Privacy Policy

Noire Group ("Noire", "we", "us" or "our") is the private family office of a single family. We are committed to protecting the privacy, confidentiality and security of personal data we process.

This Privacy Policy explains how we collect, use, store and protect personal data in accordance with the Swiss Federal Act on Data Protection (FADP / nDSG) and, where applicable, the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018.

This policy applies to visitors to our website, and to the family’s own representatives, advisers, referrers, counterparties and other individuals whose personal data we process in the course of administering the family’s own affairs. Noire Group does not offer services to, or process personal data on behalf of, external clients.

1. Who We Are

Noire Group is the private family office of a single family, operating through noire7group.com. Based in Bern, Switzerland.

For the purposes of applicable data protection law, Noire Group acts as data controller in respect of the personal data described in this policy, unless a separate written agreement states otherwise.

• Controller: Noire Group is the private family office of Matthias Thäler, operating as an unincorporated private office based in Bern, Switzerland. This website is informational and does not constitute an offer of financial services.
• Registered address: Oberdorf 2, 3414 Oberburg, Switzerland
• Data protection contact: concierge@noire7.com

2. Information We Collect

We collect only the personal data reasonably necessary to administer the family’s own affairs, operate this website, maintain security and meet our legal and regulatory obligations. This may include:

• Identity data: full name, date of birth, nationality, passport or government-issued identification details, proof of identity and, where required, beneficial ownership information
• Contact data: email address, telephone number, correspondence address and preferred communication method
• Professional data: organisation name, role and professional background of the family’s own advisers and counterparties
• Financial and asset data: asset details, wealth structure, source of funds and source of wealth relating to the family’s own affairs
• Compliance data: information required for KYC, AML, sanctions screening and related checks conducted by the family’s banks and counterparties, and for our own internal risk-management purposes
• Transaction data: records of instructions, transactions and related administrative activity concerning the family’s own affairs
• Communication data: correspondence, meeting notes, enquiry submissions and records of instructions
• Technical data: IP address, browser type, device information, server logs and website access information where you interact with our website

We do not seek to collect sensitive personal data unless it is voluntarily provided, necessary for administering the family’s affairs, or required for legal, regulatory, compliance or risk-management purposes. Where such data is processed, we do so only where permitted by applicable law and subject to appropriate confidentiality and security measures.

3. Sources of Personal Data

We may collect personal data:

• directly from you
• from the family’s representatives, advisers, referrers or authorised intermediaries
• from banks, fiduciaries, lawyers, tax advisers, brokers or counterparties involved in the family’s own affairs
• from public registers, sanctions lists, compliance databases, adverse-media sources and other lawful due diligence sources
• through your use of our website or contact form

4. How We Use Your Information

We use personal data for the following purposes:

• to respond to enquiries about this website
• to verify identity and conduct KYC, AML, sanctions, source-of-funds and source-of-wealth checks in connection with the family’s own affairs
• to communicate regarding the family’s own affairs, instructions or related arrangements
• to coordinate with professional advisers, banks, fiduciaries, brokers, counterparties and service providers involved in administering the family’s own affairs
• to comply with legal, regulatory, tax, accounting, AML and reporting obligations
• to protect the security, integrity and confidentiality of our records and communications
• to maintain accurate internal records, audit trails and governance procedures

We do not sell personal data. We do not use personal data for mass marketing, advertising profiling or unrelated commercial purposes.

5. Legal Basis for Processing

Where the FADP applies, we process personal data only for lawful, proportionate and transparent purposes consistent with this Privacy Policy and applicable confidentiality obligations.

Where the EU GDPR or UK GDPR applies, we rely on one or more of the following legal bases:

• Legal obligation: to comply with AML, tax, accounting, regulatory, sanctions, court or authority requirements
• Legitimate interests: to operate our website and internal affairs securely, manage risk, maintain records and protect our legal position
• Consent: where we specifically request consent for a particular processing activity — consent may be withdrawn at any time, without affecting prior lawful processing

Where special category or sensitive personal data is processed, we do so only where permitted by applicable law, including where necessary for legal claims, substantial public interest, compliance obligations, explicit consent, or another lawful basis available under the applicable regime.

6. Confidentiality & Discretion

Confidentiality is central to how we operate. Personal data is handled with strict discretion and access is limited to authorised persons on a need-to-know basis. We disclose information only where necessary and appropriate, including:

• where required by law, regulation, court order, tax authority, supervisory authority or competent public authority
• to professional advisers, fiduciaries, lawyers, tax specialists, banks, brokers, counterparties or other parties engaged in connection with the family’s own affairs
• to secure IT, hosting, email, document-management, compliance, administrative or operational service providers acting under confidentiality and data-protection obligations
• to Noire Group personnel or authorised representatives involved in your enquiry or in administering the family’s own affairs
• with your explicit instruction or prior consent

All staff, advisers and service providers with access to this information are expected to observe strict confidentiality obligations. Non-disclosure agreements are available upon request — see the NDA page for details.

7. Data Storage & Security

Personal data is stored using secure systems located in Switzerland, the EEA, the UK or other jurisdictions where appropriate safeguards are in place. We apply technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures may include:

• encrypted communication channels, available on request
• access controls limited to authorised personnel
• secure document-management and retention procedures
• confidentiality obligations for staff and service providers
• internal review of security and access practices
• procedures for responding to suspected data security incidents

No method of transmission or storage is completely secure. However, we take reasonable and proportionate steps to protect personal data according to its sensitivity.

8. International Transfers

Because the family’s own affairs may involve Switzerland, the EEA, the UK, Singapore and other jurisdictions, personal data may be accessed from or transferred internationally. Where personal data is transferred to a country that does not provide an adequate level of protection under applicable data protection law, we use appropriate safeguards where required. These may include contractual protections, confidentiality obligations, standard contractual clauses, transfer-risk assessments, or other lawful transfer mechanisms.

Further information about applicable transfer safeguards may be requested by contacting us.

9. Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including to administer the family’s own affairs, maintain records, comply with legal and regulatory obligations, resolve disputes and protect our legal position. As a general guide:

• enquiry records are retained only for as long as reasonably necessary to manage the enquiry and protect our legitimate interests
• transaction, accounting and compliance records concerning the family’s own affairs may be retained for the period required by applicable law, including Swiss AML, tax, accounting and regulatory retention obligations
• where Swiss AML obligations apply, relevant records may be retained for at least 10 years after the end of the relevant relationship or completion of the relevant transaction
• records may be retained longer where required by law, court order, regulatory request, dispute, investigation or legitimate legal interest

When personal data is no longer required, we delete, anonymise or securely archive it in accordance with applicable retention procedures.

10. Your Rights

Subject to applicable legal limits and retention obligations, you may have the right to:

• request access to personal data we hold about you
• request correction of inaccurate or incomplete personal data
• request deletion or destruction of personal data where lawful
• object to or restrict certain processing
• request data portability where the EU GDPR or UK GDPR applies
• withdraw consent where processing is based on consent
• ask for information about international transfer safeguards
• lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, where applicable, another competent data protection authority

To exercise your rights, contact us at concierge@noire7.com. We may need to verify your identity before responding to a request.

11. Automated Decision-Making

We do not use personal data for automated decision-making that produces legal or similarly significant effects. We do not conduct automated profiling for advertising or marketing purposes.

12. Cookies & Website Data

Our website does not use advertising cookies, behavioural tracking cookies or third-party analytics unless expressly stated in an updated cookie notice. We may process limited technical data, such as server logs, IP address, browser type and basic security information, to operate the website, maintain security and receive enquiries submitted through the contact form. Information voluntarily submitted through our contact form is processed in accordance with this Privacy Policy.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, regulation, security practice or our operations. The current version will be published on this page with the date of last revision.