UGN Global («UGN», «we», «us») takes the protection of your personal data seriously. This Privacy Policy explains what data we collect, how we process it, and what rights you have under the Swiss Federal Act on Data Protection (revDSG) and, where applicable, the EU General Data Protection Regulation (GDPR).
Last updated: 1 May 2026
1. Data Controller
The data controller responsible for the processing of your personal data is:
EntityUGN Global
AddressZürich, Switzerland
RegistrationCHE-XXX.XXX.XXX
Contactprivacy@ugn-global.com
2. Data We Collect
We collect the following categories of personal data:
- —Identity data: name, username, professional title
- —Contact data: email address, telephone number
- —Authentication data: login credentials managed via Clerk
- —Usage data: pages visited, features accessed, session duration
- —Technical data: IP address, browser type, operating system
- —Portfolio data: anonymised portfolio identifiers and mandate references linked to your advisor profile
3. Legal Basis for Processing
We process your data on the following legal bases:
- —Contractual necessity: to provide you access to the Atlas platform under our service agreement
- —Legitimate interests: to improve platform security, detect fraud, and maintain system integrity
- —Legal obligation: to comply with applicable Swiss financial law
- —Consent: for optional communications and analytical cookies (where applicable)
4. Data Retention
We retain personal data for as long as necessary to fulfil the purposes set out in this policy. Specifically:
- —Account data is retained for the duration of your access agreement plus 10 years (Swiss financial recordkeeping requirements)
- —Audit log entries are retained for 10 years in accordance with applicable Swiss recordkeeping requirements
- —Usage and technical logs are retained for 12 months
- —Session tokens are invalidated upon logout and not persisted
5. Data Sharing
We do not sell your personal data. We share data only with:
- —Clerk Inc. (USA) — authentication and identity management, covered by Standard Contractual Clauses
- —Vercel Inc. (USA) — application hosting, covered by Standard Contractual Clauses
- —Railway Corp. (USA) — backend infrastructure, covered by Standard Contractual Clauses
- —Competent authorities: FINMA, Swiss courts, or law enforcement, where legally required
6. Your Rights
Under the revDSG and GDPR (where applicable), you have the right to:
- —Access the personal data we hold about you
- —Rectify inaccurate or incomplete data
- —Erasure of your data, subject to legal retention obligations
- —Restriction of processing in certain circumstances
- —Data portability in a structured, machine-readable format
- —Object to processing based on legitimate interests
- —Lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC)
To exercise any of these rights, contact us at privacy@ugn-global.com.
7. Cookies and Tracking
Atlas uses only technically necessary cookies required for authentication and session management. We do not use advertising or cross-site tracking cookies. A session cookie is set by Clerk for authentication and is deleted when your browser session ends.
8. Security
We implement industry-standard technical and organisational measures to protect your data, including TLS encryption in transit, encrypted storage at rest, role-based access control, and regular security reviews. Access to production systems is restricted to authorised personnel only.