Legal Notice

Information and conditions of use (“Conditions of Use”)

Privatbank IHAG Zürich AG (hereinafter referred to as the “Bank”) makes its website (i.e. the content and web pages accessible at the www.pbihag.ch web address (hereinafter referred to as the “Website”)) available to you under the terms of the following Conditions of Use. The Bank provides the content of the Website for personal information purposes only. By accessing the Website, you confirm that you agree to be bound by the following Conditions of Use. If you do not agree to be bound by the Conditions of Use, you are obliged to refrain entirely from accessing the Bank’s Website.

All persons who are subject to any form of legal restriction (e.g. owing to their nationality, place of residence or for other reasons) are not permitted to access the Website. This applies in particular to persons and entities domiciled or headquartered in the USA, Canada and the United Kingdom.

At any time and without notice, the present Conditions of Use may be amended and the use of the Website may be restricted. For this reason, you are required to check the present Conditions of Use every time you access the Website.

No offer / no advice. The content of the Website is provided for information only and does not constitute recommendations, incitements or offers to enter into any form of contract. In particular, the Website does not contain any investment, legal or tax advice. The Bank recommends that you consult your client advisor or another qualified professional for further information. On no account should investment decisions be made on the basis of the content of this Website.

The financial instruments, products and services referred to on this Website may not be available to or suitable for persons in certain countries.

Beyond these Conditions of Use, you cannot enter into a contractual relationship with the Bank, or take any legally binding action in relation to an existing contractual relationship with the Bank, simply by establishing contact with the Bank via the Website (specifically by completing the contact form). In particular, the Website cannot be used to issue any orders or to convey any binding communications.

Exclusion of warranty. The Bank makes no assurances and assumes no guarantee or responsibility whatsoever for the correctness, quality, appropriateness, completeness, up-to-date nature or presence of the Website content. Any and all guarantees are expressly excluded.

Specifically, the past performance of an investment instrument may not be interpreted as any indication of future returns. The Bank offers no guarantee of the increase in or preservation of the value of an investment instrument, or of the related distributions.

Similarly, no guarantee whatsoever is offered in respect of the technical availability, suitability or fault-free nature (including faulty functions such as viruses or changes resulting from interference by third parties (“hacking”)) of the Website.

Exclusion of liability. Furthermore, the Bank accepts no liability whatsoever for direct or indirect loss or damage of any nature associated with the use of this Website or the information or opinions it contains.

Data protection and banking confidentiality. The Bank treats in confidence all data that is transmitted to it in connection with your use of the Website. It does not pass such data on to third parties. This includes information about the computer systems used by you and the personal data that you may disclose, for example when completing the “Contact” form.

Your accessing the Website involves data being transmitted unchecked across international boundaries via the internet, i.e. a public network that is accessible to all. You acknowledge that, under certain circumstances, all of the associated data, including that which falls under Swiss banking confidentiality regulations, may be viewed without restriction and may also be used in some manner. As such, compliance with Swiss banking confidentiality regulations cannot be guaranteed, and conclusions may be drawn about any existing or future bank-client relationships.

Users are reminded that Swiss law (e.g. data protection legislation) applies on Swiss territory alone. Consequently, data that is transmitted abroad ceases to enjoy protection under Swiss law.

Intellectual property rights. The Website, including all content and its design, is protected by copyright and may be viewed for personal and private purposes. Where the Website uses protected marks and/or names (e.g. registered trademarks), you are permitted to view them within the terms of these Conditions of Use. You are not granted any further licence or usage rights to those protected marks and/or names. The Website and its content may not be used in any other way. Specifically, the reproduction, transmission, amendment, linking or use for a public or commercial purposes of the Website’s content or software, or any of the marks, logos and other elements it contains, are prohibited.

Links to other websites. The Bank may make links to third-party websites available on its Website. The Bank has no control over this content, neither does it monitor it. For this reason, the Bank accepts no responsibility whatsoever for third-party websites, and you acknowledge that you access websites beyond the present Website at your own risk.

Applicable law and place of jurisdiction. Access to the Website, as well as the Conditions of Use, are subject to Swiss law. Notwithstanding any imperative provisions in law, Zurich is the sole place of jurisdiction for any and all disputes arising in connection with access to the Website and with the Conditions of Use.

The present Conditions of use are dated Februar 2021.

Object of FinSA
The Financial Services Act (FinSA), which entered into force on 1 January 2020, is intended to

• protect clients more effectively by making financial service providers meet stricter information and documentation requirements when providing financial services or offering financial instruments,
• create a level playing field for all financial services providers,
• enhance the reputation and competitiveness of the Swiss financial sector.

Information and documentation requirements
Privatbank IHAG Zürich AG (the “Bank”) fulfils its specific individual FinSA information and documentation requirements directly while it is providing its financial services. This information sheet satisfies the Bank’s obligation to provide general information.
Client segmentation
Under FinSA, all bank clients must be classified as a private client, a professional client, or an institutional client. This approach to segmentation is based on the client’s financial circumstances, and their knowledge and experience of financial instruments. Investors enjoy a greater or lesser degree of protection depending on the client segment to which they belong.
Information on risk
Before using a financial service or issuing securities orders to the Bank, it is important that the client educate themselves on the associated opportunities and risks, and that they understand them. The “Risks Involved in Trading Financial Instruments” booklet issued by the Swiss Bankers Association, which the Bank provides to its clients, contains key information on the various types of financial instruments and financial services, and the risks attached to them. Clients may contact their client advisor at any time if they have any questions. The booklet mentioned above can also be downloaded from the Swiss Bankers Association website:
Information on products
In addition to the general information contained in the “Risks Involved in Trading Financial Instruments” booklet, individual documentation – such as key investor information documents (KIIDs) and prospectuses – is available for a whole range of financial instruments. If these are available from the originator of the financial instrument concerned, the Bank will provide them to the client. The client may also obtain this documentation at any time from their client advisor.
Under FinSA, where a financial services provider personally recommends financial instruments to clients in the private clients segment, they must also supply the relevant key investor information documents (KIIDs). A KIID describes the features of the financial instrument, as well as its risks and costs. It also permits a comparison of different financial instruments.
Information on costs
The Bank and, in most cases, third parties, charge costs and fees for providing financial services. It is important to distinguish here between direct costs and fees that are debited straight from the client’s account, and indirect costs that are charged against the return generated by the financial instrument.
Clients can contact their client advisor at any time to request detailed information on the Bank’s current fee rates, and on the actual costs and fees incurred with the financial transactions they have made.
Conflicts of interest
The bank pursues business activities in a variety of areas, which may result in conflicts of interest. The Bank has appropriate precautions in place to prevent such conflicts or, if there is the risk of a conflict of interest, to ensure that the client is never at a disadvantage. Examples here include separating departments and management processes, and waiving incentives to sell certain financial instruments. If disadvantage to the client cannot be ruled out, the Bank discloses the conflict of interest and obtains the consent of the client in question. Further information on how the Bank handles conflicts of interest is available to clients on request.
Contacting the Bank and the banking supervisory authority
As a financial institution under the Swiss Banking Act, Privatbank IHAG Zürich AG falls under the supervision of the Swiss Financial Market Supervisory Authority (FINMA).
Contact details:
Privatbank IHAG Zürich AG
Bleicherweg 18
8022 Zürich
+41 44 205 11 11
Contact form
info@pbihag.ch
Swiss Financial Market Supervisory Authority FINMA
Laupenstrasse 27
3003 Bern
+41 31 327 91 00
Contacts on FINMA website
Ombudsman
The Bank makes every effort to resolve all complaints to the satisfaction of the client. Clients may contact their client advisor, the advisor’s line manager, or the Bank’s Legal Services department at any time with their concerns. Clients also have the option of taking their case to the competent ombudsman’s office, which provides free, unbiased information and referral services. However, it will generally wait until it has received the client’s complaint in writing before requesting a response from the bank.
The competent authority for Privatbank IHAG Zürich AG is the Swiss Banking Ombudsman.
Contact details:
Schweizerischer Bankenombudsman
Bahnhofplatz 9
P.O.Box
8021 Zürich
www.bankingombudsman.ch

1. General information
1.1. Company, address and contact details of bank
Privatbank IHAG Zürich AG
Bleicherweg 18
P.O. Box
CH – 8022 Zurich
Phone: +41 44 205 11 11
E-mail: info@pbihag.ch

1.2. Authorisations
The Bank is licensed as a bank by the Swiss Financial Market Supervisory Authority. The banking licence enables the Bank to provide all the usual banking services, including the trading and safekeeping of securities.

1.3. Company identification numbers
UID/VAT number: www.uid.admin.ch; CH-ID no.: CH-020-3912706-8; LEI: 529900K5U2R8FX5LN839

1.4. Relevant supervisory authority
As a banking institution according to the Swiss Banking Act, the Bank is supervised by the Swiss Financial Market Supervisory Authority (FINMA).

Swiss Financial Market Supervisory Authority FINMA
Laupenstrasse 27
CH – 3003 Bern
Phone: +41 31 327 91 00
Fax: +41 31 327 91 01
E-mail: info@finma.ch

2. Language for information and contracts/Currency
German is the language used for the contractual relationship and for communicating with Clients. Accounts are operated in CHF, unless a different currency is explicitly agreed (e.g. for a foreign currency account).

3. Means of communication
In principle the Bank and the Client communicate with each other by means of the usual channels individually agreed with the Client depending on the service; general contact details are given in section 1.1. The same applies to order placement. If the Bank cannot be reached via one particular means of communication (e.g. online services, mobile applications or telephone) for order placement, the Client is required to switch to another of these means of communication.

The Bank is entitled, but not obliged, to send documents in electronic form (e.g. execution confirmations, account statements etc.) to the Client, the latter’s representatives or other third parties.

4. Client category
When providing securities services and ancillary services, the Bank generally treats all Clients as retail clients within the meaning of the Securities Trading Act (or any other national implementation of MiFID II), unless different arrangements have been agreed with the Client.

5. Information on financial instruments
5.1. Risk information
Before using a financial service or issuing securities orders to the Bank, it is important that Clients inform themselves about the associated opportunities and risks and ensure they understand them. The Bank provides its Clients with a copy of the booklet “Risks Involved in Trading Financial Instruments” published by the Swiss Bankers Association, which contains the key information about the different types of financial instruments and financial services and the associated risks. Clients may consult their relationship manager at any time if they have questions. The above-mentioned booklet may also be downloaded from the website of the Swiss Bankers Association:

https://www.swissbanking.ch/_Resources/Persistent/6/1/3/c/613cf17d17e7628788b2135114e5d399e822778d/SBA_Risks_Involved_in_Trading_Financial_Instruments_2019_EN.pdf

5.2. Product information
In addition to the general information in the booklet “Risks Involved in Trading Financial Instruments”, relevant information documents (key information documents, prospectuses) are available for numerous financial instruments. Where these are supplied by the producer of the financial instrument in question, the Bank makes them available to Clients. Clients can also order them from their relationship manager at any time.

According to FinSA, the financial services provider must make relevant key information documents (KIDs) available when individually recommending financial instruments to clients in the retail clients segment. A KID contains details of the features of the financial instrument as well as its risks and costs. It also enables different financial instruments to be compared.

6. Information on costs and compensation
The provision of financial services incurs costs and fees not only from the Bank but also as a rule from third parties and for the product. A distinction should be made between direct costs and fees that are charged to the Client’s account, and indirect costs that are deducted from the return on a financial instrument.

In connection with assets held in the advisory portfolio, the Bank may receive compensation from third parties (such as sales commission, retrocessions, remuneration, fees, commission including trailer fees, reimbursements, discounts, reductions or other benefits) and may retain this to the extent permitted by law. The bandwidths for any such compensation are shown in the table below:

The bandwidths for any compensation, based on the entire portfolio, that the Bank could receive from third parties is 0 – 1.5% p.a., whereas the maximum amount could be reached only if the entire portfolio were invested in investment funds and structured products and if the Bank received compensations for all these financial instruments.

7. Information on safekeeping
The safekeeping of financial instruments is conducted in accordance with the Bank’s General Terms and Conditions and Safe Custody Regulations. Domestic securities are held at SIX SIS AG, provided that they are approved for collective custody. Foreign financial instruments are normally kept in the home country of the security in question, or in some cases in the country of purchase. On request, the Bank will be happy to inform Custody Clients of the country in which the Client’s financial instruments are being held. Clients have ownership of the financial instruments that the Bank has in safekeeping for them, or they enjoy the most similar legal status usual in the country of storage (securities crediting). When securities are in safekeeping in a third country and Client portfolios are not kept segregated from the Bank’s proprietary positions in the country in question, there could be a risk that Clients’ financial instruments may be seized by execution creditors if the third party becomes bankrupt.

8. Information on investment advice and asset management
8.1. Information on investment advice
The Bank does not provide independent fee-based investment advice. Investment advice entails constraints on the financial instruments and issuers that the Bank can consider when offering the investment advice. For all asset classes, the Bank makes a pre-selection which may be based on a restricted analysis of various types of financial instruments. This may, for example, mean that financial instruments are considered only if they are from issuers that have a sales agreement with the Bank. The range of financial instruments may be restricted to financial instruments from providers or issuers that have close links with the Bank.

When providing investment advice, the Bank may retain as part of its compensation any inducements/fees it receives.

The Bank does not conduct regular assessments of the suitability of the financial instruments recommended; any comments the Bank may make are not binding.

8.2. Information on asset management
In its asset management activity, the Bank typically uses only financial instruments for which no inducements/compensation are paid. However, the Bank hands over to the Client any non-minor inducements and compensation it may, exceptionally, receive in connection with its asset management activity.

9.   Notifications regarding services performed
The type, frequency and timing of notifications regarding services performed are specified in the General Terms and Conditions or the provisions of the relevant individual contract and may also be obtained from your contact partner.

10. ESG/Sustainability
When selecting financial instruments as part of its investment advisory or asset management activities, the Bank takes various factors into account, including sustainability. The Bank shall observe the ESG and sustainability provisions applicable in Switzerland. However, the Bank does not observe the detailed provisions of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector, since this regulation does not have to be implemented in Switzerland.

11. Conflicts of interest
The various business activities conducted by the Bank may result in conflicts of interest. The Bank takes appropriate measures (such as keeping departments and management processes separate and renouncing pecuniary inducements) in order to avoid such conflicts and to ensure that the Client is not disadvantaged by potential conflicts of interest. If it is impossible to exclude a disadvantage to the Client, the Bank discloses the conflict of interest and obtains the consent of the affected Client (please refer for example to the above-mentioned information on the retention of compensation). On request, the Bank will provide the Client with further information about how it handles conflicts of interest.

In relation to an asset management or investment advisory mandate, the Bank may, for example, recommend investment instruments to other clients at the same time, or buy or sell them on its own account. Furthermore, investments in instruments that are issued, advised, managed, developed and/or controlled by the Bank may be purchased or recommended. The Bank’s own products are also publicised on the Bank’s website. The Client will be provided with a more detailed description of the Bank’s conflict of interest policy on request. Clients may also seek further information from their contact partner at the Bank at any time.

12. Trading and execution venues
The trading and execution venues offered by the Bank comply with the Bank’s Best Execution Policy, which is made available to the Client free of charge on request and can be accessed online at https://www.pbihag.ch/en/.

The Bank’s Best Execution Policy permits orders to be executed outside trading venues. Unless otherwise arranged under a different agreement, the conclusion of the present contractual relationship means that the Client accepts the possibility of this type of order execution by the Bank or by appointed brokers.

13. Recording of electronic communications
The Bank is entitled, and in some circumstances obliged, to record electronic communications. Subject to the applicable legal provisions, the Client may object to telephone conversations with the Bank being recorded, in which case it may not be possible for the Bank to provide certain services. The Bank will usually retain recordings of telephone conversations and electronic communications for a minimum of five years. The Client may require the Bank to release recordings of telephone conversations and other electronic communications with the Bank.

14. Tied agents
The Bank does not use tied agents.

15. Information on depositor protection
Cash deposits held in the account are covered by the Swiss deposit insurance scheme according to the applicable regulations. Further information about the Swiss deposit insurance scheme may be found at https://www.esisuisse.ch and may be obtained from your contact partner on request.

16. Complaints
The Bank has a procedure for dealing with client complaints reasonably and rapidly. Clients can submit a complaint irrespective of whether they are classified as retail or professional clients. Clients may contact their relationship manager, that person’s line manager, or the Bank’s legal department at any time if they have concerns.

17. Ombudsman
The Bank makes every effort to resolve all client complaints to the satisfaction of its Clients. Clients may contact their relationship manager, that person’s line manager or the Bank’s legal department at any time if they have concerns. Clients do, however, also have the option of taking their concerns to the relevant ombudsman. The ombudsman can provide clients with information and mediation, impartially and free of charge; as a rule, it requests a statement from the Bank once it has received a written complaint from a client.

The Swiss Banking Ombudsman is the relevant ombudsman for clients of Privatbank IHAG Zürich AG.

Contact details:
Swiss Banking Ombudsman
Bahnhofplatz 9
P.O. Box
8021 Zurich
http://www.bankingombudsman.ch

The possibility of bringing a case before an ordinary court remains unaffected.

The new global standard for the automatic exchange of information (AEOI) is designed to prevent cross-border tax evasion. To date, almost 100 countries, including all major financial centres and Switzerland, have declared their intention to adopt the standard.

To date, Switzerland has signed agreements with various partner states to introduce the automatic exchange of information.

A list of these partner states, as well as more detailed information on AEOI, can be found on the website of the State Secretariat for International Financial Matters SIF.

Privacy Policy in accordance with the Data Protection Act

This Privacy Policy provides information on how Privatbank IHAG Zürich AG (‘we’) handles personal data (referred to below as ‘data’).

You accessing our website www.pbihag.ch (referred to below as ‘the Website’) involves data being transmitted unchecked across international boundaries via the internet, i.e. a public network that is accessible to all. You acknowledge that, under certain circumstances, all of this data, including that which falls under Swiss bank-client confidentiality regulations, may be viewed without restriction and may also be used in some manner. As such, compliance with Swiss bank-client confidentiality regulations cannot be guaranteed. We should like to point out that Swiss law (e.g. bank-client confidentiality regulations and data protection legislation) applies on Swiss territory alone. Consequently, data that is transmitted abroad ceases to enjoy protection under Swiss law. The bank does not accept any liability whatsoever in this respect.

This Privacy Policy applies to all data that we collect from you via our website, apps (e.g. e-banking), or via social media. By browsing our Website or transferring data to us by other means, you declare that you agree with this Privacy Policy and the processing of data it describes. The processing of data entails the collection, recording, organisation, sorting, storage, amendment, modification, reading, retrieval and usage of data as well as disclosure by transmission, dissemination or any other form of delivery and the comparison, linkage, compression, deletion or destruction of data. If you do not agree, please do not use our Website.

This Privacy Policy is dated September 2023. We recommend that you check this Privacy Policy regularly for updates. Please note the data protection provisions in the bank’s current General Terms and Conditions.

What is personal data?

‘Personal data’ refers to all information that permits a specific natural person (‘person’) to be identified, or that relates to an identified or identifiable person. This may be information that identifies a person directly (such as first name and surname, address or e-mail address, or account or contract number), information that identifies a person when combined with other information, and/or information about an identifiable person (such as location data, occupation, or income). All such data which identifies you or which recognisably relates to you, whether alone or in combination with other information, is treated as personal data under this Privacy Policy.

What data do we collect about you?

The data that we may collect from you when you browse our Website typically includes the following:

• Data you actively transmit to us when browsing the Website. When doing so, you can:
  • Register for our publications (e.g. Monthly CIO letter and Perspectives). By doing so, you give us permission to send you the publications you have requested by e-mail or post, and to process your data. To this end, we must have the following information:
    – E-mail address
    – First name, Surname
    – Address
    – Phone number
    – Town or city
    – Official place of residence
  • Communicate with us: We receive the same data and your message when you contact us via our contact form. In this case, or if you contact us via the Website by other means, such as e-mail, you provide us with your data voluntarily, and thus with your consent.
• Data that we collect automatically when you browse our Website: With the exception of your IP (internet protocol) address, this information does not contain any personal details. It covers:
  • Device information: for example, information on the hardware and operating system you are using, or a unique device identifier.
  • Log data: this includes your IP address, as well as event and device information (such as crashes, system activity, browser type, browser language and the date and time of browser activity).
• Cookies and similar technologies: When you visit our Website, cookies and similar technologies are used to collect and store information that can identify your browser or device, as well as certain other data.

For more information and to learn how and to what extent you can prevent such data being collected, please read our Cookie Notice.

Why do we collect your data?

Data that you actively provide:

This data is gathered for the following purposes:

• To enable us to send you the publications that you have requested.
• To use your data for marketing purposes
• Your consent to the processing of your data for the aforementioned purposes may be withdrawn at any time by sending an e-mail to: marketing@pbihag.ch

Data that we receive automatically when you browse our Website:

This data may be processed for the following purposes:

• To improve the use and functionality of the Website.
• To improve services and products.
• To correct errors.
• To identify users who are acting unlawfully or who are infringing our rights.

For more information and to learn how and to what extent you can prevent such data being collected, please read our Cookie Notice.

With whom do we share your data?

We may share your data with the following third parties:

• Service providers that we engage to provide services for us, such as hosting and support for our website. To provide their services, these providers may, under certain circumstances, have access to your data, and may receive it, store it, or otherwise process it on our behalf. In accordance with the applicable legal requirements, we require these third parties to institute measures to ensure that your data is appropriately safeguarded, and processed only according to our instructions and for the purpose for which you provided it to us.
• Any third party to which we are ordered or obliged to disclose your data as the result of a court or official order, or by law.
• In addition, where permitted under applicable law, we reserve the right to make your data available to other third parties in the pursuit of overriding legitimate interests. For example, we may pass data on to the authorities if needed to investigate possible criminal behaviour, or we may use data in court or in debt collection proceedings if necessary to enforce our rights or to defend ourselves against claims.

Where is your data stored?

We take steps to ensure that your data is processed in accordance with this Privacy Policy and the requirements of applicable law, wherever the data is located.

Your data will be stored and, as a rule, also processed in Switzerland. However, depending on the service provider in question, your data may also be processed outside Switzerland. Please consult our Cookie Notice regarding Google Analytics and other tracking tools.

Should we make your data available from Switzerland to processors in other countries outside of the European Economic Area (‘EEA’), we will do so only in accordance with the applicable data protection legislation.

How do we protect your data?

We are committed to ensuring that your data is secure.

We use a variety of technologies and procedures to protect your data appropriately against unauthorised access, use, modification or disclosure.

In addition, provisions in our contracts with third parties (see above) ensure that they process your data securely in order to guarantee its confidentiality and integrity.

How long do we retain your data?

We store the data that you actively transmit to us for as long as it is required to serve its purpose (for example, your e-mail address will be retained for as long as you continue to subscribe to one of our publications). Thereafter, we will retain it if required to do so by law, or until any related claims have become subject to a statute of limitations (such as data relating to information on services).

Please refer to the Cookie Notice for details of retention periods for data that is collected automatically as you browse our Website.

Social media and other websites

Where we have a presence on a social media website such as LinkedIn, X (Twitter), YouTube or Vimeo, etc., and you visit our page, you should familiarise yourself in advance with the settings of those individual social media platforms that allow you to make choices about how data is processed and made available to third parties by the operators of such platforms. Each of those platforms is subject to the privacy practices and guidelines of the operators concerned. We therefore recommend that you read their privacy policies, terms of use and other information carefully to find out how your data is processed by these social media platforms.

Our website may contain links to third-party websites, for example through social media feeds. These websites are not operated or monitored by us. If you click on these links, you will leave our website. We accept no responsibility or liability whatsoever for the processing of your data by the organisations concerned. For more information and details, please consult the privacy terms of the websites you are visiting.

What rights do you have in respect of your data?

Under the Swiss Data Protection Act, you have the right to

• request information about whether and what personal data we process for what purposes, the individuals or entities to which we make that data available, and how long we store that data,
• request the correction of data about you,
• request that we restrict or halt the processing of your data, or that we delete your data, and
• request that we provide you with your data in a conventional electronic format suitable for migration.

If you would like to submit such a request, please contact the Controller according to section 10 of this Privacy Policy in writing. We require a copy of a valid official identification document to verify your identity. If you have a general question about our data processing or about this Privacy Policy, please send us an e-mail to: legal@pbihag.ch

Where permitted under applicable law, there may be rare cases in which we may not be able (fully) to comply with such a request. In such cases, we will notify of the reasons for this.

You have the right to lodge a complaint with the supervisory authority about the way in which we process your data. If you are resident in Switzerland, please contact:

Federal Data Protection and Information Commissioner
Feldeggweg 1
3003 Bern
Switzerland

Further information is available at www.edoeb.admin.ch. If you are resident in a country within the EEA, you may contact the supervisory authority in your country.

Controller (and representative in the EEA)

The Controller for the data collected via this Website is:

Privatbank IHAG Zürich AG
Bleicherweg 18
8002 Zürich
Phone +41 44 205 11 11

The data protection officer (within the meaning of the Swiss Data Protection Act) of the bank is:

Privatbank IHAG Zürich AG
Head Legal
Bleicherweg 18
8002 Zürich
Phone: +41 44 205 11 11
e-mail: legal@pbihag.ch

Applicable law and place of jurisdiction

This Privacy Policy is subject to Swiss law to the exclusion of the provisions of international private law. The courts at the registered office of Privatbank IHAG Zürich AG alone may decide any and all disputes arising from or in connection with the present Privacy Policy.

1 Purpose
This document provides information on the execution principles (Best Execution Policy) of Privatbank IHAG Zürich AG (the Bank). It contains the measures adopted by the Bank for the achievement of the best possible execution of clients’ instructions for the purpose of acquisition or disposal of securities or other financial instruments. The Bank applies thereby the regulatory requirements applicable in Switzerland (in particular those of the Swiss Financial Services Act “FinSA”). The purpose of the Best Execution Policy is to ensure that the instructions of the client are always executed or transferred in the best possible manner in terms of value, timeliness and quality. The most important execution venues listed at the end of the document are an integral component of the Best Execution Policy and may be adapted at any time where changes occur.

2 Scope of application
The Best Execution Policy applies to all clients. The Bank applies the execution principles independently of the nature of the execution to client instructions for the acquisition or disposal of financial instruments. The execution principles are also applied if, in fulfilment of its obligations under an asset management contract with the client, the Bank acquires or disposes of financial instruments on behalf of the client. In accordance with the supervisory regulations of the FinSA, the Bank divides its clients into private clients, professional clients and institutional clients.
Based on the supervisory regulations, the Bank has no Best Execution obligation in the following cases:

• Business with institutional clients according to the FinSA
• For divergent client instructions that under market conduct rules have priority over the principles of the execution of instructions governed here. Within the framework of divergent client instructions the Bank is absolved of its obligations for compliance with Best Execution, or these are considered to be fulfilled.
• For business conducted in the primary market. In such cases the Bank does not have the option to influence the execution factors.

3 Investment categories
The Best Execution Policy applies to the execution of client instructions for the acquisition or for the purpose of disposal of the financial instruments or transactions listed below (not exhaustive):

• Listed shares, stock exchange traded investment funds

(Exchange Traded Funds; ETF)

• Interest bearing securities
• Stock exchange traded derivatives
• Non-listed shares
• Structured products
• Securities lending
• OTC derivatives (i.e. “over the counter”, OTC, off market)

4 Principles
The Bank has processes that guarantee its clients the best possible execution. As part of this, the execution factors and execution criteria listed below are suitably weighted and applied when the instructions are executed in order to achieve the best possible outcome for the client. The continuous monitoring of the processes in compliance with this Best Execution Policy ensures that the best possible outcomes can always be achieved.

5 Instruction execution factors
When executing instructions, the Bank takes into account the various factors that are dependent upon the investment category in question. The Bank takes the following execution factors into account for the instructions:

• Price: execution price of the financial instrument to be traded
• Costs: (brokerage, processing fees, etc.) that may be charged to the client by the Bank for executing the instructions, taking into account any possible remuneration accruing to the Bank from third parties; the Bank’s clients receive the most up-to-date relevant information
• Execution probability: the probability that the client instructions will be completely executed
• Processing probability: the probability that the client instructions will be processed completely and successfully
• Size and type of the instruction: the volume and the structure of the instructions that influence the execution price
• Rapidity: the duration of an instruction from issue to completion
• Other factors that are relevant for the execution of the instructions

If there are no specific client instructions, the best possible execution outcome determines the execution, whereby both the price and costs factors are generally weighted higher than the other execution factors in the overall evaluation of the execution. For objective reasons, the Bank may decide to apportion the highest priority to execution factors other than price and costs (cf. point 6).

6 Execution criteria
When executing instructions, the Bank may use the following criteria to determine the relative importance of the execution factors:

• Characteristics of the client, if necessary, including the regulatory categorisation of the client
• Characteristics of the instructions
• Characteristics of the individual financial instruments affected by the instructions
• Characteristics of the execution venues where the client instructions can be carried out
• The market conditions prevailing at the time of receipt of the client instructions

7 Execution venues
In order to ensure the highest possible liquidity, the Bank may allocate instructions to different execution venues. These include:

• Stock exchanges and regulated markets
• Multilateral trading systems (MTF)
• Organised trading systems (OTF)
• Systematic internalisers (SI)
• Liquidity pools
• Interbank platforms
• Liquidity sources of the Bank, meaning market makers or other liquidity providers (brokers, etc.)
• The Bank’s own trading book, provided it is acting in the capacity of a counter party or liquidity provider

The list of execution venues at the end of this document “Execution venues of Privatbank IHAG Zürich AG” outlines which execution venues can be used for the individual categories of financial instruments. This list is not exhaustive, but includes execution venues that are continuously relied upon by the Bank to a great extent.
The Bank reserves the right to choose other execution venues that according to the Bank comply with the requirements of this Best Execution Policy, as well as to add or remove execution venues to or from this list. The list of “Execution venues of Privatbank IHAG Zürich AG” is updated periodically. The aim is to determine those execution venues that enable the Bank to achieve the best possible outcome from the execution of client instructions.

8 Instructions transfer
Dependent upon the instruction, market or access to trade the Bank may transfer an instruction to another financial institute (e.g. a broker) for execution. The Bank regularly checks the selection of the institutes with which it collaborates, and the quality of the execution, to ensure that the institutes have made suitable arrangements for the achievement of the best possible outcome for client instructions.
Should the Bank instruct a broker to execute a client instruction, the corresponding transaction is made as part of the measures that the agent has adopted under his Best Execution Policy.

9 Aggregation of instructions
The Bank does not normally combine the instructions of individual or groups of clients.
On the rare occasions when the Bank does indeed decide on aggregation, the following conditions must be cumulatively fulfilled:

• The aggregation is suited to the characteristics of the corresponding client instructions
• It is improbable that the aggregation will be disadvantageous for the clients whose instructions are being grouped together
• Compliance with the applicable procedure for the allocation of instructions is guaranteed

The allocation of completely or partially executed instructions, which were grouped together for execution, is made in accordance with the principles set out in this document. The allocation of the instructions executed is handled in the best interests of all the clients involved.
If the Bank is carrying out instructions on its own account, these are never grouped together with client instructions.

10 Processing divergent instructions
If individual markets are subject to unusual conditions or situations (e.g. partial or full interruption of trading), taking the interests of the client into account, the Bank may select another method of execution.

11 Fixed prices, OTC transactions and commission trading
If the Bank enters into a purchase or sale contract for financial instruments with the client at a fixed price (fixed price transaction), i.e. if the client makes a statement that he wishes to enter into a contract with the Bank for the acquisition or disposal of financial instruments, foreign exchange or precious metals at a defined price, the best possible outcome in terms of the execution principles is achieved where the client is offered prices in line with the market.
Bilaterally agreed transactions between the parties for the purchase or sale of financial instruments such as OTC derivatives as well as foreign exchange and precious metals are not conducted at a trading venue. In this case, the Bank and the client enter into a purchase contract at a defined or definable price, or sign a derivatives contract under agreed conditions. In the case of OTC trading, the Bank checks the offer price by examining market data – where available – that was used to estimate the price for this product and if possible compares this with similar or comparable products.
Certificates and warrants not traded on the stock exchange are produced in commission trading with the issuer or an outside execution provider. If the certificates and warrants were not produced in commission trading, the Bank offers them at a fixed price agreed with the client or at a definable price.

12 Monitoring
The Bank monitors, assesses and checks the effectiveness of its execution principles at least once a year. Information about any changes to this Best Execution Policy is provided to the clients in an appropriate form and published on IHAG.ch.

Execution venues of Privatbank IHAG Zürich AG

This Notice describes how Privatbank IHAG Zürich AG (‘We’) handle cookies and related technologies in connection with our www.pbihag.ch website and the official social media pages We control, as well as the HTML-format e-mail messages that We might send to you (referred to collectively below as ‘Sites’).

The access and use of our Sites require us to employ cookies and related technologies. These are essential to enable our Sites to run properly. You are able to block the use of such cookies (see further details below). However, blocking the use of such cookies in your browser settings may be detrimental to your use of our Sites. We may also use advertising cookies and tracking technologies to provide you with an enhanced and/or customised experience of our Sites. You are not obliged to permit the use of these cookies. If you do not allow the use of advertising cookies, your use of our website will not be affected in any way.
This Notice is dated June 2018. It may be updated. You will be notified of changes here. We recommend that you check this Cookie Notice regularly.

1. What is a cookie?
A cookie is a file that is stored on your computer or mobile device by websites you visit. It allows us or a third party to (1) enable certain functions on a Site, (2) conduct anonymous data analyses, and (3) store your preferences to speed up your future activities and personalise your experience on our Site. A cookie can do this because the Sites can read and change this small file. They thus allow the Sites to recognise you and to remember important information about you that will make your use of the website more convenient (for example by remembering your preferred settings), and enable content (including advertising) that is tailored to you.
Some cookies store personal data, for example if you click ‘remember me’ or ‘remember password’ when you log in. However, most cookies do not collect data that identifies you. Instead, they collect more general information such as the name of the website from which the cookie originates, the life of the cookie (i.e. how long it will remain on your device), the importance of the cookie and a value that is usually a randomly generated number.

2. What type of cookies do We use?
Cookies can be either session or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie remains on your device until it expires (the expiry date is contained within the cookie itself) or you delete it. Insofar as the information that is collected by cookies constitutes personal data, the provisions of the Privacy Policy apply to the use of that data.
We may use the following categories of cookie:

• Type of cookie: Functional
  • Examples:
    • cms_main (CMS)
    • cms_manager (CMS)
    • cookies_accepted (cookie function)
  • What does it do?
    • These cookies are necessary or important because they ensure that our Sites run properly. They enable you to navigate around our Sites and to use their features. For example, these cookies remember previous actions (such as text you have entered) when you return to a page during the same session. They can also enable visitors to watch videos, play games, and use social tools such as blogs, chatrooms and forums.
  • Does this cookie collect my personal data or identify me?
    • These cookies may collect certain information that might identify you, but do not do so in every case.

• Type of cookie: Performance
  • Examples:
    • _ga (Google Analytics)
    • _gat (Google Analytics)
    • _gid (Google Analytics)
  • What does it do?
    • These cookies help us to understand the behaviour of visitors to our Sites by providing information about the areas visited, the time spent in those areas, and any problems that were encountered. This helps us to improve the performance of our Sites.
  • Does this cookie collect my personal data or identify me?
  • These cookies do not identify you as an individual. All data is collected and stored in anonymous form. Further information is available from Google:link

• Type of cookie: Targeting/advertising cookies
  • Examples:
    • This website does not actively use advertising cookies.
  • What does it do?
    • These cookies are used to show you content (including advertising) that is relevant to you and adapted to your interests. They may be used to place targeted advertising or to limit the number of times you see an advert­isement. They also help us to measure the effectiveness of advertising campaigns on our Sites or on third-party sites. We may use these cookies to record the Sites that you have visited, and We may share this information with third parties such as advertisers, analytics services, and our agencies.
  • Does this cookie collect my personal data or identify me?
    • Most of these cookies track users via their IP address, and are thus able to collect personal data. However, these cookies are only ever used with your prior express consent, which you may withdraw at any time. In no event are they stored on your device for more than one year after they have been set.

3. How do third parties use cookies on our Sites?
Dritte, wie Unternehmen, welche Daten analysieren, nutzen Cookies normalerweise auf einer anonymisierten Basis.

4. Other similar technologies
Our Sites additionally use other tracking technologies, such as IP addresses and/or log files and/or web beacons, which also help us to tailor our Sites to your personal needs:

• IP addresses: An IP address is a number that is used by computers on the network to identify your computer every time you go on to the internet. We may record IP addresses for the following purposes: (i) to troubleshoot technical problems, (ii) to maintain website safety and security, (iii) to better understand how our websites are used, and (iv) to tailor content better to your needs, depending on the country you are in.
• Log files:We (or a third party on our behalf) may store data in the form of log files, which record website activity and gather statistics about the user’s browsing habits. These logs are generated anonymously and, among other things, help us to gather the following information: (i) the user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited the website, and which pages they viewed and for how long) and (iii) other similar navigational or click-stream data. Information that is collected by Google Analytics is stored for 38 months.
• Web beacons: We (or a third party on our behalf) may use web beacons (or clear GIFs) on our Sites. Web beacons (also known as ‘web bugs’) are short strings of code that provide a method of projecting a graphical image on to a website for the purpose of transferring data back to us. The data that is collected by web beacons may include information about how a user responds to an e-mail campaign, such as the time the e-mail is opened, what link in the mail the user clicks on, etc. We use web beacon information for a variety of purposes, such as to record website traffic, for unique visitor counts, for advertising, for e-mail auditing and reporting, and for personalisation.

5. How can I manage my cookie settings?
Although this may change in the near future, most browsers are initially set up to accept cookies, but allow you to change these settings and thus delete existing cookies, block future ones, or alert you when they are being sent to your device. Please refer to your browser settings and the corresponding instructions. If you modify your settings, please note that you may no longer be able to use all of the features We offer, or We may not be able to store your preferences, and that some of our pages may no longer be displayed in full. Please also note that, if you use different computers at different locations, you must ensure that the browser settings on each of these computers reflect your cookie preferences.
Microsoft Internet Explorer 6.0, 7.0, 8.0, 9.0, 10.0, 11.0

• Click on the ‘Tools’ icon (the cog) in the upper right-hand corner of your browser window and select ‘Internet options’, then click on ‘Privacy’. Under ‘Settings’, click on ‘Advanced’ to choose whether you want to accept or block cookies, or decide on an individual basis.

Microsoft Edge

• Click on the ‘Menu’ icon (three dots in a horizontal line) in the upper right-hand corner of your browser window and select ‘Settings’. Scroll down to the bottom and select ‘View advanced settings’. At the end of the list you will find the ‘Cookies’ section, with several options. If you select the ‘Block all cookies’ option, they will no longer be saved.

Google Chrome (latest version)

• Click on the ‘Menu’ icon (three dots in a vertical line) in the upper right-hand corner of your browser window and select ‘Settings’. Click on ‘Advanced’ at the bottom and locate the ‘Privacy and security’ section. Click ‘Content settings’ and, in the cookie section at the top, select ‘Allow sites to save and read cookie data (recommended)’ to enable cookies. To disable cookies, switch off this latter function and enable the ‘Block third-party cookies’ and ‘Keep local data only until you quit your browser’ options.

Mozilla Firefox

• Click on the ‘Menu’ icon (three horizontal lines) in the upper right-hand corner of your browser window and select ‘Options’. Then select the ‘Privacy & Security’ section from the list on the left. Check ‘Accept cookies and site data from websites (recommended)’ to enable cookies. If you do not wish to enable cookies, check ‘Block cookies and site data (may cause website to break’.

Safari

• Click on the Safari icon in the upper right-hand corner of your browser window and select ‘Preferences’. Then click on the ‘Privacy’ icon at the top of the overlay that appears. Check ‘Accept cookies from other sites’ to enable cookies. If you do not wish to enable cookies, check ‘Never’. Since a web beacon forms part of a web page, it is not possible to opt out of them, but you can render them ineffective by opting out of the cookies that enable them.

More information
If you have any questions about our Cookie Notice, you can contact us by e-mail to the following address: marketing@pbihag.ch.

Deposit insurance

Deposit insurance protects the credit balances of private and corporate clients in the event of a bank or securities firm’s bankruptcy and is regulated by law. The protection is limited to a maximum of CHF 100’000 per client and institution. Multiple accounts are added together. esisuisse guarantees that it will cover protected deposits as part of the self-regulation of Swiss banks and securities firms. Deposits at Privatbank IHAG Zürich AG are also covered by the deposit insurance scheme. Detailed information are available at www.esisuisse.ch.

Privatbank IHAG Zürich AG
Head Legal
Bleicherweg 18
8022 Zürich
phone: +41 44 205 11 11
legal@pbihag.ch