Privacy policy

The latest update of this privacy policy has been published on October 11th, 2024.

Please note that this privacy policy has been translated in English for your convenience, but in case of divergence, inconsistency or difference between this English version and the original version in French, the French version prevails and is considered the reference version.

Please find here below the Privacy Policy of Mt Pelerin Ltd (hereinafter called «Mt Pelerin», «we», or «us»), a company incorporated under the laws of Switzerland with registration number CHE-188.552.084 and the address Mt Pelerin Ltd, Microcity, Rue de la Pierre-à-Mazel 39, 2000 Neuchâtel.

We understand that your privacy is important and we are strongly committed to protecting it and the Personal Data or Information that you may provide when you access and use content we own or operate on the websites located at mtpelerin.com, or any other websites, app, pages, features, or content we own or operate (hereafter: the "Site(s)") and/or when you use our mobile application and related services (referred to collectively hereinafter as "Services").

Furthermore, the information you provide to Mt Pelerin in response to an email request, to any other contact from Mt Pelerin, or while using any Mt Pelerin application, will also be processed in accordance with this Privacy Policy.

In this Privacy Policy, Mt Pelerin explains how your Personal Data is used and outlines its commitment to privacy protection. We are committed to handling your Personal Data responsibly, in compliance with the requirements of the Swiss Federal Data Protection Act of September 25, 2020, its ordinances, and other legal provisions. Additionally, we ensure compliance with the European Union's General Data Protection Regulation (GDPR) 2016/679.

1. Acceptance of Mt Pelerin's privacy policy

By using Mt Pelerin's site and services, and by submitting your personal information, you consent to the terms of our privacy policy. If your consent is required for the processing of your personal data, we will ask for it explicitly. Ibani may provide specific additional information for certain uses of services.

If you do not agree to this policy, please stop using our services.

2. Data and personal data

Personal Data refers to information that allows you to be directly or indirectly identified or contacted.

Our Privacy Policy applies to all Personal Data you voluntarily submit or that we obtain from our partners. This includes identification data, financial data, and transactional information, among others. Such data is processed solely for legitimate purposes such as providing services, legal compliance (including fraud and money laundering prevention), and improving our services.

We are committed to not selling, renting, or lending your Personal Data to third parties, except as described in this policy.

2.1 Personal data we collect

We collect Personal Data that you provide directly or that is generated when using our services. This includes, but is not limited to:

  • Personal identification data: full name, date of birth, address, phone number, etc.
  • Financial data: banking information, transaction history, etc.
  • Official identification data: passport number, driver's license, etc.
  • Transactional data: information related to transactions conducted using our services.

We may also collect additional information through third parties (identity verification partners, public databases, etc.) as required by Swiss law, particularly for identity verification and compliance with legal obligations regarding anti-money laundering and fraud prevention.

2.2 Data collection when using our services

When registering for our services, you may be asked to provide information such as your name, address, tax identification number, financial information, and transaction history. This information is necessary to meet our legal obligations and provide the requested services.

We also collect browsing data when you visit our website, such as IP address, device used, and login information. This data is used for security analysis and statistical purposes, without directly associating it with personal data unless fraud or abuse is suspected.

2.3 Data storage and security

Your Personal Data is retained for as long as necessary to fulfill the defined purposes or comply with Swiss legal obligations. We implement technical and organizational security measures to protect your data from unauthorized access or unlawful processing.

3. How your personal data is used

We use your personal data to provide you with a seamless and secure experience while complying with Swiss law. This includes processing for:

  • Legal compliance: Customer identification and identity verification, in accordance with Swiss anti-money laundering laws.
  • Service provision: Use of data to grant access to Mt Pelerin services.
  • Information security: Protection against fraud and cyberattacks.
  • Research and development: Continuous improvement of our services and customization based on your usage.
  • Marketing and communication: Sending personalized offers if you consent.

3.1 Legal compliance

We are required to identify and verify users to meet obligations regarding anti-money laundering and combating the financing of terrorism.

3.2 To enforce our terms in our user agreement and other agreements

We handle sensitive information, such as your identification and financial data, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our terms.

3.3 To provide Mt Pelerin services

We process your personal information in order to provide the Services to you.

We cannot provide you with Services without such information.

3.4 To provide service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.

3.5 To provide customer service

We process your personal information when you contact us to resolve any question, dispute, collected fees, or to troubleshoot problems. We may process your information in response to another customer's request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

3.6 To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.

3.7 Information security

We ensure information security and meet Swiss cybersecurity standards by monitoring online threats and protecting access to our services.

3.8 For research and development purposes

We process your personal information to better understand the way you use and interact with our Services. In addition, we use such information to customize, measure, and improve the Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest.

3.9 To enhance your website experience

We process your personal information to provide a personalized experience and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

3.10 To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.

EEA residents: pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

3.11 Marketing activities

We will only send marketing communications if you consent. You may unsubscribe from these communications at any time.

4. Cookies - collection and use of data collected automatically

Cookies are small files that we use to enhance your experience on our site. We inform you that cookies do not store personal data without your explicit consent.

We use cookies to:

  • Track your preferences and improve our services.
  • Ensure the site's security.
  • Analyze traffic and interactions to optimize the user experience.

Your rights: You can disable cookies in your browser settings at any time, though this may affect certain site features.

Third-party tracking tools: We use Google Analytics to anonymously track traffic on our site. You can disable Google Analytics by installing the browser-specific opt-out add-on.

For more information on Google Analytics' privacy practices, please review the Google Privacy Policy

5. Disclosing and transferring personal data

Mt Pelerin may disclose your Personal Data to third parties, authorities, and transfer it outside of Switzerland or the EEA in certain cases. All disclosures will be made in accordance with Swiss law and only when necessary to provide you with our services or to comply with legal obligations.

5.1 International data transfer

If your data is transferred in countries that don't offer an adequate level of protection, Mt Pelerin will prepare standard contractual clauses or other appropriate guarantees to protect your personal data.

5.2 Sharing with third parties

We may share your information with:

  • Trusted partners that act on our behalf (for instance marketing agencies or IT experts), and such third parties will respect our privacy policy.
  • Legal authorities, if law demands it.
  • Companies from the Mt Pelerin group to improve the services that we offer.

5.3 Transfers outside of Switzerland and the EEA

We may only transfer your Personal Data out of those areas if:

  • We have standard contractual clauses or other adequate guarantees.
  • The transfer is necessary to execute our legal or contractual obligations.
  • We obtain your explicit consent.

5.4 Transparency and control

We will inform you of any transfer of important data to third parties and you will have the possibility to revoke your consent at any time.

5.5 How your information are shared with third parties

When you authorize a third party application to access your Mt Pelerin account, third parties may access certain information, but only to facilitate your transactions with Mt Pelerin. That information is protected by the Federal Act on Data Protection (FADP) and by the privacy policies of those third parties.

6. Transfer of data

We store and process your Personal Data in data centers around the world. Your information might be transferred out of Switzerland and the EEA in countries that don't offer a data protection level that correspond to the Swiss or European norms.

For such transfers, we use standard contractual clauses or we ensure that the third parties respect frameworks like that Data Privacy Framework (previously known as the Privacy Shield). It guarantees that your data enjoys a level of protection equivalent to the Swiss or the EEA one.

7. Security of data

We store your Personal Data on secured servers managed by Amazon Web Services (AWS), located in the United States. AWS is compliant with the requirements of the new Swiss Data Protection Act to ensure the safety and confidentiality of your data. Moreover, a specific addendum to the AWS data processing contract has been implemented to respect the Swiss regulation regarding data protection. We have implemented strict technical and organizational security measures to protect your data from loss, unauthorized access or mishandling.

All data are stored on secured networks only accessible by authorized persons, subject to confidentiality obligations. We use advanced security protocols and our systems are regularly scanned to detect vulnerabilities.

Although we strive to ensure the safety of your data, we encourage you to use strong passwords and to report any suspect activity. If you suspect a safety breach, please contact us immediately.

8. Retention of data

8.1 Personal data

Mt Pelerin keeps your Personal Data as long as necessary to the purposes defined by this Privacy Policy, in accordance to Swiss legal obligations. For instance, after the closure of an account, data is kept for a minimum duration of five years and up to ten years depending on legal requirements.

8.2 Data collected automatically

Automatically collected data, like the one generated from using the website, are kept for internal analysis and security improvements, usually for a period of one year, unless legal obligations require a longer period.

9. Disclosures due to legal compliance

Mt Pelerin follows Swiss and international privacy laws. We can be led to disclose your personal information to relevant authorities without your consent if we are forced to do so by a court decision, a legal order, or any other form of legal obligation. It includes cases where laws of Switzerland or other applicable juridictions demand it.

In case of breach of our terms and conditions, we can also share your information with our commercial partners or with relevant authorities.

10. Your rights

10.1 General

Mt Pelerin Ltd acts as the legal representative for the processing of your Personal Data. We define the purposes and modalities of the processing of your data.

Whenever possible, you update your Personal Data directly in your user profile. If you fail to modify your Personal Data, please contact us to make the relevant modifications.

If you have any questions or if you would like to use your Rights, please contact us by writing at [email protected] so that we can consider your request in accordance to applicable law. Indeed, being a regulated intermediary, Mt Pelerin has a legal basis to limit certain rights of persons concerned by the protection of their personal data when it is required to comply with legal obligations such as those imposed by AMLA, KYC regulations or tax obligations, to protect public interests, in particular in the context of combating money laundering and the financing of terrorism, or to preserve confidentiality or professional secrecy.

You have the following rights:

10.1.1 Right to access

You can request access to your personal data and obtain a copy of the information held by Mt Pelerin.

10.1.2 Right to correct

You have the right to request the correction of your incomplete or incorrect data.

10.1.3 Right to withdraw consent

You can withdraw consent for the processing of your data at any time.

10.1.4 Right to limit

You can request the limitation of the processing of your data in specific circumstances.

10.1.5 Right to oppose

You have the right to oppose the processing of your data for legitimate reasons or for direct marketing purposes.

10.2 Complaint

If you think that your rights have been violated, you can contact us at [email protected]. You also have the right to file a complaint with competent authority in Switzerland or in the EU.

11. Children's personal data

Mt Pelerin does not knowingly collect Personal Data from individuals under 18 years old. However, in some exceptional cases, and under strict and justified conditions, such a collect might be considered as long as it complies with applicable law. If we discover that a person under 18 has submitted personal data without respecting these conditions, we will immediately take action to close that person's account and delete that person's personal data according to applicable law.

12. Links to other websites

The Mt Pelerin website may contain links to third-party sites. We advise you to review their own privacy policies, as we have no control over their content or policies. We decline all responsibility in that regard.

13. Changes to this privacy policy

We reserve the right to update this privacy policy. Please check this page regularly for changes.

14. Contact us

For questions or complaints, contact us at [email protected] or by postal mail at the following address:

Mt Pelerin Ltd
Microcity
Rue de la Pierre-à-Mazel 39
2000 Neuchâtel, Switzerland