Data Privacy Notice

1. Introduction

Atonra (“We”, “Us”, “Our”) is committed to protecting the privacy and security of your personal data. As a Swiss investment company, trust is at the core of our relationship with our clients and partners.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website atonra.ch or engage with our services, in compliance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).

2. DATA CONTROLLER

The entity responsible for processing your personal data is:

AtonRâ Partners SA
7, rue de la Croix d’Or
1204, Geneva, Switzerland
Email: info@atonra.ch

3. TYPES OF DATA WE COLLECT

Depending on your interaction with us, we may collect the following categories of personal data:

• Identification Data: Name, surname, email, phone number.
• Account Information: preferences and settings (through cookies).
• Technical Data: IP address, browser type, operating system, and activity logs.
• Communication data: messages or requests you send through the Platform or by email.
• Financial and investment data: portfolio configurations, stock screenings, risk preferences, and performance metrics.

We collect data directly from you, through integrated solutions such as APIs, from your interactions with our Platform, or from trusted third parties (e.g., analytics services).

4. WHY WE PROCESS YOUR DATA

We use your personal data for specific, defined purposes:

• To Provide Our Services: Managing client accounts, client support, portfolio construction and simulation, analytics, and reporting.
• Regulatory Compliance: Fulfilling our legal obligations under Swiss law, particularly financial market regulations.
• Marketing & Communication: Service updates or marketing (with your consent).
• Website Optimization: Analyzing traffic to improve our digital presence and security.

5. SHARING AND TRANSFER OF DATA

We do not sell your personal data to third parties for commercial purposes. However, we may share your data with:

• Service Providers: Third-party vendors (e.g., IT hosting, email services) who process data on our behalf, subject to confidentiality agreements.
• Affiliates: Entities associated with Atonra for management and administrative purposes.
• Authorities: Regulators or courts if required by law.

Your data is primarily processed in Switzerland or the European Union (EU). If data is transferred to other countries, we ensure appropriate safeguards are in place in accordance with Swiss law.

6. DATA RETENTION

We process and retain your personal data only as long as necessary to fulfill the purposes described above or as required by law (e.g., up to 10 years for financial data under Swiss regulation).

7. COOKIES AND ANALYTICS

This Website uses cookies to enhance user experience and analyze traffic. You can adjust your browser settings to refuse cookies, though this may limit your access to certain functionality.

8. YOUR RIGHTS

Under the Swiss Federal Act on Data Protection (FADP), you have the right to:

• Request access to the personal data we hold about you.
• Request the rectification of inaccurate data.
• Request the deletion of your data (subject to legal retention obligations).
• Request a processing of your Data based on our legitimate interest by explaining your particular reasons and specific circumstances on which your objection is based.
• Request to ask us to temporarily restrict our processing of your Data.
• Request to ask us to provide you in electronic form (to the extent technically feasible) the Data you have provided to us.
• Withdraw your consent for marketing communications at any time.

To exercise these rights, please contact us at: info@atonra.ch.

If you believe that our processing of your Data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the appropriate data protection authority.

The data protection authority for AtonRâ is the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Berne, Switzerland (https://www.edoeb.admin.ch).

9. THIRD PARTY LINKS

Our Platform may include links to third-party websites or services. We are not responsible for their content or privacy practices.

10. SECURITY

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or alteration. Access to your personal data is restricted to employees and agents who need it to fulfill their duties.

• Email Warning: Please note that standard email communication is not encrypted. We advise against sending sensitive financial information via unencrypted email.

11. CHANGES TO THIS POLICY

We reserve the right to amend this Privacy Policy at any time without prior notice. This Privacy Notice does not form part of any contract with you. The latest version published on this Website shall apply.