to protecting personal data under the Swiss Federal Act on Data Protection (nFADP) and, where applicable, the EU General Data Protection Regulation (GDPR).

While we are not licensed or supervised by FINMA, we maintain data protection and confidentiality standards expected of firms handling sensitive client information.

1. Who We Are

Data Controller:

AltFunds Global AFG AG

Chamerstrasse 176

6300 Zug, Switzerland

Email: legal@altfundsglobal.com

2. Scope of This Policy

This policy applies to:

• Visitors to our website: www.altfundsglobal.com
• Clients and prospective clients who contact or engage with us
• Users of our chatbot, webinars, forms, or consultation services

3. What Personal Data We Process

Category	Examples	Purpose
Identification Data	Name, nationality, date of birth, passport or ID copies	KYC/AML screening, onboarding
Contact Information	Email, telephone, address	Communication, notifications
Financial/Project Data	Proof of funds, business plans	Transaction suitability review
Technical Metadata	IP address, browser type	Website performance, compliance
Communication Records	Emails, meeting notes, chat transcripts	Legal and service records

We do not collect sensitive personal data unless required for compliance and with explicit consent.

4. Why We Process Your Data

• To fulfil contractual or pre-contractual obligations
• To conduct KYC/AML reviews and ensure eligibility
• To comply with Swiss legal and regulatory requirements
• To provide advisory and consulting services
• To improve service quality, analytics, and risk mitigation
• To respond to legal or regulatory requests

We do not engage in automated decision-making with legal or material consequences without human involvement.

5. Legal Basis for Processing

• Art. 6(1)(b) GDPR – Contract necessity
• Art. 6(1)(c) GDPR – Legal obligation (e.g., AML)
• Art. 6(1)(f) GDPR – Legitimate interest
• Art. 6(6) and Art. 31(2)(a) nFADP – Consent or overriding interest

Where required, consent is obtained explicitly.

6. Retention of Personal Data

• KYC/AML files – Retained for 10 years
• Communication records – Up to 5 years
• Website/session data – Up to 12 months (anonymized thereafter)

Once data is no longer required, it is securely deleted or anonymized.

7. Data Sharing and Confidentiality

We do not sell, rent, or trade personal data. Data may be shared with:

• Legal or risk advisors
• Technology providers
• Regulatory authorities as required
• Third-party institutions involved in authorized transactions

All third parties are bound to confidentiality obligations.

8. Cross-Border Data Transfers

We ensure data transferred outside Switzerland or the EU/EEA is protected through:

• FDPIC-approved jurisdictions
• Standard Contractual Clauses (SCCs)
• Explicit consent where required

9. Your Rights

You may:

• Access your data
• Request corrections or deletions
• Limit or object to processing
• File a complaint with the FDPIC

Limitations: Once data is shared with regulated entities or authorities, we may not be able to modify or delete it. These entities act as independent data controllers. We will inform you and cooperate where possible.

To exercise rights, contact us at legal@altfundsglobal.com. Response time is typically within 30 days.

10. Cookies and Website Tracking

We use cookies and analytics tools for:

• Essential website functionality
• Usage analytics (e.g., Google Analytics)
• Session management and user preferences

You may control cookies through your browser. See our Cookie Policy for more.

11. Data Security

We implement the following security measures:

• SSL encryption
• Access restrictions and audit trails
• Encrypted cloud storage
• Role-based data access

12. Changes to This Notice

This policy may be updated for legal or operational reasons. The latest version is published at www.altfundsglobal.com/legal. Significant updates will be announced via the website or direct communication where necessary.

Contact Us

Legal & Compliance Department

AltFunds Global AFG AG

Chamerstrasse 176

6300 Zug, Switzerland

Email: legal@altfundsglobal.com