LEGAL NOTICE

Director of publication: PRIME ADVISORS SWITZERLAND SA

Data Protection Statement

Version effective as of May 25, 2018

With this Data Protection Statement we, Prime Advisors SA, describe how we collect and further process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing.

It is possible that other data protection statements are applicable to specific circumstances. The term “personal data“ in this Data Protection Statement means any information that identifies, or could reasonably be used to identify any person.

If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and if such personal data is correct.

This Data Protection Statement is in line with the EU General Data Protection Regulation (GDPR).

Although the GDPR is a European Union (EU) regulation, it may be relevant for us.

The Swiss data protection legislation (FADP) is heavily influenced by EU law. In addition, companies outside

the European Union or the European Economic Area (EEA) must comply with the GDPR in certain cases.

Your information is collected and processed in accordance with Swiss data protection laws, in particular the Federal Act on Data Protection of June 19, 1992 (“FADP”) , replaced by the new Federal Act on Data Protection of September 25, 2020, which is expected to come into effect on September 1st, 2023.

1. Controller

The “controller” of data processing as described in this data protection statement (i.e. the responsible person) is Prime Advisors SA, unless we have informed you otherwise in certain cases.

You can notify us of any data protection-related concerns using the following contact details :

Or by post :

Prime Advisors (Suisse) SA

Rue du Marché 28
CH -1204 Geneva

Switzerland

Or by mail : info@primeadvisors.ch

DATA COLLECTION AND PROCESSING

4. Prime Advisors (Switzerland) SA is responsible for the processing of personal data provided by Users when using the Service.

5. Prime Advisors (Switzerland) SA guarantees that Users can use its Service anonymously, however, to receive a newsletter, it is necessary for them to provide data in the form of an e-mail address.

6. With regard to commercial communications, the provision of personal data is voluntary, but it may be necessary

to enter into and perform a contract (with respect to the personal data of individual companies).

PURPOSES AND LEGAL BASIS OF DATA PROCESSING

7. Prime Advisors (Suisse) SA processes the personal data of Service Users for the following purposes :

sending newsletters Prime Advisors (Suisse) SA sends a free newsletter and other messages containing information about Prime Advisors (Suisse) SA

The legal basis for the processing is Article 6(1)(a) GDPR (consent of the user to receive correspondence from Prime Advisors (Switzerland) SA).

b. ensure the security and functionality of the Service

Prime Advisors (Switzerland) SA processes personal data as necessary to ensure the security of Prime Advisors (Switzerland) SA's information processing and to operate the Service.

The legal basis for the processing is Article 6(1)(f) GDPR (satisfying the legitimate interest of Prime Advisors (Switzerland) SA, i.e. ensuring the functioning of the service).

vs. prosecution or protection against possible claims

In the event of possible claims against Users, or the need to protect against such claims, Prime Advisors (Switzerland) SA may process User data obtained through the Service.

The legal basis for the processing is Article 6(1)(f) GDPR (satisfaction of the legitimate interests of Prime Advisors (Switzerland) SA, i.e. the protection or pursuit of claims).

D. processing of personal data for commercial purposes Prime Advisors (Suisse) SA processes the personal data of the persons representing or designated as contacts for the subcontractors, as well as the data of other persons for the purposes of commercial communication.

The legal basis for the processing is: - Article 6, paragraph 1, point f) of the GDPR (satisfaction of the legitimate interest of Prime Advisors (Switzerland) SA, i.e. the ability to enter into or perform a contract with a contractor, protection against or pursuit of claims); - Article 6(1)(b) of the GDPR (conclusion and execution of a contract – with regard to the data of individual companies).

SOURCE OF PERSONAL DATA

8. In the case of commercial communications, if the data has not been provided by the data subject,

the source of the personal data may be other employees/contractors of the entity with which Prime Advisors (Suisse) SA is about to enter into or has entered into a contract, or the personal data may have been obtained from a publicly accessible register (for example, the National Court Register).

SHARING OF PERSONAL DATA

9. Access to user data may be granted to employees and authorized contractors of Prime Advisors (Suisse) SA, as well as entities whose services are used by Prime Advisors (Suisse) SA (for example, suppliers computer services). In such cases, Prime Advisors (Switzerland) SA has entered into agreements with such entities aimed at protecting Users' data against unauthorized access.

USER PRIVACY RIGHTS

10. The User has the following rights regarding their processed personal data by Prime Advisors (Suisse) SA

as part of the Service :

a. right of access to personal data

b. right of rectification of personal data

c. right to withdraw consent

d. right to erasure of personal data

e. right to limit the processing of personal data

f. right to request a transfer of personal data

g. right to object to the processing of personal data

11. To exercise any of these rights, Users may contact Prime Advisors (Suisse) SA by e-mail at : bassam.salame@primeadvisors.ch

12. If it turns out that a violation of the regulations on the protection of personal data has occurred,

the User has the right to file a complaint with the President of the Personal Data Protection Office.

DATA RETENTION PERIOD

13. Prime Advisors (Switzerland) SA only retains Users' personal data for as long as necessary to achieve the purposes for which the data was collected. After this period, the data is either deleted or anonymized in such a way as to make it impossible to establish the identity of a User.

14. Personal data may be retained for longer periods if such an obligation arises from the law or is necessary to defend or enforce the rights of Prime Advisors (Suisse) SA against Users.

15. Data processed on the basis of consent will be processed until the consent is withdrawn.

COOKIES

16. Cookies used on the Innova service can be managed through browser settings. For example: (i) on Internet Explorer, Cookies can be disabled via the following settings: Tools/Internet Options/Privacy/Block all cookies, (ii) on Firefox, Cookies can be disabled via the following settings: Tools/ Options/Privacy.

17. Blocking certain Cookies may impact the functionality of the Service.

18. The Prime Advisors (Suisse) SA Service uses several types of Cookies, including :

a.Session cookies are essential, enabling movement within the website and the use of its basic functions.

They are only used during the same session. Session Cookies are anonymous and are used to: optimize and improve the performance of the Service.

b. Persistent cookies Unlike session cookies, persistent cookies are reactivated each time a user returns to the same website and remain in the browser's subfolder until they expire (usually after 12 months). These cookies collect information about the use of the website, including data on the pages visited by users and potential errors.

c. Third-party cookies Third-party cookies allow the system to cooperate with external companies or services.

Third-party Cookies are used to :

- connect to social networking sites,

- provide research companies with data on site traffic.

LINKS TO OTHER SITES

19. This Policy only applies to the Service operated by Prime Advisors (Suisse) SA. Prime Advisors (Suisse) SA is not responsible for links placed on the Service that allow Users to navigate directly to sites that Prime Advisors (Suisse) SA does not administer. We encourage users to read the privacy notices available on linked sites.

CONTACT DETAILS AND RIGHT TO MAKE A COMPLAINT

20. Questions, conclusions and comments regarding the privacy policy and the handling of user data by

Prime Advisors (Switzerland) SA should be sent by email to the following email address :