Company

Tolomeo Capital was established in 2011 as a spin-off from the quant and risk management unit of one of Switzerland’s largest institutional family offices. Tolomeo focuses on quantitative, technology-driven investment strategies with a strong emphasis on risk-adjusted returns. It has built a proprietary and state-of-the-art technology infrastructure that allows it to control every detail of the investment process from front to back. This enables Tolomeo to rapidly develop new trading ideas and translate them into high-quality tradable quantitative models. Tolomeo Capital is regulated and licensed as an asset manager of collective investment schemes by the Swiss Financial Market Supervisory Authority (FINMA).

 

Investment philosophy

Tolomeo Capital’s objective is to deliver stable and attractive risk-adjusted returns that have no correlation to major equity indices and hedge fund benchmarks. Tolomeo strives to generate an independent return stream with controlled volatility. To achieve this, the company pursues a systematic, short-term and price-based strategy that focuses on trading patterns of liquid, publicly-traded equity securities and derivatives. R&D and innovation are a key focus of the company. Tolomeo constantly improves its set of productive trading systems and adds new diversifying quantitative models in order to deliver uncorrelated alpha over the long term.

Team

The partners at Tolomeo Capital have worked together successfully for many years. All investment professionals have strong analytical backgrounds and a full set of complementary skills, ranging from investment management to risk management, financial mathematics and software engineering.

Ivan Popovic

Ivan Popovic

Managing Partner

Ivan Popovic is a founding partner of Tolomeo Capital and serves as the company’s Managing Partner. In 2006, he co-founded aeris CAPITAL (nka Calibrium), a large family office where he was responsible for several investment funds and served as a member of the Executive Management and the Board. Prior to that, he held various investment and risk management positions at Adveq, an international private equity investment company. Ivan Popovic previously also worked as an actuary at Swiss Re.

 

Ivan Popovic graduated with a Bachelor’s degree in Physics and a Master’s degree in Mathematics from the Swiss Federal Institute of Technology (ETH) in Zurich. He obtained an MBA from IESE, University of Navarra, Barcelona.

 

Simon Keel

Simon Keel

Chief Technology Officer

Simon Keel is a founding partner and the Chief Technology Officer of Tolomeo Capital. He previously worked at aeris CAPITAL (nka Calibrium), a large family office where he focused on the areas of risk management and asset allocation. In 2006, Simon Keel was one of the co-founders and Chief Information Officer of swissQuant Group, a spin-off from the Swiss Federal Institute of Technology (ETH) in Zurich, where he served as a member of the Executive Management and the Board. From 2003 to 2006, he worked at the Measurement and Control Laboratory at the ETH, where he completed his PhD. Prior to that, he was employed as an IT consultant at the global technology consulting group Altran.

 

Simon Keel obtained a Master’s degree in Mechanical Engineering and a PhD in Financial Engineering from the ETH in Zurich.

 

Zoe Russell

Zoe Russell

Director of Sales & Investor Relations

Zoe Russell joined Tolomeo Capital as Director of Sales and Investor Relations in 2016. From 2015 to 2016, Zoe headed the Distribution team at alternative asset management firm Trium Capital in London. Prior to this, she worked for over six years at Marshall Wace Asset Management, a global alternative investment manager, initially as an Investor Relations Analyst and latterly as global Head of Investor Relations & Client Services based in London.

 

Zoe Russell obtained a BA (Hons) degree in History from the London School of Economics and Political Science in 2007.

 

Sonja Frech

Sonja Frech

Director of Finance & Compliance

Sonja Frech is a founding partner and the Director of Finance & Compliance of Tolomeo Capital. In 2006, she co-founded aeris CAPITAL (nka Calibrium), a large family office where she was the CFO and a member of the Executive Management and the Board. Prior to that, Sonja Frech worked for Energie-Baden-Württemberg (EnBW) in the areas of extrajudicial debt enforcement proceedings, mergers and acquisitions, and investment controlling, and held senior Finance and Controlling positions in several financial and industrial companies.

 

Sonja Frech graduated in Business Administration (VWA) and obtained a Bachelor in Professional Marketing and Communication Management (CCI). She also studied at the Institute for International Accounting in Stuttgart and the Controller Academy in Munich.

 

Denis Kubasov

Denis Kubasov

System Engineer

Denis Kubasov joined Tolomeo Capital as a System Engineer & Software Developer in 2015. In this function, he is responsible for enhancing and maintaining the internal proprietary trading platform. Before joining Tolomeo Capital, Denis worked as a senior software developer for Source Capital AG in Zug, Switzerland, from 2014 to 2015 and spent three years as a software developer at Société Générale CIB in Paris.

 

Denis Kubasov obtained an MSc in Computer Science and Applied Mathematics from Moscow State University, an MSc in Financial Markets and Asset Management from CNAM in Paris and a PhD in Informatics from the University of Rennes 1, France.

 

Pietro Maciotta

Pietro Maciotta

Quantitative Engineer

Pietro Maciotta joined Tolomeo Capital as a Quantitative Engineer in June 2012. In this function, he is responsible for the company’s mid and back office operations. Before moving to Tolomeo Capital, Pietro Maciotta spent two years at Liechtensteinische Landesbank (LLB), where he was part of the Asset Management team. From 2008 to 2010, he worked in the Equity team at swissQuant Group, a spin-off from the Swiss Federal Institute of Technology (ETH).

 

Pietro Maciotta obtained a Master’s degree in Mechanical Engineering from the ETH in Zurich. His research focused on scientific techniques in signal processing used for the analysis of financial time series.

 

Georgi Kostov

Georgi Kostov

Quantitative Analyst

Georgi Kostov joined Tolomeo Capital as a quantitative analyst in February 2018. In this function, he is assisting the senior development team in the implementation and integration of new trading strategies and in exploring the further applicability of machine learning techniques to certain areas of Tolomeo’s investment process. Prior to this, Georgi worked as a research and teaching assistant at the Ss. Cyril and Methodius University in Skopje.

 

Georgi Kostov obtained a BSc degree in Computer System Engineering, Automation and Robotics from the Ss. Cyril and Methodius University (Skopje) and a MSc in Financial Engineering from the ETH Lausanne (EPFL).

 

Robert Tratt

Robert Tratt

Senior Quantitative Strategist

Robert Tratt joined Tolomeo Capital’s R&D team as a Senior Quantitative Strategist in October 2018. His responsibility is to help expand and diversify Tolomeo’s collection of quantitative trading strategies. In 2014 he was Co-founder and Chief Investment Officer of systematic boutique investment manager M&P Partners and from 2016 until 2018 he worked as a Quantitative Strategist for trading firm Epoch Capital, both in London. Before, Robert spent 13 years as an independent futures trader in the UK, evolving from discretionary intraday into fully systematic trading.

 

Robert obtained a BSc in Economics from The University of Hull (UK) in 1999. In 2013 he attained the CISI Investment Advice Diploma.

 

Team

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Ivan Popovic

Ivan Popovic

Managing Partner

 

Ivan Popovic is a founding partner of Tolomeo Capital and serves as the company’s Managing Partner. In 2006, he co-founded aeris CAPITAL (nka Calibrium), a large family office where he was responsible for several investment funds and served as a member of the Executive Management and the Board. Prior to that, he held various investment and risk management positions at Adveq, an international private equity investment company. Ivan Popovic previously also worked as an actuary at Swiss Re.

 

Ivan Popovic graduated with a Bachelor’s degree in Physics and a Master’s degree in Mathematics from the Swiss Federal Institute of Technology (ETH) in Zurich. He obtained an MBA from IESE, University of Navarra, Barcelona.

 

Simon Keel

Simon Keel

Chief Technology Officer

 

Simon Keel is a founding partner and the Chief Technology Officer of Tolomeo Capital. He previously worked at aeris CAPITAL (nka Calibrium), a large family office where he focused on the areas of risk management and asset allocation. In 2006, Simon Keel was one of the co-founders and Chief Information Officer of swissQuant Group, a spin-off from the Swiss Federal Institute of Technology (ETH) in Zurich, where he served as a member of the Executive Management and the Board. From 2003 to 2006, he worked at the Measurement and Control Laboratory at the ETH, where he completed his PhD. Prior to that, he was employed as an IT consultant at the global technology consulting group Altran.

 

Simon Keel obtained a Master’s degree in Mechanical Engineering and a PhD in Financial Engineering from the ETH in Zurich.

 

Zoe Russell

Zoe Russell

Director of Sales & Investor Relations

 

Zoe Russell joined Tolomeo Capital as Director of Sales and Investor Relations in 2016. From 2015 to 2016, Zoe headed the Distribution team at alternative asset management firm Trium Capital in London. Prior to this, she worked for over six years at Marshall Wace Asset Management, a global alternative investment manager, initially as an Investor Relations Analyst and latterly as global Head of Investor Relations & Client Services based in London.

 

Zoe Russell obtained a BA (Hons) degree in History from the London School of Economics and Political Science in 2007.

 

Sonja Frech

Sonja Frech

Director of Finance & Compliance

 

Sonja Frech is a founding partner and the Director of Finance & Compliance of Tolomeo Capital. In 2006, she co-founded aeris CAPITAL (nka Calibrium), a large family office where she was the CFO and a member of the Executive Management and the Board. Prior to that, Sonja Frech worked for Energie-Baden-Württemberg (EnBW) in the areas of extrajudicial debt enforcement proceedings, mergers and acquisitions, and investment controlling, and held senior Finance and Controlling positions in several financial and industrial companies.

 

Sonja Frech graduated in Business Administration (VWA) and obtained a Bachelor in Professional Marketing and Communication Management (CCI). She also studied at the Institute for International Accounting in Stuttgart and the Controller Academy in Munich.

 

Denis Kubasov

Denis Kubasov

System Engineer

 

Denis Kubasov joined Tolomeo Capital as a System Engineer & Software Developer in 2015. In this function, he is responsible for enhancing and maintaining the internal proprietary trading platform. Before joining Tolomeo Capital, Denis worked as a senior software developer for Source Capital AG in Zug, Switzerland, from 2014 to 2015 and spent three years as a software developer at Société Générale CIB in Paris.

 

Denis Kubasov obtained an MSc in Computer Science and Applied Mathematics from Moscow State University, an MSc in Financial Markets and Asset Management from CNAM in Paris and a PhD in Informatics from the University of Rennes 1, France.

 

Pietro Maciotta

Pietro Maciotta

Quantitative Engineer

 

Pietro Maciotta joined Tolomeo Capital as a Quantitative Engineer in June 2012. In this function, he is responsible for the company’s mid and back office operations. Before moving to Tolomeo Capital, Pietro Maciotta spent two years at Liechtensteinische Landesbank (LLB), where he was part of the Asset Management team. From 2008 to 2010, he worked in the Equity team at swissQuant Group, a spin-off from the Swiss Federal Institute of Technology (ETH).

 

Pietro Maciotta obtained a Master’s degree in Mechanical Engineering from the ETH in Zurich. His research focused on scientific techniques in signal processing used for the analysis of financial time series.

 

Georgi Kostov

Georgi Kostov

Quantitative Analyst

 

Georgi Kostov joined Tolomeo Capital as a quantitative analyst in February 2018. In this function, he is assisting the senior development team in the implementation and integration of new trading strategies and in exploring the further applicability of machine learning techniques to certain areas of Tolomeo’s investment process. Prior to this, Georgi worked as a research and teaching assistant at the Ss. Cyril and Methodius University in Skopje.

 

Georgi Kostov obtained a BSc degree in Computer System Engineering, Automation and Robotics from the Ss. Cyril and Methodius University (Skopje) and a MSc in Financial Engineering from the ETH Lausanne (EPFL).

 

Robert Tratt

Robert Tratt

Senior Quantitative Strategist

 

Robert Tratt joined Tolomeo Capital’s R&D team as a Senior Quantitative Strategist in October 2018. His responsibility is to help expand and diversify Tolomeo’s collection of quantitative trading strategies. In 2014 he was Co-founder and Chief Investment Officer of systematic boutique investment manager M&P Partners and from 2016 until 2018 he worked as a Quantitative Strategist for trading firm Epoch Capital, both in London. Before, Robert spent 13 years as an independent futures trader in the UK, evolving from discretionary intraday into fully systematic trading.

 

Robert obtained a BSc in Economics from The University of Hull (UK) in 1999. In 2013 he attained the CISI Investment Advice Diploma.

 

 

News

October 2017

Tolomeo Capital appoints Director of Finance & Compliance

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Tolomeo Capital AG, the Swiss based systematic asset manager, announced the appointment of Sonja Frech to the newly created position of Director of Finance & Compliance. With this move the company extends its team in a significant way.

Media article published July, 2017

The Hedge Fund Journal | The Hunt for Alpha Lies in the Short-Term

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By Nicolas Mirjolet

Distinctive and compelling return streams can still be found within the universe of short-term strategies.

Media article published June 27, 2017

EuroHedge | Tolomeo gains traction in systematic short-term equity

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Since launching in 2011 as a spin-out from the quant and risk management unit of a large Swiss family office, Tolomeo Capital is raising its profile and attracting new clients.

April 2016

Tolomeo Capital obtains FINMA Asset Manager License

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In April 2016 the Swiss Financial Market Supervisory Authority (FINMA) granted Tolomeo Capital the license as an asset manager of collective investment schemes. This confirms the institutional-set up of the firm and of its investment activities, risk management and corporate governance.

Media article published November 2, 2015

Le Temps | Gestion active ou passive : l’union fait la force

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By Ivan Popovic and Nicolas Mirjolet

La prolifération spectaculaire des fonds de placements dits «passifs» tels que les ETFs au cours de ces dix dernières années s’est accompagnée d’un débat de plus en plus acharné sur la question de savoir si la gestion passive est supérieure à la gestion active

Media article published October 23, 2015

Neue Zürcher Zeitung | Hedge-Funds wenden sich US-Banken zu

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Starke Regulierung macht das Prime Brokerage für Investmentbanken in Europa unattraktiv. Hedge-Funds wenden sich daher US-Banken zu. Das hat unerwünschte Folgen.

Media article published October 10, 2014

Neue Zürcher Zeitung | Hochfrequenzhandel: Wünschenswerte Ausbeutung der Anleger?

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Anleger sind derzeit stets mit Hochfrequenzhändlern konfrontiert, die ihre Order ausbeuten. Dennoch könnte dies unter dem Strich attraktiv für Investoren sein. Die Analyse einer Zürcher Hedge-Funds-Firma.

 

Jobs

Senior Researcher/Trader

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To strengthen our research team, we are looking for a senior quantitative researcher with a documented track record in developing and trading systematic strategies in the equity space.

 

Your main task is to incorporate systematic trading algorithms into our investment strategy and actively contribute to its performance. You will conduct research with large financial datasets to improve existing and to create new systematic trading strategies that are uncorrelated to the current set of trading systems. In addition, you are taking part in the daily trading activities.

 

We are looking for candidates with the following qualifications:

  • Experienced systematic trader with documented track record
  • Profound knowhow in financial markets and in the application of science to these markets
  • Strong background in probability and statistics, data mining, optimization, pattern recognition or signal processing
  • Superior critical thinking and analytical skills, combined with creativity, curiosity, and attention to detail
  • Solution oriented approach to complex problem solving and the ability to convey complicated mathematical and financial concepts in a straightforward manner
  • Ability to develop new ideas and to conduct independent research using financial data
  • High achiever with relentless drive to succeed and the willingness to learn new techniques
  • Familiarity with object orientated programming (Java, C#, C++) and advanced programming skills in at least one scripting language (e.g. Matlab, Python, R)
  • Excellent written and verbal presentation skills in English language
  • High level of cooperativeness and self-reliance

 

Tolomeo Capital offers the opportunity to be part of an emerging asset manager with high growth potential. In this position, you are incentivized based on your contributions. Professionals are given room for contributing own ideas and developing own initiatives. They have access to state-of-the art technology and can leverage their own experience with the one of a strong international team.

 

For further information or for sending us your application please contact us by email at

 

Internship in Systematic Trading Development

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There are currently no open internship positions at Tolomeo. We will post new internship positions on our website once they become available.

 

 

Contact

Zurich Headquarter
Tolomeo Capital AG
Fortunagasse 40
CH-8001 Zurich
Switzerland

 

Phone +41 555 110 520

 

 

London Office
Tolomeo Capital AG
Kensington Pavilion
96 Kensington High Street
London
W8 4SG
United Kingdom

Phone +44 207 871 3445

 

Disclaimer

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Tolomeo Capital provides no guarantee and assumes no liability towards third parties regarding the reliability, accuracy and completeness of the information published. Moreover, the information is subject to change at any time without obligation to notify the recipient.

Furthermore, Tolomeo Capital assumes no responsibility and provides no guarantee that access to the website will be uninterrupted or error-free, that defects will be corrected, or that the website or the relevant server are free from viruses or other harmful components or programs.

The website of Tolomeo Capital contains links to third-party websites. Tolomeo Capital has no control over such links. Consequently, Tolomeo Capital accepts no responsibility for the accuracy, completeness or legality of the contents of such websites or for any products or services contained on them.

Exclusion of liability

Tolomeo Capital and its contracting partners accept no liability (including negligence or liability towards third parties), to the extent permitted by law, for any losses resulting from direct, indirect or consequential damage of any kind related to the use of the website.

Copyright

All rights reserved. The entire contents of this website are the property of Tolomeo Capital unless specifically stated otherwise. No part of this website grants any license or right to use any image, text, trademark or logo. No act of downloading or otherwise copying from the website will transfer any legal entitlement to any software or material contained on this website to the user.

The contents of this website may not be reproduced without the prior written consent of Tolomeo Capital or without explicitly acknowledging the source.

Privacy Policy

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We are very delighted that you have shown interest in our company. Data protection is of a particularly high priority for the management of Tolomeo Capital Ltd. (‘Tolomeo’). The use of the Internet pages of Tolomeo is possible without any indication of personal data; however, if a data subject, as defined in section 1 of this policy, wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Tolomeo’.. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, Tolomeo has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of Tolomeo is based on the terms used by the Swiss Data Protection Act (DPA) and the European General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

  • Personal data: Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Data subject: Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
  • Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Restriction of processing: Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
  • Profiling: Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
  • Pseudonymization: Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  • Controller or controller responsible for the processing: Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by EU or Swiss law, the controller or the specific criteria for its nomination may be provided for by EU or Swiss law.
  • Processor: Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  • Recipient: Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with EU or Swiss law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
  • Third party: Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
  • Consent: Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Switzerland and other provisions related to data protection is: Tolomeo Capital Ltd., Fortunagasse 40, 8001 Zurich/Schweiz. Phone: +41 55 511 05 20. Email: compliance@tolomeo-capital.com , Website: www.tolomeo-capital.com

3. Cookies

The Internet pages of the Tolomeo use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, Tolomeo can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information

The website of Tolomeo collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Tolomeo does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Tolomeo analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Subscription to our newsletter and extended fund information

On the website of Tolomeo, users are given the opportunity to subscribe to extended fund information. During this subscription process, we collect personal information from you like the name, first name and email address.
Tolomeo informs its customers and business partners regularly by means of a newsletter. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to receive the newsletter. Before sending out the newsletter, a confirmation e-mail will be sent to the e-mail address registered by a data subject, for legal reasons, in order to comply with the requested double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized and is opting-in to receive the newsletter.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter E-mail.

6. Newsletter-Tracking

The newsletter of Tolomeo is distributed through the automation platform of MailChimp. In order to ensure that you will get our newsletter on a regular basis we will transfer the information you provide to us to MailChimp for processing the newsletter distribution in accordance with our Privacy Policy. This allows a statistical analysis of the success or failure of the distribution of our marketing materials or newsletters. Tolomeo is able to see whether the materials were delivered successfully, if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure.

7. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the Swiss and European legislator in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the Swiss and European legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

8. Rights of the data subject

a) Right of confirmation

Each data subject shall have the right to obtain from Tolomeo the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact Tolomeo.

b) Right of access

Each data subject shall have the right granted by the Swiss and European legislator to obtain from Tolomeo free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • 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;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact Tolomeo.

c) Right to rectification

Each data subject shall have the right granted by the Swiss and European legislator to obtain from Tolomeo without undue delay the rectification of inaccurate personal data concerning him or her. Considering the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the Swiss and European legislator to obtain from Tolomeo the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Tolomeo, he or she may, at any time, contact Tolomeo. Tolomeo shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.

e) Right of restriction of processing

Each data subject shall have the right granted by the Swiss and European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Tolomeo, he or she may at any time contact Tolomeo.

f) Right to data portability

Each data subject shall have the right granted by the Swiss and European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact Tolomeo.

g) Right to object

Each data subject shall have the right granted by the Swiss and European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Tolomeo shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If Tolomeo processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Tolomeo to the processing for direct marketing purposes, the Tolomeo will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Tolomeo for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact Tolomeo. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the Swiss and European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not  necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Swiss or European law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, Tolomeo shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact Tolomeo.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the Swiss and European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact Tolomeo.

9. Data protection provisions about the application and use of Google Analytics
(with anonymization function)

On this website, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under
- https://www.google.com/intl/en/policies/privacy/
- http://www.google.com/analytics/terms/us.html.
- https://www.google.com/analytics/

10. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. In the case that our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

11. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

12. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

13. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

14. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.