DMS Capital AG is a member firm of Organisme d’Autorégulation des Gérants de Patrimoine ("OAR-G") and as such is monitored by OAR-G in its capacity as an SRO (Self Regulatory Organization) officially recognized by the Swiss Financial Market Supervisory Authority (FINMA), with dual supervision pursuant to (1) independent asset management and; (2) the Anti-Money Laundering Act (AMLA). The rules of professional conduct of OAR-G regulate the content of the asset management agreement and how it must be implemented (asset manager's duty of trust, information and due diligence towards the customer and regulation of the asset manager's compensation), with due attention aid to the protection of investors.
In this document, references to TitanPro refer to the digital platform TitanPro, its modules, programs and procedures, while references to DMS Capital AG refer to the swiss firm DMS Capital AG, its owners, directors, and employees.
“DPL” herein means data protection law applicable to TitanPro, including the Swiss Federal Act on Data Protection (CC 235.1 Federal Act of 19 June 1992 on Data Protection (FADP)) and the EU General Data Protection Regulation 2016/679, their successors or implementing texts. Personal Data" has the meaning set forth in DPL. This notice covers our use of your personal data arising from use of the TitanPro website (www.titanpro.ch) as well as registering / subscribing / buying / selling / using our products and services. If you have any questions or need any further clarity please get in touch. Contact details are set out below in the Contact Us section.
A. Personal Information We Collect
We collect the Personal Data you provide directly to us or which we generate when you open a TitanPro Account, perform any transactions on the TitanPro Platform, or use other TitanPro Services or our website. This may include:
We also automatically collect certain computer, device and browsing information when you access the TitanPro website or use TitanPro Services. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals. This information may include:
Finally, we may collect Personal Data from third party partners and public sources, which include:
It is important to note that the Personal Data we collect on you when you create an account will be retained for the mandatory retention period set forth by applicable law and as necessary for us to maintain an exhaustive documentation of our operations as required from us as regulated financial sector professionals, even if your account has not been successfully activated (e.g., if account verification has not been completed) or no transaction has been made using it.
We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information, as applicable. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.
If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or services, such as logging on to your TitanPro Account or making transactions. Your use of our website or service with a browser that is configure to accept cookies constitutes an acceptance of our and third-party cookies.
For more information about cookies, the types of cookies we use and how we use them please see our Cookie Statement.
C. How We Use Your Personal Information
We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract – for example your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers' identities.
Some information is processed because you've given your consent to that, which can be withdrawn in your account preferences and settings. Other information we collect and use because we have legitimate business interests to so, having taken into account your rights, interests and freedoms.
We may use your Personal Information to:
Automated Decisions Making
We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision will be reached automatically as to whether we are able to provide products or services to you based on your credit worthiness.
If you disagree with the decision you are entitled to contest this by contacting us at following email address: firstname.lastname@example.org.
We may also occasionally communicate company news, updates, promotions and related information relating to similar products and services provided by TitanPro. We may also administer a contest, promotion, survey or other site features as will be more explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under the DPL in pursuit of our legitimate interests (that is, promoting our services).
We may share personal data with third parties to help us with our marketing and promotional projects, or sending marketing communications.
If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from us [or our promotional partners] in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:
If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you reserve from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.
We may disclose your Personal Data to third parties and legal and regulatory authorities, and transfer your Personal Data outside the Switzlerland and the EEA, as described below.
A. Disclosures to Third Parties
There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.
Your personal data may be transferred to other third party organizations in certain scenarios:
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide TitanPro Services or as required by law.
TitanPro’s third party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms complying with DPL.
B. Disclosures to Legal Authorities
We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:
C. International Transfers of Personal Data
We store and process your Personal Data in data centers around the world, wherever TitanPro facilities or service providers are located. As such, we may transfer your Personal Data outside of Switzerland and the European Union. Some of the countries to which your personal data may be transferred for these purposes that are located outside the EU do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal data in that country. Details of these specific countries can be found here:.
Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under DPL will be implemented, such as standard data protection clauses with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.
You have certain rights concerning your Personal Data under DPL as mentioned below, and can exercise them by contacting us at email@example.com.
Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it to check that we are lawfully processing it. We process a large quantity of information, and can thus request, in accordance with the DPL, that before the information is delivered, you specify the information or processing activities to which your request relates.
Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Transfer: you may request the transfer of certain of your personal data to another party.
Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may challenge this. However we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes.
Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
You also have a right to lodge a complaint with a supervisory authority, in particular in the EU Member State where you reside, in Switzerland where we are based, or where an alleged infringement of Data Protection law has taken place. In Switzerland, you can make a complaint to The Federal Data Protection and Information Commissioner (FDPIC), which is the competent authority for data processing by federal bodies and private persons, including enterprises. As far as data processing by cantonal or communal authorities is concerned, the supervision is up to the cantonal and communal data protection commissioners. You can find all contact information by canton here:
We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to: (1) Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely; (2) Advanced Encryption Standard “AES 256 Bit” for (but not limited to): General account registration information, including personal sensitive data, etc. Full name, Date of birth, Personal living addresses, Email, Phone number; (3) AES 256 Bit and Password protected directories for TitanPro client database administrator access; (4) PCI Certified and AES 256 bit encrypted: Bank accounts, Credit cards, Crypto-related personal information, like wallet addresses, transaction hashes and transaction Id’s blockchain; (5) AES 256 Bit Closed-loop transaction information; (6) AES 256 Bit and Multilayer encryption technologies for the closed-loop transaction information.
All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized TitanPro personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.
You are responsible for keeping your account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us below as soon as possible.
In accordance with our record keeping obligations, we will retain Account and other Personal Data for at least five years (and some up to ten years, as required by applicable law) after an Account is closed.
DPL. means data protection law applicable to TitanPro, including the Swiss Data Protection Act, draft of September 2017, its successors or implementing texts as well as equivalent legislation, which is applies to the processing of Personal Data by TitanPro.
Personal Data. Information that identifies an individual, such as name, address, e-mail address, trading information, and banking details. Personal Data does not include anonymized and/or aggregated data that does not identify a specific user;
Service(s). The platform, functional rules and services provided by TitanPro.