Data Privacy Notice
This data protection policy describes how Little Whale Capital SA (hereinafter "the Company") treats the personal data it may receive in its capacity as data controller.
1. Data Controller
The Company can be contacted at the following address for any questions or complaints:
5 rue Rousseau, 1201 Geneva, Switzerland
or via our contact page.
2. Type of Personal Data Collected
In the context of its business relationships with clients and the legal and contractual obligations arising therefrom, the Company processes personal data received in principle directly from its clients, in particular:
- identification and contact details, such as surname, first name, date of birth, telephone number and address;
- data relating to family and professional profile, such as occupation, investment knowledge;
- financial and tax data, such as income, earnings and investments, debts, tax residence;
- data relating to interactions with the Company and the use of the Company's services, such as letters and e-mails;
- any other data that the Company is required by law to collect.
As part of its legal obligations, the Company may also in certain cases collect personal data from third parties, for example by accessing public databases (e.g. internet search engines) or paying databases (e.g. press subscriptions).
The Company does not collect any personal data via its website.
3. Third-Party Data
If a client provides the Company with personal data of third parties, the client must ensure that the data subject has been informed of this data protection policy.
4. Aim of the Treatment
The Company processes the personal data of its clients in particular to provide the services requested, to comply with its legal obligations and in the event of overriding legitimate interests (e.g. exercising a right).
5. Communication to Third Parties
Personal data is transferred to third parties when this is necessary to perform the services requested, in particular to carry out transactions (e.g. communication to a bank or to a security firm). In addition, the Company reserves the right to subcontract the processing of personal data to third parties who are contractually bound to confidentiality, such as IT or compliance services. Personal data may also be disclosed to its legal advisors, auditors, authorities, courts or similar institutions when the Company is required to disclose information by applicable law or regulation or to protect its legitimate interests.
6. Communication Abroad
The Company may need to communicate personal data abroad in order to perform its contract, in particular if the custodian bank for the customer's assets is located abroad or if this is required by law or applicable regulations. The Company undertakes to ensure that any transfer abroad complies with the applicable provisions.
7. Deletion
Personal data is deleted when it is no longer reasonably necessary to provide the services, if the Company is not required to retain it by its legal obligations, unless the Company has an overriding private interest in retaining the data concerned.
8. Rights of the Data Subjects
Any person affected by the processing of personal data (data subject) has the right to access his or her personal data, to have it corrected, to prohibit or limit its processing, to request its deletion and in certain cases to request that it be disclosed to him or her or to a third party. The Company may be entitled to refuse to act on a complaint if it is legally obliged to process the data concerned or if there is an overriding private interest on the part of the Company or a third party.
9. Data Security
The Company takes appropriate technical and organisational measures to protect the security of personal data, in compliance with applicable law.
10. Changes
This data protection policy may be amended at any time, with effect as soon as they are published on the Company's website.
Last modified on: 11.12.2025