Privacy Regulations

1. Preliminary remark

SWISSCHANGE Financial Services AG (hereinafter “SWISSCHANGE“,“we” or“us“) greatly appreciate your visit to this website and your interest in our products and services. The protection of your data is important to us and we want you to be able to use our website without reservation. SWISSCHANGE attaches great importance to the responsible handling of your personal data in accordance with the legal requirements. For this purpose, we take various precautionary measures, including reliable technical and organizational security measures (e.g. password encryption, firewalls, authentication technologies, access management, awareness-raising and employee training, designation of a data protection officer (DPO).).

This Policy (together with our Terms of use, our Cookie Policy and the other documents referred to therein, the “Privacy Policy) explains how we process your personal data when you visit our website or mobile applications, when you use services, register for a service and enter information about yourself and/or use other electronic services (“Electronic services“).

Please read our Privacy Policy before you access our Electronic Services, and in particular before you enter any personal information, so that you understand our views and procedures regarding your personal information and you are aware of how we are data and on what basis they could be transmitted to third parties. By accessing our Electronic Services, you confirm that you agree to the handling of personal data described in this Privacy Policy and the data protection measures. If you do not agree with this Privacy Policy, please do not open any other pages of our website or use our Electronic Services.

Other regulations (e.g. the terms of use for apps) apply to certain types of data processing (such as the apps offered by SWISSCHANGE) and our presence on social media. You can obtain the relevant regulations on the relevant websites and/or in the respective apps.

2. Processing of personal data

2.1 Categories of personal data
SWISSCHANGE processes different categories of personal data (including data from existing and potential customers, website users, suppliers, suppliers and other third parties). The processing of this data remains limited to the minimum necessary and is carried out in accordance with the applicable laws and regulations. This applies to the following:

  • master data (e.g. name, address, e-mail address, telephone number, date of birth, account or contract number, other account information, completed transactions or third parties, such as family members, authorised representatives, consultants who are also may be affected by data processing, as well as other data transmitted to us, if a person voluntarily fills out a registration form or comment box for a newsletter or makes use of certain services).
  • Risk management, transaction and/or order data (e.g. data relating to the recipients of a bank transfer, card payments, data on investment products, risk and investment profiles, fraud).
  • Technical data (e.g. IP addresses, type and version of browser plug-ins, cookies, internal and external identifiers, log data, access and change logs, content retrieved by the user of the website, including date and time of access, business/account number).
  • Marketing data (e.g. preferences, wishes, requested information material).

SWISSCHANGE intends to collect as far as possible sensitive data (also referred to as data of special categories) via our websites, unless this is required by labour law in the personnel area. Sensitive data includes various types of information relating, inter alia, to race or ethnic origin, political beliefs, religious or other similar beliefs, union membership, physical or mental health, sex life or any criminal record. SWISSCHANGE recommends that you do not provide such sensitive information. If for any reason you wish to provide sensitive data, SWISSCHANGE considers this to be your express consent to the use of this data, as described in this Privacy Policy or in the transmission of sensitive data requested by you. If you wish to provide us with sensitive data, your express consent is required in a separate procedure during the transfer in this regard.

2.2 Origin of personal data
For the purposes set out in Section 2.3, we may collect personal information, to the extent permitted by law, in particular from the following sources:

  • Personal data provided to us by the data subject, such as when opening an account, during a consultation, in the context of a request, when registering on our websites or when using certain products and services, when registering for a newsletter and/or event, when participating in discussion forums or other social media functions on our websites or in connection with the application for a job.
  • Personal data required to provide products and services that are transmitted to us using the technical infrastructure (e.g. through our website, log-in information, e-banking, apps, payment and trading transactions, cooperation with financial or IT service providers or through trading venues and stock exchanges).
  • Personal data of third parties, such as public authorities, sanction lists (e.g. UN/EU), Worldcheck, credit rating agencies, credit reporting agencies (e.g. Swiss Central Credit Information Centre (ZEK), Consumer Credit Information Centre (IKO), Schufa Holding AG (SCHUFA)), analytics service providers or providers of search services and companies of the SWISSCHANGEGroup.
  • Personal data that is publicly available (e.g. entries in public registers, public social media platforms).

2.3 Purpose and use of data
We may process personal data as described above for the purpose of providing our services and/or for the purposes specified by law and to the extent permitted by law. This applies in particular to:

  • processing, improvement, management and setup of our products and services (e.g. accounts, payment transactions, invoices, cards, financing, financial planning, investments, stock exchanges, retirement provision, eFinance, succession planning) as well as the Updating the data of private individuals with whom we have a business relationship.
  • development of products and services, statistics, business decisions (e.g. ideas for new or evaluation of existing products, services, processes, technologies and revenues, identification of key figures for the use of services and load data).
  • Manage, control and monitor business decisions and risks, timely business execution (e.g. investment profiles and limits, as well as market, credit, operational and fraud risks).
  • System management and reporting of collected statistical data about browsing behaviors and actions that cannot be assigned to any specific person.
  • Compliance with the relevant regulations, legal and/or supervisory disclosure, notification and reporting obligations to authorities, courts, including money laundering and terrorist financing (e.g. automated exchange of information with foreign tax authorities, public prosecutors).
  • market research, marketing, comprehensive customer service, advice and information on various products and services, etc. (e.g. events for current and potential customers and interested third parties, cultural events, sponsorship, Assessing customer, market or product potential, information about changes, identification of customer satisfaction, online and print advertising).
  • Safeguarding our interests and rights if claims are made against us or against our employees or customers.
  • Anonymized information (e.g. data collected by means of cookies) is only used for statistical purposes and to improve our website. This data is then deleted. We also use such non-personal information to facilitate your use of our website (among other things, we may use cookies to store your selected country of residence for the duration of a session so that you do not receive this information more than once must be entered).

In this context, we would like to expressly point out that we may (further) evaluate any non-anonymised personal data that you voluntarily provide and, in particular, use such data to provide additional personal data. collect information about you that comes from publicly available sources or collections of data. You hereby give your express consent to this procedure. If you do not agree with this, please do not use our website.

Personal data that is not anonymized, such as postal and e-mail addresses, which are transmitted to us in the context of a request or with a request for information, will be used primarily for correspondence with you or the sending of the relevant information. e.g. if you have signed up for a newsletter or an event.

In addition, non-anonymized personal data will only be made available to employees or third parties who need to be aware of this information in order to provide products or services, or if, by law, we or regulatory provisions are required to disclose this information. To the extent permitted by law, we may also share non-anonymized personal information with companies that provide services on our behalf for the purposes set out above. The data collected may be passed on to service providers located outside the EU or the EEA, Switzerland or outside the country in which the user is located (see section 5). These service providers must treat the information and all data collected confidentially and may only use it for the intended purposes. They are contractually bound by applicable data protection laws and regulations.

Under no circumstances will personal data be sold to third parties for marketing or other purposes.

2.4 Special cases of automated individual decisions, including profiling
SWISSCHANGE reserves the right to analyse and evaluate your data in an automated manner in the future (including data relating to affected third parties, see section 2.1) in order to identify essential personal characteristics for you or to forecast future developments and to create appropriate profiles. These are used in particular for business-related audits, individual consulting services as well as offers and information that we and the companies of our group may provide to you.

Your profiles may lead to automated individual decisions in the future, e.g. in the context of the automated receipt and execution of your orders in e-banking. If you do not want your data to be used in this way, you have the right to inform us so that we no longer use this information for this purpose.

SWISSCHANGE ensures that you have a suitable contact person if you wish to comment on an automated individual decision, provided that the opportunity for such an statement is provided for by law.

2.5 Potential recipients, warranties and transmission abroad
In the following cases, we may disclose personal data to third parties or to other companies within SWISSCHANGE to the extent permitted by law:

  • On some websites, we ask for your consent to share data with third parties and to use it for advertising purposes. By filling in the relevant form, you agree that the data we collect will not only be provided by us, but also by other companies within the SWISSCHANGEGroup may be used to establish Group-wide customer relationships within SWISSCHANGE and to inform you about new products that might be of interest to you. In addition, you agree that your personal data may be processed and used by us and other companies within SWISSCHANGE for advertising or market research purposes, or to develop services according to customer needs.
  • With your consent, we share data with companies within SWISSCHANGE to ensure comprehensive customer service or as part of outsourcing (see section 4).
  • For the execution of orders, e.g. for the use of products and services (e.g. to service providers, trading venues or stock exchanges, when certain stock exchange transactions are reported to international trade repositories).
  • With regard to legal obligations, other legal reasons or in the case of an administrative order (e.g. disclosure to courts or supervisory authorities in the field of financial market or tax law or in order to safeguard our legitimate interests in the EU or eEA , in Switzerland or in another country).
  • With regard to contractual relations between a company of the SWISSCHANGEgroup and a third party, if that third party processes personal data on behalf of SWISSCHANGE. If personal data is transmitted to such third parties, they may only process the data received to the extent that they may also be processed by SWISSCHANGE itself. We carefully select these third parties and let them contractually ensure confidentiality, compliance with data protection requirements and the security of personal data.

When personal data is transferred to other countries, we ensure that applicable laws and regulations are complied with (see section 5). Depending on the product or service, personal data may also be transferred to third parties established in countries where there may generally be no adequate or equivalent level of data protection. When data is transferred to such a country, we take appropriate measures to ensure adequate and reliable protection of personal data (e.g. by agreeing standard contractual clauses for the transfer of data from EU to non-EU countries).

Some countries may have stricter privacy policies that may not allow your non-anonymized personal information to be used in those countries to the extent described above. These terms may, for example, exclude the collection of additional personal data based on the information provided or the disclosure of your personal data to other parties or companies.

3. Communication by e-mail and e-newsletter

SWISSCHANGE may send youup-to-datecommunications, offers and information about events or services by e-mail or newsletter (” Newsletter Service “). To do this, you must have registered as a user (i.e. You must set up a user account with us) and subscribe to our newsletter service. If you are not a registered user and prefer not to receive marketing emails or newsletters from us, you can unsubscribe by following the unsubscribe instructions at the end of each email.

The newsletter service can be offered in cooperation with other service providers. The information you provide in the form in question may be processed and stored on cloud servers operated by the respective service providers in data centres in Switzerland, the EU or the EEA or the United States. These service providers are contractually obliged to maintain confidentiality (e.g. by agreeing standard contractual clauses for the transfer of data from EU to non-EU countries). In order for personal data to be adequately protected, these service providers must report detected breaches of data protection requirements.

4. Transmission of data on the Internet

Please note that data can be transmitted uncontrollably across national borders on the Internet, even if the sender and recipient are in the same country.

We cannot guarantee the security of the data transmitted on the Internet and assume no liability in this regard. Messages you send us by email may not be secure. If you send us confidential information by e-mail, you do so at your own risk. When you contact us, please do not send your data over the Internet, but use a secure procedure if necessary.

The sender and recipient can also be identified if the transmitted data is encrypted. Third parties may, possibly by mistake, conclude that there is a business relationship between you and SWISSCHANGE. We therefore recommend that you avoid the transmission of highly confidential information over open networks.

5. Outsourcing

SWISSCHANGE may, under certain circumstances, be required to outsource all or part of its business units and services to other companies within the SWISSCHANGEGroup or to service providers outside SWISSCHANGE (e.g. payment transactions, subscription and redemption of fund shares, printing and sending of bank documents, IT systems and other supporting functions). We may also use such providers for new services that we have not yet offered.

In such cases, we generally use service providers that are based in the EU, EEA or Switzerland and, if possible, prefer companies within our group to ensure compliance with the relevant laws and regulations. Can. If customer data has to be disclosed during outsourcing, the respective service providers are obliged to comply with the bank customer confidentiality and the other applicable regulations. If services are outsourced to a provider abroad in exceptional cases, SWISSCHANGE will disclose this in accordance with the applicable rules.

6. Storage of data

After you submit your personal data to us, this information will be stored securely and used for the purposes described in this Privacy Policy and for which the information has been provided.

We have taken reasonable and reliable data security measures to ensure that this information is accessible to only a limited number of authorized persons and is protected from unauthorized access, misuse, loss or damage.

In general, data that we collect through a company of the SWISSCHANGEGroup are transferred by us to a central file in Switzerland and stored there (at bank SWISSCHANGE Financial Services AG, Spalenvorstadt 8, CH-4051 Basel), regardless of the country in which the data is collected. Switzerland is recognised as a country that guarantees adequate data protection. However, this general procedure does not apply to data collected in connection with the newsletter service (see section 3).

7. Retention period

Even if the retention period for personal data depends on the legal retention requirements as well as on the respective legal basis and the purpose of the data processing, SWISSCHANGE will not store your personal data for longer than necessary. In doing so, we take into account our obligation to respond to any queries or to resolve any problems that arise, to provide improved and new services and to act in accordance with applicable laws and regulations.

This means, in particular, that we are entitled to retain your personal data for a reasonable period of time after your last contact. If the personal data we collect is no longer required for this purpose, we are obliged to delete the data in a secure manner.

8. Your rights as a data subject

You have the right to be informed whether we are processing personal data about you. On request, we will provide you with information about your personal data in our databases, including the available information on the origin of the data, the purpose of use and, if applicable, the legal basis for the processing as well as the categories of data. processed personal data, the parties involved in the collection of data and the data recipients.

You may withdraw your consent to the processing of your personal data and/or object to the use of your information for advertising and marketing purposes at any time with effect for the future. In addition, you may exercise other rights, such as the right to rectification, you are entitled to correct any errors in your personal data or to block or delete your data, depending on the legal basis on which we stored in the respective data.

Please also let us know if we do not meet your expectations regarding the processing of personal data or if you wish to complain about our privacy practices. This gives us the opportunity to examine your request and, if necessary, to make improvements.

In such cases, please always send a clear written request together with a legible copy of a valid official identification document (e.g. passport, identity card) to the body listed in section 15 so that we can clearly identify you, or use the request form. We will confirm receipt of the request immediately, check your request and respond promptly. If a comprehensive response takes more than a month, taking into account the complexity and number of requests, we will inform you.

9. Note on the protection of children

SWISSCHANGE is aware of the importance of protecting children’s privacy, especially in an online environment. Therefore, children under the age of 16 are not part of the target group of our services, and we do not knowingly collect personal information from such users, unless a child applies for a training place, an internship or a “sniffing day”. In this case, we will give us the written consent of the parents or legal representatives.

10. Cookies and web analytics services

Our website uses cookies to distinguish you from other users of our website. Every time a person accesses our website and a file is retrieved, data about this process is temporarily stored and processed in a data log, e.g. through the use of a cookie or tracking pixel technology. The respective data that is logged for each access/retrieval includes the IP address, the web browser, the domain name, date and time of day, the page/name of the requested file, the data transferred and the access status (i.e. whether the access or retrieval was successful).

We use web analytics tools to gather information about how our sites and Internet offerings are used. These tools are usually provided by third parties. As a rule, the information is collected using cookies and sent to an external server. Depending on the provider, these servers may be located in other states.

The data transmission is carried out by means of shortened IP addresses, which prevents the identification of individual end devices of the users. Your IP address will not be linked to other data of these third parties. Further transmission by third parties is only carried out on the basis of legal provisions or under a service contract for data processing.

For detailed information about the cookies or web analytics tools we use, their intended use, and how you can accept and/or reject them, please see our Cookie Policy.

11. Retargeting

Our website and our online newsletter service can use retargeting technologies to make our website more interesting for you. With this technology, ads can be placed on other websites if their users have already shown interest in our products.

12. Onsite targeting

On our website, data can be collected using cookie technology, which is then used to optimize our advertisements and our entire online offering. This data is not used to determine your personal identity, but only to anonymously analyze the use of our website. With this technology, we can show you advertisements and/or point you to certain offers and services. Our goal is to make our online presence as attractive as possible for you and to show you advertisements that suit your interests.

13. Social media

We may use so-called social plug-ins on our website. This allows you to share the content of our website with other Internet users via the relevant social media platforms or to link to our website through these platforms. The following information on the nature and scope of the data collected is based on the communications and information provided by the respective provider.

Our website may include plug-ins of The Social Network of Facebook Inc, 1601 South California Avenue, Palo Alto, CA 94304, USA (“Facebook“). Among other things, we use Facebook’s “LIKE” button (also known as the “Like Me” button). In addition, our website contains a Facebook page plug-in that integrates partial content of our Facebook page into our website. When you visit one of our websites that contains such a plug-in, your browser establishes a direct connection to a Facebook server. The contents of the plug-ins are transmitted directly to your browser and integrated into the website. The data is automatically transferred to Facebook and stored on its servers. Among other things, connection data (e.g. Your IP address, date and time, the URL (address of a website) accessed, and information about the browser and operating system used. Your visit to our websites may be tracked by Facebook, even if you are not actively using the plug-in features.

If you are logged in to Facebook while you are visiting our website, Facebook may associate your visit to our websites directly with your user account. If you want to prevent this immediate assignment, you must unsubscribe from Facebook before you visit our website. Facebook decides at its sole discretion for which purposes and to what extent the transmitted data is processed and used on its servers. Information about the purpose and scope of the data collection as well as the further processing and use of the transmitted data by Facebook can be found in Facebook’s privacy policy. These also contain information about your rights and the possible settings to protect your privacy. For more details, please refer to Facebook’s respective privacy policy.

Our website may include plug-ins from Twitter, Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter“). We use Twitter buttons to access our Twitter account and share buttons from Twitter to share the content of our website through your Twitter account. We also use a Twitter widget to integrate and make visible the list of our current tweets in our website. When you visit our website, your browser connects directly to a Twitter server. The contents of the plug-ins are transmitted directly to your browser and integrated into the website. Certain data is automatically transferred to Twitter in the USA and stored there. This includes, but is not only, connection data (your IP address, date and time, the URL (address of a website) called) as well as the browser type and operating system.

If you are logged in to Twitter during your visit to our website and use the above plug-ins, information about your user account will be transmitted to Twitter so that Twitter will identify you directly by your profile and use your visit to our site. When you click a button, additional data is transferred to Twitter and stored in your profile. Twitter’s privacy policy contains information about the nature, scope, and purpose of Twitter’s data processing. If you want to prevent Twitter from receiving this information in the future and being able to connect it to your Twitter profile, you must unsubscribe from Twitter before you visit our website. For more details, please refer to Twitter’s privacy policy.

Our website may include an integrated “XING Share Button” with which you can share the content of our website through a link with your Xing contacts. XING buttons are also integrated and contain a link to our XING profile. When you access our website, a temporary connection to servers of XING AG, Dammtorstrasse 30, 20354 Hamburg, Germany (“XING“), is established via your browser, with which the functions of the “XING Share Button” are executed (especially the calculation/display of the counter value). XING does not store any personal data about you when you visit our website, especially not your IP address. Also an evaluation of your user behavior by the use of cookies does not take place in connection with the “XING Share Button”. For more details, please refer to the respective XING Privacy Policy.

Our website may include plug-ins of the Instagram service. These are offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA (“Instagram“). We use the built-in Instagram buttons to link our Instagram profile. In addition, a widget is integrated that allows us to display certain photos and videos from our Instagram profile on our website. When you visit a website that contains such a plug-in, your browser connects directly to an Instagram server. The contents of the plug-ins are transmitted directly to your browser and integrated into the website. The data is automatically transferred to Instagram and stored on its servers. Among other things, connection data (e.g. Your IP address, date and time, the URL (address of a website) accessed, and information about the browser and operating system used. This allows Instagram to track your visit to our website even if you are not actively using the plug-in features.

If you are logged in to Instagram, you can link the content of our websites to your Instagram profile by clicking on the Instagram button. In this way, Instagram can connect your visit to our websites with your user account. If you want to disable this immediate mapping, you must unsubscribe from Instagram before you visit our website. For more details, please refer to Instagram’s privacy policy.

Our website may include plug-ins of LinkedIn’s linkedin social network, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn“). For this purpose, we use the “in” button to share content and link our LinkedIn profile. LinkedIn collects information that our corresponding pages have been loaded into your web browser using LinkedIn’s plug-ins. In addition, LinkedIn automatically receives the URL of the website you have previously visited or to which you will be redirected. LinkedIn also receives the IP address of your computer or proxy server that you use to access the Internet, information about your computer’s operating system and web browser, your mobile device (including the mobile device identifier that is operating system of your mobile device), your mobile device’s operating system (if you access LinkedIn with a mobile device), and the name of your Internet or mobile service provider. LinkedIn may also receive location data that is transmitted by GPS-enabled devices if you enable this feature, unless you have set your mobile device so that LinkedIn does not receive real-time location data. Please note that SlideShare.net, Pulse.me and the Pulse app are not part of our websites, but are part of LinkedIn’s services.

Information on the purpose and scope of the data collection as well as the further processing and use of the transmitted data using the linkedin plug-ins can be found in LinkedIn’s privacy policy.

The use and operation of SWISSCHANGE social media channels is governed by SWISSCHANGE Terms of Use for Social Media.

14. Left

Our website may contain links to the websites of other companies (“third-party websites”) that are not operated or monitored by us. Please note that such third-party websites are not bound by this Privacy Policy or our Cookie Policy and that we are not responsible for the content or rules governing the handling of the personal data of such websites. Therefore, we recommend that you familiarize yourself with and review the respective privacy and cookie policies of third-party websites.

Despite careful control of content, we assume no liability for the content of external links that refer to third-party websites. The operators of third parties are solely responsible for the content of the linked websites. We hereby expressly dissociate ourselves from all content on third-party websites that are linked to our website and do not adopt these contents as our own.

15. Contact

Please let us know if we do not meet your personal data processing expectations or if you wish to complain about our privacy practices. This gives us the opportunity to examine your request and, if necessary, to make improvements. In such cases, please always send a clear written request to the following body or one of the following data protection officers:

SWISSCHANGE Financial Services Ltd
Aeschenplatz 6
CH-4152 Basel
Phone +41 61 264 00 50
info@swisschange.ch www.swisschange.ch

17. Changes to the Privacy Policy

We reserve the right to change this Privacy Policy without prior notice. Therefore, we recommend that you check this website regularly. This Privacy Policy was last amended on May 25, 2018.