Privacy Policy

Important Legal Notice

Galena Asset Management S.A. (“Galena”) is committed to protecting and respecting your privacy. This Privacy Policy (together with our Legal and Regulatory Notice and any other documents referred to in it) sets out the basis on which any personal data which Galena collects about you, or that you provide to Galena, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. Information Galena may collect from you

Galena may collect and process the following data about you: Information that you provide by filling in forms on our site https://www.galena-invest.com (the “Website”), including without limitation information provided as part of applying to register for full access to the Website.
If you contact us, we may keep a record of that correspondence.
Galena may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Details of your visits to the Website including any resources that you access.

2. Cookies and Other Tools

1. We may use information about your visits to the Website by using a “cookie” or similar technologies for storing information, such as local shared objects and web beacons, which we refer to collectively in this Privacy Policy as “cookies”. A cookie is a small text file which is transferred to and stored on your computer, portable device or mobile. Cookies can be unique to your web browser and contain text and information such as a unique identifier, site name, digits and numbers. The information collected and stored is statistical data about our users' browsing actions and patterns and we do not use it to identify any individual.

2. Cookies are used to differentiate one user from another, to pass information from page to page during their visit to the Website and to collect data about a given browser, along with the information requested and sent by the browser's operator (the visitor). They enable us:

To estimate our audience size and usage pattern.
To store information about your preferences, and so allow us to customise the Website according to your individual interests.
To recognise you when you return to the Website, in particular if you are accessing registration-dependent part of the Website.

3. You may at any time refuse to accept cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Website.

4. By using the Website, you are consenting to our use of cookies.

What cookies do we use?

1. We use two different types of cookies on the Websites: session cookies and persistent cookies. Session cookies are temporary files that only remain in the cookie file of your internet browser until you leave the Website. Depending on the cookie type, persistent cookies can remain for periods ranging from hours to years in the cookie file of your internet browser after you leave the Website and after your internet browser is closed.

2. The cookies we use are ‘analytical’ cookies (in particular, we use Google Analytics which provides us with meaningful reports on how visitors use the Website. The cookies we use are first-party cookies which means that they are set by the Website when you visit and the data collected by these cookies cannot be altered or retrieved by any service on another domain or by any third party.

3. Our use of cookies basically falls into three categories:

those that are strictly necessary to deliver the services and products you have requested, such as the Galena Disclaimer cookie
cookies related to the performance of the Website, such as Google Analytics
cookies related to the functionality of the Website, such as remembering a preferred choice of language, when available.

5. You may at any time refuse to accept or block cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. You may also be able to change the setting on your internet browser so that only particular types of cookies will be accepted.

6. If you would like to know more about cookies, including local storage devices, the following websites provide useful information:

7. For a video about cookies visit https://www.google.com/policies/technologies/cookies. You can also opt out of being tracked by Google Analytics across all websites by visiting https://tools.google.com/dlpage/gaoptout to find out how.

8. Please note, if you change your settings in either of these ways, you may be unable to access certain parts of the Website.

3. Where We Store Your Personal Data

1. The data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area ("EEA"). You acknowledge that such foreign jurisdictions may not have data protection laws equivalent to Swiss or EEA data protection legislations. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. Galena will take all steps reasonably necessary to treat your data securely and in accordance with this Privacy Policy.

2. You acknowledge and understand that the transmission of information via the internet is not completely secure. Although we will take reasonable and appropriate steps to protect your personal data once we have received it, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.

4. Uses Made of the Information

We use information held about you in the following ways:

To ensure that content from the Website is presented in the most effective manner for you and for your computer.
To provide you with information that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
To carry out our obligations arising from any contracts entered into between you and us.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.

5. Disclosure of Your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Galena or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

6. Your Rights

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at information@galena-invest.com.
The Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

7. Changes to Our Privacy Policy

Any changes we may make to the Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

8. Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to information@galena-invest.com

last updated: September 2020