1. Who we are
RAM Capital SA (“RAM Capital”, “we”) is responsible for the processing of personal data described in this policy, within the meaning of the Swiss Federal Act on Data Protection (FADP).
RAM Capital SA, Rue Versonnex 11, 1207 Geneva, Switzerland
Telephone: +41 22 849 83 00
For any question about your personal data, contact us at dsarper@ramcapital.ch, or write to us at the address above.
2. Scope
This policy explains how we handle personal data when you visit ramcapital.ch, contact us, ask to receive our publications, or become a prospective or existing client. It also covers the people connected to a client relationship, such as authorised representatives, beneficial owners and family members.
Clients receive additional information in their contractual documentation. Where that documentation is more specific, it prevails.
3. Personal data we collect
We collect only the data we need for the purposes in section 4. Our website has no contact form, account area or analytics tool: you share data with us mainly by e-mail, telephone or in meetings.
| Situation | Data | Source |
|---|---|---|
| Visiting our website | IP address, date and time, page requested, browser type, recorded in our hosting provider’s technical logs | Your browser |
| Contacting us | Name, e-mail address, telephone number, content of your message | You |
| Publications and newsletter | Name, e-mail address, the publications you request | You |
| Prospects and clients | Identity and contact details, date of birth, nationality, domicile, identity documents, civil and family status, signature specimens, professional background, origin of assets, financial situation including income, assets and debt-collection records, investment objectives, knowledge and experience, risk profile, account and portfolio data, transactions, correspondence and meeting notes | You, your custodian banks, your authorised representatives, business introducers, public registers such as the commercial and land registers, and compliance databases used for anti-money-laundering checks |
Some of this data may reveal sensitive information, for example in sanctions or politically-exposed-person screening. We process it only where the law requires or allows it.
4. Why we use your data
We use personal data to:
- answer your enquiries and arrange meetings;
- send you the publications and newsletter you asked for, until you unsubscribe;
- open and manage a client relationship, including portfolio management, advisory and execution services under the Financial Services Act (FinSA);
- meet our legal and regulatory duties, in particular client identification and anti-money-laundering checks under the Anti-Money Laundering Act (AMLA), record-keeping, reporting and supervision by FINMA and SO-FIT;
- operate and secure our website and IT systems;
- establish, exercise or defend legal claims.
We rely on the performance of a contract, our legal obligations, our legitimate interests or, where required, your consent. You can withdraw consent at any time for the future.
5. Who receives your data
We do not sell personal data. Within RAM Capital, only staff who need it for their work have access. We share data outside the firm only with:
- custodian banks, brokers, issuers and financial market infrastructures involved in your mandate and transactions;
- service providers acting on our instructions, such as our website host (OVHcloud), our e-mail and office software provider (Microsoft 365, with data stored in Switzerland), and portfolio-management and IT providers, with data stored in Switzerland;
- our auditors and professional advisers, who are bound by confidentiality;
- FINMA, our supervisory organisation SO-FIT, courts and other authorities, where the law requires it;
- other third parties you ask us to involve, such as your lawyer, tax adviser or fiduciary.
Service providers must keep the data confidential and use it only for the service they provide to us.
6. Data sent abroad
Our custodian banks and our main IT providers keep your data in Switzerland. Our website is hosted by OVHcloud in Gravelines, France, so the technical data from your visits is stored there.
We send personal data abroad only to countries the Swiss Federal Council recognises as providing adequate protection, such as EU and EEA member states. For other countries, we use the safeguards required by the FADP, such as standard contractual clauses recognised by the Federal Data Protection and Information Commissioner (FDPIC), or a legal exception, for example where the transfer is needed to perform your contract, such as executing a transaction you instructed.
7. How long we keep your data
We keep personal data only as long as its purpose requires, or as long as the law obliges us to.
| Data | Retention period |
|---|---|
| Client records, identification and anti-money-laundering files, transaction records | 10 years after the end of the relationship or the transaction (AMLA, Code of Obligations) |
| Newsletter and publication lists | Until you unsubscribe |
| Website technical logs | Kept by our hosting provider for a limited period, for security and statistics, then deleted |
We may keep data longer where it is needed to establish or defend legal claims. At the end of the period, we delete or anonymise it.
8. Security, cookies and our website
We protect personal data with technical and organisational measures appropriate to the risk, including access restrictions, encrypted connections and confidentiality obligations for our staff and service providers.
Our home page does not use cookies, analytics, advertising trackers or social-media plug-ins, and it does not load content from third-party servers. Our legal pages (terms of use, rules and regulations and this policy) set one technical cookie, nitroCachedPage, which only helps deliver cached pages faster. They are delivered through the NitroPack content-delivery network and load fonts from Google Fonts, so NitroPack and Google receive your IP address when you open these pages. Google LLC is certified under the Swiss-U.S. Data Privacy Framework. We do not use these services to track you.
Ordinary e-mail is not a secure channel. Please do not send confidential information, such as account details, by unencrypted e-mail. We will agree a secure channel with you where needed.
9. Your rights
Under the FADP, you can:
- ask whether we process your personal data and obtain a copy of it;
- have inaccurate data corrected;
- object to processing, or ask us to delete data, unless we must keep it by law;
- receive data you gave us in a common electronic format, or have it sent to another controller;
- withdraw consent you gave us, for example to receive our newsletter.
Send your request in writing, signed and with a copy of your identity document, to the contact in section 1. We answer within 30 days. Legal retention duties or professional secrecy may limit some rights; if so, we will tell you why.
You may also lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch.
10. Changes to this policy
We may update this policy when our services, providers or the law change. The version published on ramcapital.ch applies.
Last updated: 10 October 2026