Privacy Notice

This Privacy Notice (“Notice”) explains how the entities within the Earl Group (defined below) collect, use, disclose, and retain your personal data (including personal data that you provide to us about other persons) (together, “Personal Data”). It also explains your privacy rights and how you can exercise them.

In this Notice, the “Earl Group”, “we”, “us”, and “our” includes Earl Group Holdings Limited, Earl Fiduciary AG, Earl Capital AG, Earl Trust (Cyprus) Limited, Earl Management (Netherlands) B.V., and all subsidiaries of these entities, including companies acting as nominee companies and/or corporate directors.

The entity within the Earl Group with whom you conduct business is the data controller of your Personal Data for the purposes of the EU General Data Protection Regulation 2016/679 (“GDPR”), the Swiss Federal Act on Data Protection (“FADP”), and any locally applicable data protection laws and regulations.

If you have any questions regarding our processing of your Personal Data or would like to exercise your privacy rights, please contact us.

Table of Contents

  1. Who is responsible for the data processing and who can I contact in this regard?
  2. Why does the Earl Group hold Personal Data?
  3. Whose Personal Data do we hold?
  4. How do we collect Personal Data?
  5. What types of Personal Data do we collect?
  6. Use of Personal Data
  7. Statutory and legal requirements
  8. How do we protect your Personal Data?
  9. Storage and sharing of Personal Data
  10. Are you obliged to provide Personal Data?
  11. Is automated decision-making used?
  12. Will your Personal Data be transferred to a third country?
  13. Revocation of your consent to data processing
  14. How long will we keep Personal Data?
  15. Your rights
  16. Exercising your rights
  17. Changes to your data
  18. Updates to this notice

1. Who is responsible for the data processing and who can I contact in this regard?

Controller:
Earl Group
General Wille-Strasse 10
P.O. Box 1688
CH-8002 Zurich
Switzerland		 Our internal data protection representative may be contacted at:
Earl Group
Data Protection Representative
General Wille-Strasse 10
P.O. Box 1688
CH-8002 Zurich
Switzerland
Tel: +41 (0)44 208 18 18
Fax: +41 (0)44 208 18 28
Email: info@earlfiduciary.com

2. Why does the Earl Group hold Personal Data?

We hold Personal Data to meet contractual obligations and provide services as a trust and corporate service provider, to comply with legal, anti-money laundering, and regulatory requirements, to administer and manage our business and associated relationships, and to fulfill obligations arising from employment contracts.

3. Whose Personal Data do we hold?

We hold the Personal Data of natural persons as follows:

  • Clients, directly or indirectly, of the Earl Group. Such persons may include settlors, trustees, protectors, beneficiaries, directors, officers, shareholders, controllers, and beneficial owners of entities to which we provide services.
  • Persons inquiring about our services, whether or not we are or will be engaged to act.
  • Suppliers of goods and services to us and to entities to which we provide services.
  • Applicants for a role with us, interns, contractors, and employees of the Earl Group.

4. How do we collect Personal Data?

“Personal data” refers to any information that can identify you directly or indirectly, or provide insights into your personal or professional circumstances—such as your name, address, telephone number, date of birth, or email address. Data that cannot be linked to your identity, such as anonymized information, is not considered personal data.

You will voluntarily provide most of your Personal Data directly to us. We will also obtain Personal Data from third parties. The main sources and occurrences are as follows:

  • Information and documentation you or your professional advisers or introducers provide at the point of initial enquiry and subsequent follow-up.
  • When we complete client take-on procedures.
  • When you, your professional advisers, intermediaries, or other suppliers or service providers communicate with us by whatever means, resulting in us recording and storing such communication.
  • From other entities within the Earl Group.
  • From publicly available sources such as the internet and online information and checking services.

Sometimes the provision of your Personal Data to us by third parties will be unsolicited and/or provided in confidence (for example, reports made to us by regulators and other persons), and in this event, we will be unable to notify you. In all cases, we shall take such steps as necessary to ensure that Personal Data is obtained and used in a fair and lawful way.

5. What types of Personal Data do we collect?

Core Categories of Personal Data

The types of Personal Data we collect will vary depending upon the specific relationship that we have with you. We will hold personal identification and contact data with related verification documentation. In addition to the information you provide directly, we may collect and process a range of information including but not limited to:

  • Information relating to your financial circumstances including banking, investments, source of funds, and source of wealth;
  • Information relating to your employment history, business activities, and taxation status including tax, national insurance, and other identification numbers;
  • Certain details about your family and your personal circumstances;
  • Information obtained from publicly accessible sources (such as debt registers, land registries, commercial registers, press, or the internet);
  • Information from public registers or obtained in connection with administrative or court proceedings;
  • Information about your professional role and activities (for example, to conclude and carry out contracts with your employer);
  • Information contained in correspondence or discussions with third parties;
  • Information provided by individuals connected with you (such as family members, consultants, or legal representatives) for the purpose of concluding or processing contracts with you or involving you (e.g., references, delivery addresses, or powers of attorney);
  • Information collected to meet legal and regulatory obligations (including anti-money laundering requirements) together with bank account details;
  • Information relating to insurance or other business partners where necessary to order or provide services (such as payment records or previous transactions);
  • Information about you identified in the media or on the internet where relevant (for example, in relation to job applications).

Personal Data Collected for Recruitment Purposes

If you apply for a role with the Earl Group, we may also collect and process Personal Data relevant to your application. This may include:

  • Your curriculum vitae (CV) and cover letter;
  • Education, qualifications, and professional memberships;
  • Employment history and references;
  • Interview notes and assessment results;
  • Any other information you choose to provide as part of your application.

6. Use of Personal Data

We process personal data in accordance with applicable data protection laws. This includes obtaining, recording, or holding the data, or carrying out any operation or set of operations on the data including organizing, copying, analyzing, amending, retrieving, storing, disclosing, transferring, retaining, archiving, anonymizing, erasing, or destroying it.

7. Statutory and legal requirements

We are subject to a range of statutory and legal requirements that oblige us to process your data. The legal basis upon which we process Personal Data is that we have either obtained your consent to do so or (more commonly) where it is necessary:

  • To perform our contract with you or to take steps at your request to enter into the contract;
  • For compliance with a legal obligation;
  • For the purposes of our or another party’s legitimate interests.

The purposes for which we process Personal Data (“Permitted Purposes”) are for the proper governance, management, and administration of the Earl Group and for the proper discharge of our responsibilities to clients, staff, suppliers, and other third parties and to comply with all applicable legal, regulatory, and anti-money laundering obligations.

8. How do we protect your Personal Data?

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access and misuse. These include access restrictions, security technologies like encryption and firewalls, regular data backups, employee training on data protection, and oversight of third-party providers to ensure compliance with data protection standards.

9. Storage and sharing of Personal Data

We hold Personal Data in organized paper files and electronically in various document formats including in email and database form on secure servers and networked storage devices securely backed up.

We will, at times, need to share Personal Data within the Earl Group and with select third parties, such as:

Persons related to you: Your agents, professional advisers, counterparties, beneficiaries, family members, trustees, directors, banks, investment managers, etc., where you ask us to, or as otherwise necessary for the Permitted Purposes.

Persons related to us: Our agents, consultants, and other professionals including within the Earl Group. Suppliers and external parties who assist us with legal, administrative, financial, operational, and other services and who may have access to certain of your Personal Data as part of their role. These will include, for example, IT and backup service providers, banks, auditors, brokers, insurers, lawyers, accountants, and tax advisers.

We will also share Personal Data in situations where disclosure is required by applicable rules and laws or by any court, tribunal, law enforcement, regulatory, public, or quasi-governmental authority or department with appropriate authority.

We will also make disclosures of Personal Data as required to fulfill the obligations of the Earl Group under all applicable national and international tax compliance and exchange of information agreements including those relating to disclosure of controllers and beneficial owners.

10. Are you obliged to provide Personal Data?

You are only required to provide the personal data necessary to establish, manage, or terminate a business relationship, or data that we are legally obligated to collect. Without this information, we may not be able to enter into the requested relationship.

In the context of recruitment, if you do not provide the Personal Data necessary to assess your suitability for employment or to meet the requirements of an employment contract, we may be unable to process your application or make a hiring decision.

11. Is automated decision-making used?

We do not use automated decision-making or profiling. Should this change in a specific case, we will inform you as required by law.

12. Will your Personal Data be transferred to a third country?

Your personal data may be transferred within the Earl Group and to third parties, both within Switzerland and internationally. This includes countries that may not offer an equivalent level of data protection as required by the revised Swiss Federal Act on Data Protection (FADP), which came into force on September 1, 2023.

In such cases, we ensure that appropriate safeguards are in place—such as standard contractual clauses or other legally recognized mechanisms—to protect your personal data. Transfers to these countries occur only when necessary to fulfill contractual obligations, comply with legal requirements, or based on your explicit consent.

In exceptional cases where such safeguards are not available, data transfers will only take place if the specific legal requirements set out under the FADP are met. As part of our ongoing compliance, we have reviewed and updated all existing standard contractual clauses with our partners in third countries to ensure alignment with the revised FADP. Information about the applicable safeguards is available upon request.

13. Revocation of your consent to data processing

A wide range of data processing transactions are possible only subject to your express consent. You have the right to revoke any consent you have previously given at any time.

14. How long will we keep Personal Data?

We will keep Personal Data in an accessible form which can identify a natural person only for as long as we need to for the Permitted Purposes. Applicable laws generally require us to retain Personal Data for a minimum period of 10 years.

After the expiry of the retention period, we may dispose of files including associated Personal Data without further reference to you.

15. Your rights

Under the EU General Data Protection Regulation (GDPR) and the revised Swiss Federal Act on Data Protection (FADP), you, as a data subject, may be entitled to certain rights concerning your personal data. These include:

  • Right to Information: You have the right to be informed about the collection of your personal data, including the purpose of processing, categories of data, and recipients.
  • Right of Access: You can request information about whether your personal data is being processed and obtain a copy of the data.
  • Right to Rectification: You can request the correction of inaccurate or incomplete personal data.
  • Right to Erasure: You may request that your personal data be deleted, particularly if it is no longer necessary or was processed unlawfully.
  • Right to Object: You may object to the processing of your personal data, especially in cases of profiling or direct marketing.
  • Right to Data Portability: You may request copies of the information that we hold on you to take away.
  • Right to Restriction of Processing: You may request that we temporarily or permanently limit the processing of your personal data under certain circumstances—for example, if you contest its accuracy or object to its processing.
  • Right to Lodge a Complaint: You can file a complaint with the Federal Data Protection and Information Commissioner (FDPIC) if you believe your data protection rights have been violated.

16. Exercising your rights

To exercise your rights, please email info@earlfiduciary.com.

You can view the full text of the GDPR and the FADP including all your rights thereunder by visiting https://gdpr-info.eu/ and https://www.fedlex.admin.ch/eli/cc/1993/1945_1945_1945/de.

17. Changes to your data

We are committed to keeping your data accurate and up to date. Therefore, if your data changes, please inform us of the change as soon as possible.

18. Updates to this notice

This Notice was updated in August 2025. We reserve the right to amend it from time to time. Any amendment or update to this Notice we will make available to you here: https://www.earlgroupco.com/earlfiduciary/privacy/. Please visit the Company’s website frequently to understand the current Notice, as the terms of this Notice are closely related to you.