DYSON DRAKE & CO AG - Privacy Policy

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 Last updated: February 2026

Dyson Drake & Co AG (“Dyson Drake”, “we”, “us”, or “our”) is committed to protecting the privacy of our clients, prospective clients, professional contacts, and website users. This Privacy Policy explains how we collect, use, disclose, and protect personal information in the United Kingdom, the European Economic Area (“EEA”), and the United States.

If you have any questions, please contact us using the details in the “Contact us” section below.

1. Who we are and how to contact us

Controller
Dyson Drake & Co acts as a data controller when we determine the purposes and means of processing your personal information (for example, in providing our advisory services or managing our client relationships).

Dyson Drake & Co AG
Alpenstrasse 12
6300 Zug
Email: daniel.webb@dysondrake.ch

Where required under UK and EU law, we may appoint a data protection officer (DPO) or local representative. Their details, where applicable, will be published here or made available on request.

2. What information we collect

We may collect and process the following categories of personal information, depending on our relationship with you and the services we provide: 

• Identification details (name, title, date of birth, national identifiers where required,      KYC/AML documentation).
• Contact details (postal address, email address, telephone numbers).
• Professional information (role, employer, regulatory status, adviser details).
• Financial and investment information (portfolio details, asset holdings, transaction history, risk profile, investment objectives).
• Compliance information (KYC/AML checks, sanctions screening results, source‑of‑funds/source‑of‑wealth information, records required by law).
• Usage      data (information about how you use our website or services, including IP address, browser type, and pages visited, generally collected via cookies or similar technologies).
• Communication data (records of emails, calls, meeting notes, and other correspondence).

We do not intend to collect special categories of personal data (such as health or political opinions) unless strictly necessary and permitted by law. Where we do, we will rely on an appropriate legal basis and additional safeguards.

3. How we collect your information

We collect personal information in the following ways:

• Directly from you, for example when you:
  • engage us to provide services,
  • communicate with us by email, phone, or in person,
  • complete forms on our website or provide documents for KYC/AML purposes.
• From third parties, such as:
  • your professional advisers (lawyers, accountants, investment managers),
  • financial institutions or product providers,
  • KYC/AML and sanctions screening providers,
  • public sources (e.g. company registers, regulatory registers, publicly available databases).
• Automatically when you interact with our website, through cookies and similar technologies (see “Cookies and similar technologies”).

4. Purposes and legal bases for processing (UK and EU/EEA)

Where UK and EU data protection law applies, we process personal information only when we have a lawful basis. Depending on the context, we may rely on: 

• Performance of a contract: To provide our advisory services, manage your account, respond to requests, and take steps at your request before entering into a contract.
• Legal obligations: To carry out KYC/AML checks, comply with financial services regulation, tax, reporting, and record‑keeping requirements.
• Legitimate interests: To manage and develop our business, maintain relationships with clients and professional contacts, improve our services, secure our IT systems, and prevent fraud, provided these interests are not overridden by your rights and freedoms.
• Consent: Where required (for example, certain marketing communications or optional      cookies). You can withdraw your consent at any time using the contact details below or by using opt‑out mechanisms in our communications. 

We will clearly indicate at the point of collection which lawful basis applies where required by law.

5. How we use your information

We use personal information for the following purposes:

• Providing and managing our advisory and related services.
• Assessing suitability and appropriateness of life wrappers and related structures.
• Performing KYC/AML and other compliance checks.
• Managing our relationships with clients, prospective clients, and professional advisers.
• Responding to enquiries and providing client support.
• Operating, maintaining, and improving our website and IT systems.
• Sending regulatory, service, and administrative communications.
• Sending marketing communications (where permitted by law and subject to your  preferences).
• Complying with legal, regulatory, and risk management obligations and co‑operating with regulators and authorities. 

6. Sharing your information

We may share personal information with: 

• Service providers who process data on our behalf (for example IT hosting, cloud services, CRM providers, document management, communications tools).
• Professional  advisers (lawyers, accountants, tax advisers, investment managers)  involved in your matters, as instructed or agreed with you.
• Financial institutions, product providers, custodians, and insurers where necessary to provide our services.
• Compliance and screening providers for KYC/AML, sanctions, and fraud prevention.
• Regulators, supervisory authorities, tax authorities, courts, or law enforcement where required by law or where necessary to establish, exercise, or defend legal claims.
• Any third party to whom we may assign or transfer our rights or obligations as part of a reorganisation, merger, or business transfer, to the extent permitted by law. 

We require third‑party service providers to process personal information only in accordance with our instructions, under appropriate confidentiality and security obligations. 

7. International transfers

Because we operate and have clients and counterparties in multiple jurisdictions, your personal information may be transferred to, and processed in, countries outside the UK and EEA, including the United States. 

Where such transfers occur and the destination country is not subject to an adequacy decision, we will put in place appropriate safeguards, such as:

• Standard contractual clauses approved by the UK or EU authorities,
• Additional contractual and organisational protections where required,
• Data minimisation and encryption where appropriate.

You may contact us for more information or to obtain a copy of the relevant safeguards. 

8. Data retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, or reporting requirements.

Retention periods may vary depending on the type of data and our regulatory obligations (for example, minimum record‑keeping periods under financial services and anti‑money‑laundering regulations). When information is no longer required, we will delete or anonymise it in line with our data retention policy. 

9. Your rights (UK and EU/EEA residents)

If you are in the UK or EEA, you have certain rights in relation to your personal information under UK GDPR and EU GDPR, subject to conditions and exceptions. These may include:

• Right of access to your personal information.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure (“right to be forgotten”) in certain circumstances.
• Right to restriction of processing in certain circumstances.
• Right to data portability (to receive your data in a structured, commonly used format and transmit it to another controller where technically feasible).
• Right to object to processing based on legitimate interests, and to direct marketing.
• Where we rely on consent, the right to withdraw that consent at any time. 

You can exercise these rights by contacting us using the details below. We may need to verify your identity before responding. You also have the right to lodge a complaint with your local data protection authority, such as: 

• In the UK: the Information Commissioner’s Office (ICO).
• In the EEA: your local supervisory authority (details are available on the European Data Protection Board website).

10. Rights of US residents (including California and other state laws)

Depending on the US state in which you reside, you may have additional rights under applicable privacy laws (for example, the California Consumer Privacy Act (CCPA) and similar laws in other states). These may include: 

• The right to know what categories of personal information we collect, use, disclose, and, where applicable, sell or share.
• The right to access specific pieces of personal information we hold about you.
• The right to request deletion of your personal information, subject to legal exemptions.
• The right to correct inaccurate personal information.
• The right to opt out of certain uses of your personal information (such as “sale” or “sharing” for cross‑context behavioural advertising, if applicable).
• The right not to be discriminated against for exercising your privacy rights. 

We do not sell personal information for money in the ordinary sense. If we engage in activities that are considered a “sale” or “sharing” under applicable US law, we will provide additional disclosures and opt‑out mechanisms as required. 

US residents may exercise their rights by contacting us using the details below. We will respond as required by applicable law and may request information to verify your identity.

11. Cookies and similar technologies

Our website may use cookies and similar technologies to:

• Make  the site function properly and securely.
• Understand how visitors use our website.
• Improve performance and user experience.

Where required by law, we will ask for your consent before using non‑essential cookies (for example, analytics or advertising cookies). You can manage your cookie preferences via your browser settings or any cookie management tools we provide. 

For more detail, please see our separate Cookie Policy, if available.

12. Security

We take appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, destruction, or damage. These measures may include access controls, encryption, secure storage, and regular review of our information security practices. 

No system can be completely secure, but we work to ensure that the level of protection is appropriate to the risks associated with the personal information we process. 

13. Children’s privacy

Our services are directed at professional and adult clients. We do not knowingly collect personal information from children under the age of 16, and we ask that such individuals do not provide personal information to us. If you believe a child has provided us with personal information, please contact us so that we can delete it where appropriate. 

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect changes in law, regulation, or our business practices. When we do, we will revise the “Last updated” date above and, where appropriate, provide additional notice.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. Contact us

If you have any questions about this Privacy Policy or how we handle personal information, or if you wish to exercise your rights, please contact us at:

Dyson Drake & Co AG
Alpenstrasse 12
6300 Zug
Email: daniel.webb@dysondrake.ch

 

If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority as described above.