The following clauses provide the visitor of the website, with explanations on how Carnegie Fund Services Limited, with its registered office at 11, rue du Général-Dufour, 1204 Geneva, Switzerland (“CFS”) processes personal data. To contact CFS, please visit: The processing of personal data encompasses the collection, storage, use, revision, disclosure, archiving and/or destruction of data and is done in compliance with the applicable data protection legislation.

1. Personal data collected by CFS

The term ‘personal data’ for the purpose of this disclaimer refers to any information relating to the visitor of the website. By visiting the website, the processed personal data will be the IP-address, country of residence, language chosen, the access date and time, the web browser and version used as well as the visited URL. If the visitor chooses to contact CFS by email, letter, phone or fax, personal data includes additionally the name, contact details, and all other data that the visitor has voluntarily provided. Personal data for the purpose of this privacy policy does not include anonymised data, this being data from which a visitor can no longer be identified.

2. Why personal data is collected

All personal data, such as the IP-address or country of residence, or in case of contact the full name or email address, is collected for the purposes of optimizing the navigation on the website or to answer queries.

3. How personal data is collected, used and retained

CFS collects personal data when a visitor navigates on the website or contacts us by letter, telephone, or contact form or any other means of electronic or personal communication, to the extent applicable law allows us to do so, i.e. if:

  • the visitor has provided his consent;
  • necessary to perform contractual obligations;
  • necessary to comply with legal obligations;
  • legitimate interests, which are not overridden by the visitors’ interests or fundamental rights and freedoms, allow for it.

The data will be processed and held by CFS in accordance with the Swiss Federal Act on Data Protection (“FADP”) of 19 June 1992 as amended, and the European Union General Data Protection Regulation (“GDPR”) of 27 April 2016 as amended, which entered into force on 25 May 2018.

All personal data collected by CFS is processed in Switzerland. The only exception concerns the transfer of data generated by cookies in relation with the use of Google Analytics. For further information, please refer to clause “8. Google Analytics” below.

For the improvement of services, and in the interest of security, communications between the visitor and CFS may be recorded and monitored. All recordings belong to CFS.

CFS will only use personal data for the purposes for which it was collected. If personal data has been anonymised and can no longer be associated with a person, it shall no longer qualify as personal data.

CFS strives to keep the data processing to a minimum. Personal data shall be held by CFS to fulfil the purposes for which it was collected and processed. Personal Data will only be retained for as long as necessary.

4. With whom data will be shared

Data will only be shared with selected business partners of CFS who adhere to the FADP resp. GDPR if this has to be done because of the query of a visitor having contacted us. These third parties will use the data only to fulfil the service rendered to CFS and not for their own purposes.

CFS will use its best efforts, not to transfer your data to a jurisdiction that is not recognized by the Federal Data Protection and Information Commissioner and the European Commission of granting adequate data protection. However, information about the use of the website generated by cookies (such as web browser and version used, IP address) is transmitted to a Google server in the United States and stored there (please refer to clause “8. Google Analytics” below).

5. Visitors’ rights in relation to collected data by CFS

A visitor may exercise individual rights in relation to personal data where applicable, namely to:

  • request information on how personal data and privacy is processed;
  • request to access personal data;
  • request the rectification of personal data;
  • request the removal of personal data (‘right to be forgotten’);
  • request the restriction of processing of personal data;
  • request and receive a copy of personal data (‘right to data portability’);
  • object to the processing of personal data;
  • withdraw consent for the processing of personal data;
  • under certain circumstances, lodge a complaint to the Office of the Federal Data Protection and Information Commissioner (“FDPIC”) or, as the case may be, any other competent supervisory authority of an EU member state, or another jurisdiction.

If a visitor wishes to exercise the above-mentioned individual rights, please contact the Data Protection Officer by means of our contact form.

6. Fees

While the exercise of any individual rights mentioned above will be free of charge, a reasonable fee may be exceptionally charged if such requests are manifestly unfounded or excessive. CFS may refuse to comply with the request under such circumstances.

7. Cookies

The website uses cookies and similar technologies. Cookies are a widely adopted method of helping site owners to improve the efficiency of their websites and gain information about how their sites are being used. A cookie is a small file containing letters and numbers that works by enabling your web browser (e.g. Microsoft Internet Explorer or another web browser) to remember certain information about your computer’s website use and to distinguish you from other visitors to a website.

The cookies that are used on the website can be categorised into the following groups:

  1. Cookies which aid navigation through the website and are essential for the website to work properly. These cookies may expire at the end of your browser session (i.e. when Microsoft Internet Explorer or another web browser is closed).
  1. Analytical’ cookies which enable the understanding on how visitors got to our website and use it (see also the provision below 8. Google Analytics). This information helps to improve the way works and to assist visitors in finding the content they need quickly. Some of these cookies only exist in the visitors’ current browser session whereas other cookies will last for a longer period, as they provide useful information about repeated visits to the website.
  1. 3. Cookies that improve Visitor experience but are not essential for the website to work. On the website, this type of cookie is used as a ‘remember me’ function.

None of the cookies used contain personal or confidential information and CFS will not attempt to identify visitors from this information. By accepting the use of cookies and similar technologies when navigating on the website or contacting CFS, the visitor agrees to the present Privacy Policy and the use of Cookies described herein. . A visitor can refuse cookies at any time, by altering the settings on the web browser in order to deactivate the use of cookies. Cookies can be cleared at any time using the settings in the web browser.

8. Google Analytics uses Google Analytics, a web analysis service of Google Inc. (« Google ») qui permet à un administrateur de site web d’analyser son audience. Through Google Analytics, dates, sessions and interactions can be allocated across several devices to one pseudonymous user ID and therefore analyse the activities of a user on several devices. The information sent to Google through this analysis service permits the anonymous evaluation of the use of, as well as the establishment of reports on the website activities.

Google Analytics also uses cookies. Information about the use of the website generated by cookies (such as web browser and version used, IP address) is transmitted to a Google server in the United States and stored there. In general, the IP-address is anonymized when transferred to a Google server in the United States. Exceptionally however the full IP-address may be transferred to a Google server in the United States.

9. Security of the personal data

CFS endeavours to ensure the security and integrity of the visitors’ personal data through adequate and reasonable technical measures.

10. Changes to the Privacy Policy

CFS may update the present Privacy Policy to reflect changes in legislation or due to the change of its data processing without any prior written notice. Where applicable, the visitor will however have to renew his consent to the change in the data processing.

The visitor agrees to review any and all of the applicable clauses of the Privacy Policy regularly and that his use of any part of this website will be immediately subject to any such changes once they are made, if his consent is not required for the concerned change.

11. Data Protection Officer

Queries in relation with the processing of personal data can be directed to the Data Protection Officer of CFS at the address below or by means of the contact form:

Carnegie Fund Services Ltd.
Rue du Général-Dufour 11
CH – 1204 Geneva