1. Consent

Please read the following legal notices/terms of use (“Terms of Use”) carefully before accessing the website of ACM Alpstein Capital Management AG (hereinafter: ACM). By accessing the ACM website, you indicate that you have understood and accepted the Terms of Use in their entirety. If you do not understand or accept any one or more provisions of the Terms of Use, we kindly ask you to leave the ACM website.

2. Limited Access

The ACM website is targeted at regional banks from Germany, Austria and Switzerland as well as professional investors from Switzerland and the EEA. Individuals and legal entities who, in particular due to their nationality and/or place of residence, are subject to a legal system which prohibits the publication of the content of the ACM website or access to the ACM website - for whatever reason - may not access the ACM website. Persons to whom these restrictions apply are prohibited from accessing the ACM website. This particularly applies to people from the USA, Cayman Islands, UK, Canada, China, Japan and Singapore.

3. No Offer

The information and opinions published on the ACM website do not constitute a recommendation, solicitation, offer or invitation to offer (1) to purchase or sell investment instruments, (2) to carry out other transactions, or (3) to enter into any other Legal transactions. They serve informational and advertising purposes only. It cannot be ruled out that the investment instruments and services described are not suitable or not available for you.

4. No Advice

The information and opinions published on the ACM website do not serve as investment advice and in no way constitute advice on legal, tax, economic or other matters. They are not suitable as a basis for decision-making. Before you decide to take any specific action, you should seek advice from a specialized expert. By publishing content on the website the provider does not enter into any contractual relationship with the user.

5. No Guarantee

ACM takes the greatest possible care in compiling information. The content of the ACM website is constantly updated and checked for accuracy. However, ACM and its cooperation partners provide no guarantee (either express or tacit) and make no representation regarding the correctness, accuracy, timeliness and completeness of the content published on the ACM website. ACM is under no obligation to update, remove from the ACM website or label any outdated information or opinions. The information and opinions contained on the ACM website are subject to change at any time without notice.

Furthermore, ACM assumes no responsibility and provides no guarantee that the functions on the ACM website will not be interrupted at any point or are error-free, that defects will be corrected, or that the ACM website and the servers from which the content can be accessed are free of malware.

In principle, no conclusions can be drawn about the future performance from the development of the value of an investment instrument in the past. Investments in foreign currencies are also subject to exchange rate fluctuations. The distributions associated with an investment vehicle can also vary. ACM provides no guarantee as to (1) the appreciation or maintenance of value of capital invested in investment instruments and (2) the amount of future distributions.

All data available through this website, including but not limited to financial market data, price data, reports, research, or other financial information, are based on sources that are considered reliable and have been carefully selected. All available information is provided to the user “as is” and without any representations or warranties, express or implied, as to quality, originality, infringement of intellectual property rights or fitness for a particular purpose.

6. No Liability

ACM assumes no liability or guarantees that the information provided on its website is up-to-date, correct or complete. To the extent permitted by law, all liability of ACM for direct, indirect or consequential damages, including loss of profits, arising from information provided on the ACM website or which is directly or indirectly related to the use of the ACM website and the information contained therein is excluded.

7. No Orders

The input fields contained on the ACM website are not available for placing orders (e.g. orders to buy/sell investment instruments) to ACM. Orders placed in this way are viewed by ACM as meaningless - even without corresponding feedback to the sender - and no effective contract is concluded with ACM.

8. Property, Copyright, and Trademark Rights

All trademarks and logos on the ACM website are protected by intellectual property rights and are the property of ACM or third parties. Downloading or printing elements of the ACM website does not transfer any rights, in particular no rights relating to software and trademarks. Copyright notices and trademarks may not be changed or removed. Full or partial reproduction of elements of the ACM website, regardless of form (especially electronic or printed), is only permitted if the source is quoted holistically.

9. Links to Other Websites

By using a link, you may leave the ACM website to other providers' websites (so-called "external links") and their content. Links to third-party websites on the ACM website are provided by ACM in addition to its own content for user-friendliness and information purposes only. ACM has no control over the content of such third-party websites and assumes no responsibility for their correctness, accuracy, completeness, truthfulness, currency or suitability for any particular purpose. Any liability on the part of ACM, in particular for any direct or indirect damages or consequences arising from the use of the content of third-party websites, is excluded. ACM has no influence over the content of the linked pages and therefore, despite careful selection, assumes no liability for the content of external links, especially for those that were changed after the link was created.

In addition, ACM does not guarantee that such websites or their content will not give rise to copyright or trademark claims or other infringements of the rights of third parties, nor that such websites or their content are free of malware. No guarantee is given for the authenticity of documents on the Internet.

10. Changes to the Terms of Use

ACM reserves the right to change these Terms of Use from time to time. We therefore ask you to read these terms of use each time you access the ACM website and to check whether you also agree to the new version. If you do not understand or accept one or more provisions of the current Terms of Use, we ask you to leave the ACM website.

11. Legal Validity of the Liability Exclusions

The aforementioned exclusions of liability are to be viewed as part of the Internet offering from which reference was made to this page. If parts or individual formulations of this text do not, no longer or do not completely correspond to the applicable legal situation, the remaining parts of the document remain unaffected in their content and validity.

12. Applicable Law / Place of Jurisdiction

User access and use of the site as well as the terms of use for all customers are subject to Swiss law with the place of jurisdiction in St. Gallen.

Compliance with data protection laws, namely the Federal Data Protection Act (DSG) and the associated regulation (VDSG), the EU General Data Protection Regulation (GDPR) and thus the protection and confidentiality of your personal data is an important concern for ACM Alpstein Capital Management AG ( ACM). This privacy policy informs you about how our company collects and handles personal data in our role as controller and in particular sets out what rights you have in relation to personal data.

1. General

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the legal provisions of Switzerland and the EEA. By means of this data protection declaration, our company would like to provide information about the type, scope and purpose of the personal data we collect, and its use and processing. Furthermore, data subjects are informed about the rights to which they are entitled using this data protection declaration.

2. Definitions

The ACM data protection declaration is based on the terms used by the European legislator for directives and regulations when issuing the General Data Protection Regulation.

We use the following terms, among others, in this data protection declaration:

2.1. Personal Data
Personal data is all information that relates to an identified or identifiable natural person (hereinafter “data subject”). A natural person is considered to be identifiable, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

2.2. Affected person
The data subject is any identified or identifiable natural person whose personal data is processed by the person responsible for processing.

2.3. Processing
Processing is any operation or series of operations carried out on personal data, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or modification, reading, querying, use, disclosure by transmission, distribution or other form of provision, comparison or association, restriction, deletion or destruction.

2.4. Restriction of Processing
Restriction of processing is the marking of stored personal data with the objective of restricting their future processing.

2.5. Profiling
Profiling is any type of automated processing of personal data which consists of using these personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, analyze or predict that natural person's personal preferences, interests, reliability, behavior, location or movements.

2.6. Recipient
The recipient is a natural or legal person, public authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, authorities which may receive personal data in the context of a specific investigative task in accordance with Union or Member State law shall not be deemed to be recipients.

2.7. Third Party
Third party is a natural or legal person, authority, institution or other body other than the data subject, the controller, the processor and the persons who are authorized to process the personal data under the direct responsibility of the controller or the processor.

2.8. Consent
Consent is any voluntary, informed and unambiguous expression of wishes given by the data subject for the specific case in the form of a statement or other clear confirmatory act by which the data subject indicates that he or she agrees to the processing of the personal data.

3. Name and address of the person responsible or who you can contact

The person responsible or responsible for processing is the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.

The person responsible by the definition of the General Data Protection Regulation is:

Alpstein Capital Management AG
Bahnhofplatz 4 CH – 9430 St. Margrethen
Tel. 071-5207588
Mail: info(at)alpsteincapital.com
Responsible for Data Protection: Dr. Christof Grabher

4. Framework of Data its origin

4.1. Categories of Processed Data and Source
We collect and process personal data that we receive as part of our business relationship with our customers. In principle, as little personal data as possible is processed. Depending on the group of people, the data processed may differ. Personal data can be collected or (further) processed in every phase of the business relationship, from the initiation of the business relationship to the termination of the business relationship.

In addition to customer data, we may also process personal data from other third parties involved in the business relationship.

By personal data we mean the following data categories:


• Personal details
• Legitimation and authentication data
• Information from fulfilling our legal obligations
• Other master data
• Data from the fulfillment of contractual obligations
• Information about financial situation and professional background
• Documentation data
• Marketing data
• Technical data
• Information from your electronic communication with our company
• Data from publicly available sources

We process personal data from the following sources:


• Personal data that we receive from you via submitted contracts, forms, correspondence or other documents.
• Personal data that is generated or transmitted due to the use of products or services.
• Personal data that is lawfully transmitted to us by third parties, by public bodies (e.g. UN and EU sanctions lists) or by other companies (e.g. to carry out orders or fulfill contracts).
• Personal data - to the extent necessary for the provision of our service - which we have lawfully obtained from publicly available sources or other sources, such as databases for checking and monitoring business relationships.

4.2. Legal Basis and Purposes for Processing Personal Data
We process personal data in accordance with the provisions of the GDPR on the following legal basis and for the following purposes:

1. To fulfill a contract or to carry out pre-contractual measures. If the processing of personal data is necessary to fulfill a contract (such as the provision of consulting services) to which the data subject is a party, the processing is based on Art. 6 Para. 1 lit. b GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our services.

2. To fulfill legal obligations
If our company is subject to a legal obligation that requires the processing of personal data, such as to comply with tax, regulatory or money laundering obligations, the processing is based on Article 6 (1) (c) GDPR.

3. To protect legitimate interests
Processing operations can also be based on Article 6 Paragraph 1 Letter f of the GDPR. Processing operations that are not covered by any of the above-mentioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that your interests, fundamental rights and freedoms do not predominate. Such legitimate interests include, in particular, the following processing activities:

• Prevention of fraud
• Direct mail
• Transfer of data within a group of companies for internal administrative purposes
• Ensuring network and information security
• Prevention of possible crimes

We also collect personal data from publicly accessible sources for the purpose of customer acquisition.

4. Based on your consent
Art. 6 Para. 1 lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose.

4.3. Use and Storage of Your Personal Data

1. Data disclosure
Both internal and external entities may have access to your data. Within the company, only departments or employees who need the data to fulfill our contractual and legal obligations and to safeguard legitimate interests may process it.

Your data may be accessed from within and outside our company. Within the company, only departments or employees may process your data, if they need it to fulfill our contractual and legal obligations and to protect legitimate interests. If business areas and services of the company are outsourced or provided in whole or in part to external service providers, this will be done in accordance with the applicable legal provisions. All external service providers or vicarious agents to whom personal data is transmitted are contractually obliged to maintain data protection, to process your data only within the scope of providing the service and to comply with data protection instructions and legal requirements. Processors can be companies in the categories of banking services, advisory and distribution agreements, IT services, logistics, printing services, telecommunications, debt collection, advice and consulting as well as sales and marketing.

2. Data deletion and storage
We process and store your personal data for the duration of the entire business relationship, i.e. from the initial initiation to the termination of the contract. After termination of a contract and therefore the purpose of storage no longer applying, the duration of storage is determined based on legal retention and documentation obligations.

3. Automated decision-making, including profiling
In principle, our decisions are not based on exclusively automated processing of personal data. In particular, we generally do not use automated decision-making to establish and implement the business relationship. We also do not use profiling measures.

5. Rights and Obligations

5.1. Available Privacy Rights

1. Right to confirmation
You have the right to request confirmation as to whether personal data concerning you is being processed. If you would like to exercise this right of confirmation, you can contact the person responsible at any time.

2. Right to information
You have the right to receive free information about the personal data stored about you and a copy of this information at any time. This right to information includes the following information:

• the processing purpose
• the categories of personal data that are processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
• if possible, the planned period for which the personal data will be stored or, if this is not possible, the criteria for determining that period
• the existence of a right to rectification or deletion of personal data concerning you or restriction of processing by the controller or a right to object to this processing
• the existence of a right to lodge a complaint with a supervisory authority
• if the personal data is not collected from the data subject, all available information about the origin of the data
• the existence of automated decision-making including profiling in accordance with Article 22 Paragraphs 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject

You also have the right to information as to whether personal data has been transmitted to a third country or to an international organization. If this is the case, you also have the right to receive information about the appropriate guarantees in connection with the transmission.

If you would like to exercise this right to information, you can contact the person responsible at any time.

3. Right to correction
You have the right to request that incorrect personal data concerning you be corrected immediately. You also have the right, taking into account the purposes of the processing, to request the completion of incomplete personal data - including by means of a supplementary declaration.

If you would like to exercise this right to correction, you can contact the person responsible at any time.

4. Right to erasure
You have the right to have the personal data concerning you deleted immediately, if one of the following reasons applies and the processing is not necessary:

• The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
• You have withdrawn your consent on which the processing was based in accordance with Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR, and there is no other legal basis for the processing.
• You object to the processing in accordance with Art. 21 Para. 1 GDPR, and there are no overriding legitimate reasons for the processing, or you object to the processing in accordance with Art. 21 Para. 2 GDPR.
• The personal data was processed unlawfully.
• The deletion of personal data is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.

If one of the reasons mentioned above applies and you would like to have personal data stored by our company deleted, you can contact the person responsible at any time. This will ensure that the deletion request is complied with immediately.

5. Right to restriction of processing
You have the right to request restriction of processing if one of the following conditions applies:

• The accuracy of the personal data is contested for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, but you refuse to delete the personal data and instead request that the use of the personal data be restricted.
• The controller no longer needs the personal data for the purposes of processing, but you need the personal data to assert, exercise or defend legal claims.
• You have lodged an objection to the processing in accordance with Article 21 Para. 1 GDPR, and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.

If one of the above conditions is met and you would like to request the restriction of personal data stored by our company, you can contact the person responsible at any time. The person responsible will arrange for the processing to be restricted.

The correction or deletion of the data or a restriction of processing will be communicated to the recipients to whom personal data has been disclosed. This obligation to notify does not apply if this proves to be impossible or involves disproportionate effort.

6. Right of withdrawal
You have the right to revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued before the GDPR came into force, i.e. before May 25, 2018. Please note that the revocation will only take effect in the future. Processing that took place before the revocation is not affected by this. If you would like to exercise your right to revoke your consent, you can contact the person responsible at any time.

7. Right to Data Portability
You have the right to receive the personal data relating to you, which you have provided, in a structured, commonly used and machine-readable format. You also have the right to have this data transmitted to another person responsible, by the person responsible to whom the personal data was provided, only if the processing is based on consent in accordance with Article 6 (1) (a or b) GDPR or Article 9 (2). lit and the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

To assert your right to data portability, you can contact the person responsible at any time.

8. Right to Object
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is carried out on the basis of Article 6 Paragraph 1 Letter f of the GDPR.

Our company will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing for the establishment, exercise or defense of legal claims serves.

If our company processes personal data in order to conduct direct advertising, you have the right to object at any time to the processing of personal data for the purpose of such advertising. If you object to our company processing it for direct advertising purposes, we will no longer process your personal data for these purposes.

5.2 Exercise of Rights
We accept requests for information in writing, along with a legible copy of a valid official ID (e.g. passport, identity card, driving license).

You can exercise further rights, such as the right to rectification, the right to deletion, the right to restrict processing and – where applicable – the right to data portability by sending us a corresponding message. Please address this notification to the person responsible within the meaning of the GDPR at point 3.

6. You have the right to lodge a complaint with a supervisory authority in Switzerland, in an EU or EEA member state, in particular at your place of residence, place of work or at the place of the alleged violation of the provisions of the GDPR.

7. Obligation to Provide Personal Data

We would like to clarify that the provision of personal data is partly required by law (e.g. tax regulations, money laundering prevention, etc.) or can also result from contractual provisions (e.g. information on the contractual partner). In order to conclude a contract, it may sometimes be necessary for you to provide us with personal data, which must subsequently be processed by us. For example, you are required to provide us with personal data when our company enters into a contract with you. Failure to provide personal data would mean that the contract could not be concluded.

You are not obliged to give your consent to data processing regarding data that is not relevant for the fulfillment of the contract or is not required by law and/or regulations.

8. Contact Form and Contact via Email

Our company's website contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If you contact our company by email or via a contact form, the personal data you provide will be saved automatically. Such personal data transmitted on a voluntary basis will be stored for processing or contact purposes. This personal data will not be passed on to third parties.

9. Information on the Use of Cookies

When accessing our website, the user is informed about the use of cookies for analysis purposes, and his consent to the processing of the personal data used in this context is obtained. In this context, a reference is also made to this data protection declaration.

9.1. Why are Cookies Used?
All of our company's websites use cookies for statistical purposes and to improve the user experience. By using this website, you agree to the use of cookies for this purpose.

9.2. What are Cookies?
Cookies are text files stored on your electronic device to track your use of electronic services and your preferences when navigating between websites and, if necessary, to save settings between visits. Cookies help the developers of electronic services to compile statistical information about the frequency of visits to certain areas of the website and help them to make the electronic services even more useful and user-friendly. A cookie contains a characteristic string that allows the browser to be uniquely identified when the website is accessed again.

Please note that most internet browsers automatically accept cookies. You can configure your browser so that no cookies are stored on your electronic device, cookies can only be accepted by certain websites or you always receive a notification before you receive a new cookie. If cookies are deactivated for our website, it may no longer be possible to fully use all functions of the website.

Through our website we inform our customers and interested parties about our company's services and products and provide information on specific topics. Contact options with us such as directions, telephone number and email address, etc. are also published on our website.