Privacy and Cookie Policy

Data protection is important to Sutterlüty Investment Management GmbH, and we are committed to protecting your privacy. Furthermore, Sutterlüty Investment Management GmbH is committed to data protection legislation and transparency, and it is important to us that you understand how we manage and process your personal data. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this privacy policy.

In the remainder of this privacy policy, “we” refers to one or more members of Sutterlüty Investment Management GmbH, and “us” and “our” should be read accordingly.

Sutterlüty Investment Management GmbH is a company registered in Austria under company number 304358k and located at A-6863 Egg Hub 734. The General Data Protection Regulation (GDPR) means more control for you.

GDPR is solely concerned with how we manage and protect your data and does not affect the services we provide to you.

Personal Data – What is it and what do we do with it?

Personal data is information that directly or indirectly identifies you. Sutterlüty
Investment Management GmbH is committed to processing your personal data in compliance with EU data protection laws.

What type of information do we collect?

We may store certain personal data to help us provide the services set out in our contract with you. This includes personal identity data, financial information, information provided during interactions or correspondence, and sensitive personal data. It is important to note that we will only collect this with your contractual consent, unless we have a legal obligation or other lawful basis to do so.

We may also request information that requires your consent. In this case, we will specify the details of how the data will be used, obtain your consent, and how you can withdraw your consent. You have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact us at office@sutterluety-invest.at or by phone at +43 (0)5512 26533.

How we collect your data

We may collect your personal information both directly from you and from other parties.
This includes personal information from individuals applying for a joint product or service, such as a joint account, as well as from third parties,
such as banks, suppliers, financial advisors, tax authorities and intermediaries, credit reporting agencies, and fraud prevention agencies.

We may also collect the following information from Sutterlüty Investment Management GmbH
and the SUNARES website (www.sutterluety-invest.at and www.sunares.com):

• Contact information such as name, email address, and phone number from the contact form (optional)
• Website usage and behavior patterns using cookies

How we handle your data

The use of your data may include, but is not limited to, verifying your identity, providing products and services, managing your accounts and tax matters, or any contractual relationship with you, or conducting surveys. We will also use it to keep you informed about products and services we may offer you (e.g., SUNARES fact sheets). We may use the data collected through cookies to improve the usability of the aforementioned websites through statistical analysis.

To whom may your data be passed on?

We may share your information with a number of parties, including:

• Any employee of Sutterlüty Investment Management GmbH who supports our processing of personal data under this policy.
• With any custodian bank appointed on your behalf in respect of your account.
• Your IT administrator, trustee, who will act for you through Sutterlüty Investment Management GmbH.
• If your account is jointly held with other people, we may share account information (including your personal information) with the other account holders unless you tell us otherwise.
• With your financial advisor and his or her agents or appointed service providers.
• With our professional advisors (including auditors and lawyers) who are bound by confidentiality.
• Business partners, suppliers, affiliates, agents, and/or subcontractors for the performance of any agreements we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling information requests, receiving and sending communications, updating marketing lists, analyzing data, providing IT and other support services, or performing other tasks from time to time. These third parties will only use your information to the extent necessary to perform their functions.
• If we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or to enforce or apply our terms and conditions of supply and other agreements with you; or to protect the rights, property, or safety of Sutterlüty Investment Management GmbH, our customers, or others. This includes exchanging information with other companies and Organizations to protect against fraud and reduce credit risk.
• In the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets.

• We have never and will not sell your personal information to third parties.

Data protection outside the EU

We may process or store your personal data outside the EEA. In these cases, where the country may not have the same EEA laws, we ensure that your personal data is protected in accordance with applicable data protection laws.
Links to Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we have no control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide while visiting such websites, and these websites are not governed by this Privacy Policy. You should exercise caution and review the privacy policy applicable to the website in question.
Understanding Your Data Rights
You have the right to access, rectify, transfer to another service provider, and, if applicable, to delete, restrict, and object to the processing of your personal data. You also have the right to lodge a complaint with the Data Protection Authority of the Republic of Austria (the “DSB”). Details on how to complain to the dsb can be found on their website:
www.dsb.gv.at
If you would like further information or to exercise your rights, please contact us first:

The Data Protection Officer, Managing Director Peter Mennel, Sutterlüty Investment Management GmbH, A-6863
Egg Hub 734 Tel: +43 (0)5512 26533; Email: office@sutterluety-invest.at

Control your personal data

We will not sell, distribute, or rent your personal information to third parties unless we have your permission or are required to do so by law.
If you believe that any information we hold about you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
Security
We are committed to keeping your data secure. To prevent unauthorized access or disclosure, we have put in place appropriate physical, technical, and managerial procedures to safeguard and secure the information we collect. In addition, we limit access to your personal data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. In some cases, Sutterlüty Investment Management GmbH uses third parties to process personal data on our behalf, such as IT providers who store personal data in the cloud or access it when auditing the security of our network.

We promise you

We will take measures to protect your personal data from loss or theft, as well as from unauthorized access, disclosure, copying, use, or alteration. We will retain your personal data for a period of at least 7 years after the end of the contractual relationship or for as long as we are legally required to comply with our retention obligations, and no longer than necessary unless there is a legal reason for extended retention, such as any ongoing contractual liability for consulting services.

We may revise or amend our Privacy Policy from time to time to reflect changes in our business, the law, the markets, or the introduction of new technologies.

Cookie Policy
How we use cookies

A cookie is a small file that asks permission to be stored on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to determine which pages are being used. This helps us analyze web page traffic data and improve our website to tailor it to customer needs. We use this information solely for statistical purposes. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you.

Just browse

If you are just browsing our website, we use analytical or performance cookies. These help us understand how our visitors interact with our website. This allows us, for example, to improve how our website works and make it easier for users to find the information they need. These cookies do not collect any information that identifies you. All information collected is aggregated and thus anonymized. They are used solely to improve the performance of our website.
If you do not want this to happen, you can adjust your browser settings or visit www.aboutcookies.org to learn how to do this on different browsers. Only use our website if you agree to the installation of cookies. Please note that restricting cookies may affect the functionality of the website.

Contact

We won’t contact you if you just browse the site. We’ll only contact you if you request a callback or contact us.

The rest of this section contains a list of the performance cookies set by our website and a description of how they are used.

_utma – This Google Analytics cookie is used to count the number of visitors to our website and is updated with each page viewed. This cookie persists for 2 years unless deleted by the user.

_utmb – This Google Analytics cookie is used to establish and maintain a user session with this website. This cookie is updated to expire in 30 minutes, thus continuing a single session as long as user activity continues within 30-minute intervals.

_utmc – This Google Analytics cookie is a tracking code used to determine session state. It persists for the duration of the browser session unless deleted.

_utmz – This Google Analytics cookie stores the type of referral the visitor used to reach the website. It persists for six months unless deleted.

Google Analytics cookie. Used for custom variables in analytics.