Privacy Policy

1. Who We Are

Thunderbirds Holding AG is an institutional investment management firm. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you visit our website or otherwise interact with us in a business context.

For questions about this policy or our data practices, please contact us at privacy@thunderbirdsholding.com.

2. Data We Collect

We may collect and process the following categories of personal data:

• Contact and identity data: name, job title, company name, email address, phone number, and postal address when you submit enquiry forms or contact us directly.
• Technical data: IP address, browser type and version, time zone, operating system, and other technology on the devices you use to access our website.
• Usage data: information about how you use our website, including pages visited, time spent, referring URLs, and links clicked.
• Marketing preferences: your preferences for receiving communications from us and your communication preferences.

We do not collect sensitive personal data (such as information about health, religion, or political views) through this website.

3. How We Use Your Data

We use your personal data for the following purposes:

• To respond to enquiries and provide requested information about our investment strategies and services.
• To send you research publications, market updates, and event invitations where you have consented or where we have a legitimate interest in doing so.
• To manage our business relationship with your organisation, including maintaining records of interactions.
• To improve and administer our website and ensure its security.
• To comply with our legal and regulatory obligations.

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Legitimate interests: for business development, maintaining client relationships, and improving our services, where our interests are not overridden by your data protection rights.
• Consent: where you have provided explicit consent, such as subscribing to our research communications.
• Legal obligation: where we are required to process data to comply with applicable laws or regulatory requirements.

5. Data Sharing

We do not sell, rent, or trade your personal data to third parties. We may share your data with:

• Service providers who assist us in operating our website, conducting our business, or servicing you (subject to confidentiality obligations).
• Regulatory or law enforcement authorities where required by law.
• Professional advisers such as lawyers, auditors, and insurers in the course of professional services rendered to us.

Any third parties with whom we share data are contractually required to maintain appropriate security measures and use your data only for the specified purposes.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. For institutional contact data, we typically retain records for the duration of our business relationship plus a period of up to seven years thereafter.

7. Your Rights

Depending on your jurisdiction, you may have the following rights in relation to your personal data:

• The right to access your personal data and receive a copy of it.
• The right to correct inaccurate or incomplete personal data.
• The right to request erasure of your personal data in certain circumstances.
• The right to restrict or object to the processing of your personal data.
• The right to data portability where processing is based on consent or contract.
• The right to withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at privacy@thunderbirdsholding.com. We will respond to your request within 30 days.

8. Cookies

Our website uses essential cookies to ensure basic functionality. We do not use tracking or advertising cookies. Essential cookies are necessary for the website to function properly and cannot be switched off in our systems.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the updated policy on this page with the revised effective date. We encourage you to review this policy periodically.

11. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

Thunderbirds Holding AG
Email: privacy@thunderbirdsholding.com