Privacy Policy
Last updated: January 2026
Hummingbird Capital Partners AG ("HCP", "we", "us", or "our"), domiciled in Zürich, Switzerland, is committed to protecting your privacy and personal data in accordance with the Swiss Federal Act on Data Protection (FADP/DSG) and, where applicable, the EU General Data Protection Regulation (GDPR).
1. Data Controller
The data controller responsible for the processing of your personal data is:
Hummingbird Capital Partners AG
c/o Hummingbird Services GmbH
Talacker 21
CH-8001 Zürich
Email: [email protected]
2. Categories of Personal Data Collected
We may collect and process the following categories of personal data:
- Contact Information: Name, email address, telephone number, postal address
- Professional Information: Company name, job title, professional qualifications
- Communication Data: Content of correspondence and inquiries
- Technical Data: IP address, browser type, device information, access times
- Usage Data: Information about how you use our website
3. Purposes of Data Processing
We process your personal data for the following purposes:
- Responding to your inquiries and providing requested information
- Providing our investment advisory and fund administration services
- Complying with legal and regulatory obligations (including AML/KYC requirements)
- Improving our website and services
- Sending relevant communications about our services (with your consent)
- Protecting our legitimate business interests
4. Legal Basis for Processing
We process your personal data based on the following legal grounds under the FADP:
- Consent: Where you have given explicit consent for specific processing activities
- Contractual Necessity: Processing necessary for the performance of a contract or pre-contractual measures
- Legal Obligation: Processing necessary for compliance with Swiss law
- Legitimate Interests: Processing necessary for our legitimate business interests, provided these do not override your fundamental rights
5. Data Recipients and Transfers
We may share your personal data with the following categories of recipients:
- Service providers who assist us in operating our business (under appropriate data processing agreements)
- Professional advisors (lawyers, auditors, accountants)
- Regulatory authorities and government bodies where required by law
- Business partners involved in providing our services
Where personal data is transferred outside Switzerland, we ensure appropriate safeguards are in place, including adequacy decisions by the Swiss Federal Data Protection and Information Commissioner (FDPIC) or standard contractual clauses.
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. Retention periods are determined based on:
- The nature of the data and the purposes for which it is processed
- Legal and regulatory retention requirements (typically 10 years for financial records under Swiss law)
- Statute of limitations for potential legal claims
7. Your Rights
Under the Swiss FADP, you have the following rights regarding your personal data:
- Right of Access: You may request information about the personal data we hold about you (Art. 25-27 FADP)
- Right to Data Portability: You may request your data in a machine-readable format (Art. 28-29 FADP)
- Right to Rectification: You may request correction of inaccurate personal data
- Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements
- Right to Object: You may object to processing based on legitimate interests
- Right Against Automated Decisions: You have the right not to be subject to decisions based solely on automated processing (Art. 21 FADP)
To exercise any of these rights, please contact us at [email protected].
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, and regular security assessments.
9. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance your browsing experience and analyse website usage. You can manage your cookie preferences through your browser settings. Essential cookies required for website functionality cannot be disabled.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website with a new "Last updated" date.
11. Contact and Complaints
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:
Email: [email protected]
Address: c/o Hummingbird Services GmbH, Talacker 21, CH-8001 Zürich
You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) if you believe your data protection rights have been violated:
Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
CH-3003 Bern, Switzerland
Website: www.edoeb.admin.ch
Governing Law
This Privacy Policy is governed by Swiss law. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Zürich, Switzerland.
