Privacy Policy

Privacy policy


ASH Capital Finance and its subsidiaries (“ASH Capital”) respect and protect the privacy of the visitors to Capital’s website and ASH Capital’s clients who use ASH Capital’s Services. To ensure transparency, this Privacy Policy describes ASH Capital’s (and its subsidiaries) information handling practices when you access the content of ASHCapital’s website located at ashcapital.org (http://www. ashcapital.org/), and when you are a client of ASH Capital or its subsidiaries. 

Acceptance of the privacy policy

By accessing and using ASH Capital’s Services, you signify that you have reviewed the terms of this Privacy Policy. Where ASH Capital requires your consent to process your personal information, ASH Capital will ask for your consent to the collection, use, and disclosure of your personal information as described further below. ASH Capital may provide additional “just-in-time” disclosures or additional information about the data collection, use, and sharing practices of specific Services. These notices may supplement or clarify ASH Capital’s privacy practices or may provide you with additional choices about how ASH Capital processes your data. If you do not agree with or are not comfortable with any aspect of thisPrivacy Policy, you should immediately discontinue access or use of ASH Capital’s Services. 

Changes to this privacy policy 

ASH Capital reserves the right to modify this Privacy Policy at any time. When required by law, ASH Capital will notify you of changes to this Privacy Policy. If ASH Capital makes any material changes, ASH Capital will notify you by email (sent to the email address specified in our database), or by means of a notice on ASH Capital’sServices prior to the change becoming effective. 

Personal information collected by ASH Capital

Personal information is data that can be used to identify you directly or indirectly or to contact you. ASH Capital’s Privacy Policy covers all personal information that you voluntarily submit to ASH Capital and that ASH Capital obtains from ASH Capital’s partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you. You may be asked to provide personal information at any time that you are in contact with any of the ASH Capital companies. The ASH Capital companies may share your personal information with each other and use it consistent with thisPrivacy Policy. They may also combine it with other information to provide and improve ASH Capital’s products, services, and content (see the section below). Except as described in this Privacy Policy, ASH Capital will not give, sell, rent, or loan any personal information to any third party. 

Personal information collected
ASH Capital collects personal information to provide you with ASH Capital’s Services. When ASH Capitalrequires specific personal information from users, it is because such information is relevant for certain purposes. Any information you provide to ASHCapital that is not required is voluntary. For example, ASH Capital collects personal information when you use or request information about ASH Capital’s Services, subscribe to marketing communications, request support, complete surveys, or sign up for an ASH Capitalevent or webinar. ASH Capital may also collect personal information from you offline, such as when you attend one of ASH Capital’s events, or when you contact your relationship manager. ASH Capital may use this information in combination with other information ASH Capital collects about you. You are free to choose whether to provide ASH Capital with the types of personal information described below, but ASH Capital may not be able to serve you as effectively or offer you some or all of ASH Capital’s Services when you choose not to share certain information with ASH Capital. 

Here are some examples of the types of personal information ASH Capital collects and how ASH Capital may use it: 

  • When you become a Client of ASH Capital (or its subsidiaries, respectively), ASH Capital or ASH Capital’s external service provider may collect personal information. The following information may be collected: your name, date of birth, driver number, personal ID or passport, address, phone, email, full bank account details, tax or corporate identification number, company legal status, information that ASH Capital needs for establishing the controlling person of operating legal entities and partnerships or regarding the identity of the beneficial owner of non-operating entities or information regarding individuals with signatory powers (first and last name, address, email, curriculum vitae), or authorised traders (first and last name, nationality, date of birth, etc.). ASH Capital will use this information to fulfil your requests and provide the relevant Services.

  • Whenever you contact ASH Capital or respond to ASH Capital’s communications (e.g., email, telephone, in writing), ASH Capital will receive your contact information and any other personal information you choose to provide ASH Capital. ASH Capital will use such information to fulfil your requests or to provide Services.

How personal information is used 
ASH Capital’s primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, ASH Capital uses personal information to create, develop, operate, deliver, and improve ASH Capital’sServices, content and advertising, and for loss prevention and anti-fraud purposes. 
Examples of how ASH Capital may use this information include:

  • •To provide you with ASH Capital Services and the client support that you request.
  • To process transactions and send notices about your transactions.
  • To verify your identity by comparing your personal information against third-party databases.
  • To send administrative or account-related information to you.
  • To better understand ASH Capital’s clients and the way they use and interact with ASH Capital-owned and/or ASH Capital-operated websites and Services.
  • To provide a personalised experience, and to implement the preferences that you request.
  • To customise, measure, and improve ASH Capital and the content and layout of ASH Capital’s website and applications.
  • To enhance security, prevent fraud, monitor, and verify identity or service access, and combat spam or other malware or security risks.
  • To deliver marketing, service update notices, and promotional offers based on your communication preferences.
  • To communicate with you about ASH Capital’s events and/or ASH Capital’s partner events.
  • To prevent and investigate potentially prohibited or illegal activities, and/or violations of ASH Capital’s posted user terms.
  • To resolve disputes, collect fees, and troubleshoot problems.
  • To comply with legal obligations.
  • To enforce ASH Capital’s agreements with third parties.

ASH Capital will not use your personal information for purposes other than those ASH Capital has disclosed to you without your permission. From time to time, ASH Capital may request your permission to allow ASH Capital to share your personal information with third parties. You may choose not to have your personal information shared with third parties where ASH Capital relies on consent as the lawful basis for processingyour personal information. You may also choose not to allow ASH Capital to use your personal information for any purpose that is incompatible with the purposes for which ASH Capital originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or ASH Capital Services may not be available to you. 

Information from third-party sources
From time to time, ASH Capital may obtain information about you from third-party sources as permitted by applicable law, such as public databases and ID verification partners: ASHCapital obtains information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publically available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. 

The legal basis for such processing is to comply with ASH Capital’s legal obligations, such as anti-money laundering laws. In some cases, ASH Capital may process additional data about you based on public interest grounds to ensure ASH Capital’s Services are not used fraudulently or for other illicit activities. ASH Capital also processes such information to provide support to you as part of ASH Capital’s contractual obligations to you. Lastly, ASH Capital processes such information in the public interest because it helps ASH Capital monitor, prevent, and detect fraud. Once ASH Capital obtains such information from third parties, ASH Capital will not subsequently share it with any other third parties except as described in this Privacy Policy. This information is shared with ASH Capital’s processors and corporate group, as necessary, to perform the Services. 

Collection and use of information collected automatically
ASH Capital receives and stores certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer), and yourInternet Protocol (IP) address/MAC address/device identifier. For example, ASH Capital automatically receives and records information on ASHCapital’s server logs from your browser, including how you came to and used theServices; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g., country or city-level location), and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. ASHCapital may also collect information about how your device has interacted with ASHCapital’s website, including pages accessed and links clicked. ASH Capital may use identifiers to recognise you when you arrive at the website via an external link, such as a link appearing on a third-party site. Please refer to the ASH Capital Cookie Policy (https://ashcapital.org/cookie-policy) for more information about ASH Capital’s use of cookies. 

How ASH Capital protects and stores personal information
ASH Capital understands how important your privacy is, which is why ASH Capital maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to ASH Capital. ASH Capital may store and process all or part of your personal and transactional information, including certain payment information, in Switzerland, and elsewhere in the world, where ASH Capital’s service providers are located. ASH Capital protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations. For example, ASH Capital uses computer safeguards such as firewalls and data encryption, ASH Capital enforces physical access controls to ASH Capital’sbuildings and files, and ASH Capital authorises access to personal information only for those employees who require it to fulfil their job responsibilities. However, ASH Capital cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. 

When registering with ASH Capital’s Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to notify ASH Capital immediately if you become aware of any unauthorised access to or use of your account. Furthermore, ASH Capital cannot ensure or warrant the security or confidentiality of the information you transmit to ASH Capital or receive from ASHCapital by Internet or wireless connection, including email, phone, or SMS, since ASH Capital has no way of protecting that information once it leaves and until it reaches ASH Capital. If you have reason to believe that your data is no longer secure, please contact ASH Capital at the email address, mailing address, or telephone number listed at the end of this Privacy Policy. 

How ASH Capital protects and stores personal information
ASH Capital takes care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it. ASH Capital will never sell or rent your personal information. ASH Capital will only share your data in the following circumstances: 

  • ASH Capital may share your information with service providers under contract who help with parts of ASH Capital’s business operations such as marketing and technology services. ASH Capital’s contracts require these service providers to only use your information in connection with the services they perform for ASH Capital and prohibit them from selling your information to anyone else. 
  • ASH Capital shares your information with financial institutions with which ASH Capital partners to process payments you have authorised. 
  • ASH Capital may share your information with companies, or other entities that ASH Capital plans to merge with or be acquired by. Should such a combination occur, ASH Capital will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies. 
  • ASH Capital may share your information with any third parties where required to do so by applicable law or any court or other authority to which ASH Capital is subject in any jurisdiction; or ASH Capital believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the ASH Capital Agreements and any other applicable policies. 
  • ASH Capital may share your information with other third parties with your consent or direction to do so.


How ASH Capital shares personal information with other parties You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting your relationship manager. However, this right is limited where personal information is needed for regulatory purposes. If you decide to end your client relationship, ASH Capital will mark your account in ASH Capital’s database as “Closed,” but will keep your account information in ASH Capital’s database for a period of time as allowed by applicable law. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by ASH Capital for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy. 

Rights in relation to the use of your personal information
You have a right of access to the personal information that ASH Capital holds about you under the Federal Act on Data Protection (and the General Data Protection Regulation) and to some related information. You can also require any inaccurate personal information to be corrected or deleted. You can object to ASH Capital’s use of your personal information for direct marketing purposes at any time, and you may have the right to object to ASH Capital’s processing of some or all of your personal information (and require them to be deleted) in some other circumstances. 
If you wish to exercise any of these rights, please contact ASH Capital as set out below. 

Retention of personal information
ASH Capital will retain your personal data for as long as is necessary for the purposes of ASH Capital’s business relationship with you, to perform ASH Capital’s contractual obligations to you, or if longer, as required for legal and regulatory purposes. ASH Capital has established internal policies for the deletion of data from client accounts following the termination of a client’s subscription to a Service. 

Changes to this privacy policy ASH Capital may periodically post changes to this Privacy Policy on this page. ASH Capital encourages you to visit this page often. When required by law, ASH Capital will notify you of any changes to this Privacy Policy. If ASH Capital makes any material changes ASHCapital will notify you by email (sent to the email address specified in your account), or by means of a notice on ASH Capital’s Services prior to the change becoming effective. 

How to contact us
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you may contact at any time your client relationship manager at investors@ashcapital.org, or you may contact ASH Capital via info@ashcapital.org