GDPR Compliance

GDPR Compliance
This Privacy Statement covers our data and technology-related products, chiefly ARDIS software. It explains how ARDIS (hereinafter referred to as "ARDIS and associated data and tech products") complies with GDPR when handling the collected data. It also provides your rights and contact information for further inquiries about your personal data.

More information about ARDIS is included here.

WHO WE COLLECT DATA ABOUT?

Polixis aims to assist financial intermediaries, governments, regulators, as well as other customers with legitimate interest in risk management (hereinafter referred to as "Customers") to perform their legal or regulatory obligation of due diligence and other screening operations. Our Scope covers several aspects of primary interest to the above-mentioned group of customers and includes economic, financial, regulatory, judicial, political, sanction and similar data sets.

THE SCOPE OF PEP-RELATED DATA PROCESSING

The Scope of PEP-related data gathering covers the personal and political data of the data subjects on legitimate basis. The criteria of our data selection are unique, as they are directed towards Politically Exposed Persons (PEPs), their families and close associates, as defined primarily by the FATF Recommendations. Other criteria may also include the ones generally accepted by the Swiss financial legislation and regulation in place.

Other selection criteria may be linked to involvement in anti-money laundering (AML) activities and other affiliated activities relevant to the legitimate interests of the above-mentioned customer groups.

Having your information in ARDIS in general and in the PEP profile in particular, does not mean that you are linked to any criminal activities or wrongdoing. The Data is collected and processed for the purpose of public interest, in accordance with Article 89 of the GDPR.

HOW WE COLLECT THE DATA?

Our data is retrieved from sources available to general public or sources made available as a rule by either Government bodies, agencies, organisations or other reputable private and semi-governmental sources. A detailed list of primary data sources is given below:

  • National Public Authorities and Governmental Sources;

  • International Organisations;

  • Country-Specific Media Sources;

  • Sanction and Enforcement Lists;

  • Courts and Other Law Enforcement Agencies.


  • WHY WE COLLECT THE DATA?

    ARDIS provides compliance-relevant economic, financial, judicial, sanction, regulatory and political data that helps its clients with Risk & Compliance and transactional due diligence.

    The Data collection helps to facilitate compliance with regulations related to anti-money laundering (AML), terrorism financing, anti-bribery and corruption, in order to prevent those with criminal intent from using banks and businesses to launder money and conduct corrupt business practices.


    WHAT KIND OF INFORMATION DO WE PROCESS?

    ARDIS primarily processes the following information about you:

  • Identifying information: First name, last name, aliases, gender, date of birth, country of citizenship and country of residence.

  • Family: Spouse & Children, Close Friends and Associates.

  • Employment: Current and previous job positions, as well as affiliations (membership in Boards and organizations, etc.)

  • Financial Information: Bankruptcy/insolvency filings, publicly reported financial figures and internationally recognised wealth rankings.

  • Judicial and Regulatory Data: Sanctions, Judicial Decisions Disqualifications, Crimes etc.


  • WE PROCESS THE INFORMATION IF:

  • the information was made public by Public Authorities (Governments, Parliaments, Agencies etc);

  • the information was made public by you;

  • the information is necessary for public interest on the basis of all applicable laws (including terrorism financing, money laundering etc.) and was publicly reported in an identifiable source.


  • TWO-WAY RELATION

    The cohesion and interconnection between us as a Data Provider and you as a Data Subject is of high importance. As a data providing company through ARDIS, Polixis falls under the regulations of the GDPR.

    The main Components of GDPR in relation to your rights as a Data Subject are within the statutory limits (Chapter 3 of the GDPR - https://gdpr-info.eu/chapter-3/):

  • Right to information

  • This right provides you with information about what kind of personal data is being processed.

  • Right to access

  • This right provides you with the ability to get access to your personal data that is being processed, as well as to request copies of your data.

  • Right to rectification

  • This right provides you with the ability to ask for changes/updates of your personal data, in case your data is not up to date, accurate or, otherwise, incorrect.

  • Right to withdraw consent

  • You have the right to request a withdrawal and deletion of information about you. However, Polixis reserves the right to assess such requests individually for its compliance to GDPR and generational legislation in place.

  • Right to object

  • This right provides you with the ability to object to the processing of your data. (Similar to withdrawal).

  • Right to be forgotten

  • This right provides you with the ability to ask for the deletion of your data.

  • Right for data portability

  • This right provides you with the ability to ask for the transfer of your personal data to another controller.

    *Cross-border data transfer - Under GDPR, your personal data can be transferred between EU member states without restrictions. Those transfers can also take place without further authorization, if the third country’s body of national law ensures an adequate level of protection for personal data. Transferring the data out of the EU, without a well-founded transfer mechanism, will result in penalties.


    DISCLOSURES

    Your information will be available to the following groups only: Clients and any other person to whom we will be legally obliged to provide this information. Most commonly, this will be law enforcement agencies that may require such information in our countries of operation.

    This statement might be updated from time to time without any prior notice.

    HOW TO CONTACT US

    The data subjects may address us their queries any time by contacting us at info@polixis.com or + 41 22 340 22 00.
    Geneva
    1-3 Chantepoulet, Geneva, 1201, Switzerland
    Telephone: +41 22 340 22 00
    E-mail:
    Zurich
    Telephone: +41 22 340 22 00
    E-mail:
    London
    Telephone: +41 22 340 22 00
    E-mail:
    Yerevan
    22 A1 Marshal Baghramyan, 0019 Yerevan, Armenia
    Telephone: +374 44 22 34 22
    E-mail: