Swiss Bankers Association Privacy Notice
1. What is this Privacy Notice about?
The Swiss Bankers Association (Swiss Banking) (also “we”, “us”) collects and processes personal data that concern you or other individuals (“third parties”). We use the word “data” here interchangeably with “personal data”.
“Personal data” means data relating to identified or identifiable individuals, which means that the relevant data, either alone or in combination with additional data, make it possible to draw conclusions about the identity of these individuals. “Sensitive personal data” is a subset of personal data that is specially protected under applicable data protection law. This includes, for example, data revealing racial or ethnic origin, health data, religious or ideological beliefs, biometric data for identification purposes and information relating to trade union membership. In Section 3, you will find information about the data we process in accordance with this Privacy Notice. “Processing” means any operation that is performed on personal data, such as collection, storage, use, alteration, disclosure and erasure.
In this Privacy Notice, we describe what we do with your data when you use www.swissbanking.ch or our other websites (collectively “website”), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. When appropriate, we will inform you in writing in good time of any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.
If you disclose data to us or share data with us about other individuals, such as co-workers, we assume that you are authorised to do so and that the relevant data are accurate. You confirm that this is the case when you share such data with us. Please make sure that these individuals have been informed about this Privacy Notice.
This Privacy Notice is aligned with the requirements of the EU’s General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection (“FADP”) and the revised Swiss Federal Act on Data Protection (“revFADP”). However, the applicability of these laws depends on each individual case.
2. Who is the controller for processing your data?
The Swiss Bankers Association (Swiss Banking), Basel (the “Swiss Bankers Association” or “SBA”) is the controller for the processing of data by the Swiss Bankers Association (Swiss Banking) under this Privacy Notice, unless we tell you otherwise in an individual case, for example in additional privacy notices, on a form or in a contract.
For each processing activity, there are one or more parties that are responsible for ensuring that the processing complies with data protection law. This party or parties is/are called the controller. The controller is responsible, for example, for responding to information requests (Section 11) and for ensuring that personal data are processed securely and not used in an unlawful manner.
Additional parties may be joint controllers for the processing set out in this Privacy Notice if they participate in determining the purpose or means of the processing. The Swiss Bankers Association remains your primary contact, even if there are other joint controllers.
In Sections 7 and 12, you will find additional information about third parties with whom we work together and who are controllers for their processing. If you have any questions for these third parties or wish to exercise your rights against them, please contact them directly.
You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:
Swiss Bankers Association (Swiss Banking)
P.O. Box 4182
3. What data do we process?
We process various categories of data about you. The main categories of data are the following:
- Technical data: When you use our website or other online offerings, we may collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. These data include logs recording the use of our systems. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example in the form of a cookie, see Section 12). Technical data are anonymised on our systems and do not in principle permit us to draw conclusions about your identity.
- Registration data: Certain offerings, for example competitions and services (such as login areas of our website, newsletters etc.), can only be used with a user account or registration. You must provide us with certain data for this purpose, and we collect data about the use of the offering or service. If we issue a voucher to you for one of our contractual partners, we may share some of your registration data with the relevant contractual partner or receive such data (see Section 7). Registration data may be required in relation to access control to certain facilities. We generally keep registration data for 12 months from the date the use of the service ceases or the user account is closed.
Registration data include the information you provide when you create an account on our website (for example username, password, name, e-mail address). They also include the data that we may require from you before you can use certain free services, such as redeeming vouchers, in which case we require your name, address and contact details and the time of redemption. You must also register if you wish to subscribe to our newsletter. In relation to access controls, we may need to register you with your data (access codes in badges) (see the category “other data”).
- Communication data: When you are in contact with us via the contact form, e-mail, telephone, chat, letter or any other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will inform you specifically of this fact. Such recordings may only be made and used in accordance with our internal policies. You will be informed if and when such recordings take place, for example by an indication during the video conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we wish or need to determine your identity, for example in relation to a request for information, press access etc., we collect data to identify you (for example a copy of an identification document). We generally keep these data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years. Recordings of (video) conferences are usually kept for 24 months.
Communication data are your name and contact details, the means, place and time of communication and usually also its content (i.e. the content of e-mails, letters, chats etc.). These data may also include information about third parties. For identification purposes, we may also process your identification document number or a password set by you or your press pass. For secure identification, the following information must be provided for media inquiries: publisher, name of publication, title, first name, surname, postal address, e-mail address and telephone number of the reporter.
- Master data: Master data are the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details as well as information about, for example, your role and function, your bank details, history, powers of attorney, signature authorisations and declarations of consent. We process your master data if you are a member, customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising or with invitations to events, vouchers, newsletters etc.). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media etc.). We may also process information about third parties as part of master data. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
Master data include data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, social media profiles, photos and videos, copies of identification documents, details of your relationship with us (member, customer, supplier, visitor, service recipient etc.), details of your status with us, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (for example from the media) or official documents (for example excerpts from the commercial register, permits etc.) that concern you. As payment information, we collect, for example, your bank details and account number. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives.
In relation to contact persons and representatives of our members, customers, suppliers and partners, master data we process include, for example, name and address, information about the role or function in the company, qualifications and (where applicable) information about superiors, co-workers and subordinates as well as interactions with these.
Master data are not collected comprehensively for all contacts. The data collected in an individual case depend in particular on the purpose of the processing.
- Contract data: These are data collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction etc.). This includes information about third parties. We generally collect these data from you, from contractual partners and from third parties involved in the performance of the contract, as well as from third-party and public sources. We generally keep them for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
Contract data include information about the conclusion of the contract, about your contracts, for example, the type and date of conclusion, information from the application process (such as an application for our products or services) and information about the relevant contract (for example its duration) and the performance and administration of the contracts (for example information related to billing, technical assistance and enforcement of contractual claims). Contract data also include information about deficiencies, complaints and changes to a contract, as well as information about customer satisfaction that we may collect, for example, through surveys. Contract data also include financial data, such as information on creditworthiness (meaning information that allows us to draw conclusions about the likelihood that receivables will be paid), reminders and debt collection. We receive this data partly from you (for example when you make payments), but also from public sources (for example a commercial register).
- Behavioural and preference data: Depending on our relationship with you, we try to tailor our products, services and offers to you. For this purpose, we collect and process data about your preferences. We do so by evaluating information in our domain. The data processed for this purpose are already known to us (for example when you use our services). We anonymise or delete these data when they are no longer relevant for the purposes pursued. We describe how your behaviour is tracked on our website in Section 12.
- Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence etc.) are processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example at events, with security cameras etc.). We may also collect data about who enters certain buildings or has access rights and when (including in relation to access controls, based on registration data or lists of visitors etc.), who participates in events or campaigns (for example competitions) and when, and who uses our infrastructure and systems and when. Moreover, we collect and process data about our members; in addition to master data, these include information relating to the exercise of their rights and the conduct of events (for example general meetings). The retention period for these data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many security cameras, to a few weeks for contact tracing and visitor data, which are usually kept for 3 months, to several years or more for reports about events with images. Data relating to you as a member are kept in accordance with the law on associations.
Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website etc.). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioural and preference data, you generally have the option of objecting or not giving consent.
We provide certain services to you only if you provide us with registration data, because we or our contractual partners wish to know who uses our services or has accepted an invitation to an event, because it is a technical requirement or because we wish to communicate with you. If you or a person you represent (for example your employer) wishes to enter into or perform a contract with us, we must collect master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offerings for this purpose. If you do not provide us with the data necessary for the conclusion and performance of the contract, you should expect that we may refuse to conclude the contract, that you may commit a breach of contract or that we will not perform the contract. Similarly, we can only respond to a request from you if we process communication data and – if you communicate with us online – possibly also technical data. Also, the use of our website is not possible without us receiving technical data.
To the extent permitted by law, we also collect data from public sources (for example debt collection registers, commercial registers, the media or the internet, including social media) or receive data from public authorities and other third parties (such as address brokers, associations, contractual partners, internet analytics services etc.).
The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we receive in relation to administrative and legal proceedings, information in relation to your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your assistance), information about you in correspondence and meetings with third parties, information about you that persons associated with you (family members, advisors, legal representatives etc.) share with us so that we can conclude or perform contracts with you or involving you (for example references, your delivery address, powers of attorney, information about compliance with legal requirements such as those relating to fraud prevention and the combating of money laundering and terrorist financing, export restrictions, information from banks, insurance companies, sales and other contractual partners of ours about your use or provision of services (for example payments, purchases etc.), information from the media and the internet about you (where appropriate in a specific case, for example in the context of an application, press review etc.), your address and potentially interests and data in relation to the use of third-party websites and online offerings where such use can be linked to you.
4. For what purposes do we process your data?
We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent our interests and potentially those of third parties. You can find further information on the legal basis of our processing in Section 5.
We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, as well as registration data in relation to offers and services that you use. We keep these data to document our communication with you and for training purposes, quality assurance and follow-up inquiries.
The above includes all purposes in relation to which we communicate with you, whether in the context of authentication for use of the website or for training and quality assurance. We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an information request. Our processing also serves to document the communication and its content.
We process data to conclude and administer memberships and contractual relationships as well as to fulfil obligations relating to these.
We admit members and conclude a wide range of contracts with our customers, suppliers, subcontractors and other contractual partners, such as partners in projects or parties in legal proceedings. In this regard, we process in particular master data, contract data and communication data and, depending on the circumstances, registration data.
In the process of initiating a business relationship, personal data – in particular master data, contract data and communication data – is collected from potential members, customers or other contractual partners (for example in an order form or a contract) or results from communication with these. In some cases, this information is reviewed in order to comply with legal requirements.
In the course of fulfilling our obligations in relation to memberships and contractual relationships, we process data for the administration of the relationship, to provide and procure performance (which includes involving third parties) and for relationship management. Performance also includes the enforcement of legal claims (debt collection, legal proceedings etc.) as well as accounting, termination of memberships and contracts, and public communication.
We process data for marketing purposes and relationship management, for example to send our members, customers and other contractual partners advertising for our own products and services and those of third parties (for example advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by post or by telephone), through other channels for which we have contact information from you, or as part of marketing campaigns (for example events, contests etc.) and may also include free services (for example invitations, vouchers etc.). You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes.
For example, if you consent, we may communicate our own information, advertising and product offers as well as those of third parties (for example advertising partners) to you in printed or electronic form or by telephone. For this purpose, we process in particular communication and registration data. Like most companies, we personalise communications so that we can provide you with customised information and offers in line with your needs and interests. For this purpose, we combine data we process about you, collect preference data and use these data as a basis for personalisation (see Section 3). We also process data in relation to contests, competitions and similar events.
Relationship management includes addressing existing members, customers and their contacts. In the context of relationship management, we may also operate a customer relationship management (“CRM”) system in which we keep data on members, customers, suppliers and other business partners that are required for relationship management, for example data about contact persons, relationship history (for example products and services purchased or supplied, interactions etc.), interests, preferences, marketing measures (newsletters, invitations to events etc.) and other information.
All of this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with members, customers and other third parties more personal and positive, to focus on the most important relationships and to use our resources as efficiently as possible.
We further process your data to improve our services and operations and for product development.
We strive to improve our products and services (including our website) continuously and to respond quickly to changing needs. We therefore analyse, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details, see Section 12). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioural data and preference data as well as communication data and information from customer surveys, polls and studies and other information, for example from the media, social media, the internet and other public sources. We use pseudonymised or anonymised data for these purposes as far as possible. We may also use media monitoring services or conduct media monitoring ourselves and process personal data in order to conduct media monitoring or to understand and respond to current developments and trends.
We may also process your data for security and access control purposes.
We continuously review and improve the appropriate security of our IT and other infrastructure (for example buildings). Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. We therefore process data, for example, for monitoring, inspection, analysis and testing of our networks and IT infrastructures, for system and error checks, for documentation purposes and in the context of backups. Access controls include electronic system access controls (for example logging into user accounts) as well as physical access controls (for example building access). For security purposes (to prevent and investigate incidents), we also keep access logs and use surveillance systems (for example security cameras). We inform you about surveillance systems at the relevant locations through appropriate signage.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations (“compliance”).
This includes, for example, the implementation of health and safety policies. Disclosure and information or reporting obligations, for example in connection with supervisory and tax obligations, also require or entail data processing, for example archiving obligations and the prevention, detection and investigation of criminal offences and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example by a law enforcement or supervisory authority or by a mandated private entity. Furthermore, we process data in order to serve our members and to fulfil our obligations in this regard. For all these purposes, we process in particular master data, your contract data and communication data as well as, under certain circumstances, behavioural data and data falling under the category of “other data”. Legal obligations may arise under Swiss law or under foreign regulations to which we are subject, as well as self-regulation, industry standards, our own governance and instructions and requests from authorities.
We also process data for the purposes of our risk management and as part of our governance, including business organisation and development.
For these purposes, we process in particular master data, contract data, registration data and technical data, as well as behavioural and communication data. For example, as part of our financial management, we need to monitor our accounts receivable and accounts payable, and we need to avoid becoming victims of crime and abuse, which may require us to analyse data for relevant patterns of such activities. We may also conduct profiling and create and process profiles for these purposes and to protect you and ourselves from criminal or abusive activity (see also Section 6). In the context of planning our resources and organising our operations, we may need to evaluate and process data relating to the use of our services and other offerings or share information about them with others (for example outsourcing partners), which may also include your data. The same applies with respect to services provided to us by third parties.
We may process your data for further purposes, for example as part of our internal processes and administration or for training and quality assurance purposes.
These further purposes include, for example, training and educational purposes, administrative purposes (such as managing master data, accounting and data archiving, and testing, managing and continuously improving IT infrastructure), protecting our rights (for example to enforce claims in or out of court and before authorities in Switzerland and abroad or to defend ourselves against claims, for example by preserving evidence, conducting legal assessments and participating in court or administrative proceedings), and evaluating and improving internal processes. We may use recordings of (video) conferences for training and quality assurance purposes. These further purposes also include safeguarding other legitimate interests that cannot be listed exhaustively.
5. On what basis do we process your data?
Where we ask for your consent for certain processing activities, we inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us with written notice (by post) or, unless otherwise stated or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you originally consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, we process your personal data based on the need to do so in order to initiate or fulfil obligations in relation to a membership or a contract with you (or the entity you represent) or on a legitimate interest on our part or that of a third party in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognised as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and Switzerland).
Where we receive sensitive personal data (for example data about political opinions, religious or ideological beliefs), we may process your data on other legal bases, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defence of legal claims. In some cases, other legal grounds may apply, which we will communicate to you separately as necessary.
6. What applies in case of profiling and automated individual decisions?
We may automatically evaluate personal aspects relating to you (“profiling”) based on your data (Section 3) for the purposes set out in Section 4 if we wish to determine preference data or to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioural and preference data, as well as master data, contract data and technical data relating to you, in order to arrive at a better understanding of you as a person with your various interests and other characteristics.
In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can result in legal effects or significant disadvantages for you, we generally ensure human review.
In certain situations, it may be necessary for the efficiency and consistency of decision-making processes that we automate discretionary decisions that can result in legal effects or potentially significant disadvantages for you (“automated individual decisions”). In these cases, we will inform you accordingly and take the measures required by the applicable law.
7. With whom do we share your data?
In relation to our contracts, the website, our services and products, our legal obligations or protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:
- Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers.
To be able to deliver our products and services efficiently and focus on our core competencies, we procure services from third parties in various areas. In each case, we disclose to these providers the data they require for their services, which may also concern you. In addition, we enter into contracts with these providers that include provisions to protect data, where such protection is not required by law. In some cases, our service providers may also process data on how their services are used and other data generated in the course of using their services as independent data controllers for their own legitimate interests (e.g., for statistical analysis or billing purposes).
- Members: Data may be shared within the Swiss Bankers Association for the purposes of disseminating information among members or opinion-forming.
- Contractual partners and customers: This refers primarily to our customers and other contractual partners as this data disclosure results from the respective contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate.
- Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. These authorities act as separate controllers with respect to the data they receive from us about you.
Examples are criminal investigations, police measures (for example health and safety policies, the prevention of violence etc.), requirements and investigations under supervisory law, legal proceedings, reporting obligations and pre-court and out-of-court proceedings, as well as legal obligations to provide information and to cooperate. Data may also be disclosed if we wish to obtain information from public bodies, for example in order to justify a request for information or because we need to say about whom we require information (for example from a register).
- Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4, for example the media and associations in which we participate or if you are included in one of our publications.
Other recipients include, for example, delivery recipients or third-party payees specified by you or persons involved in administrative or legal proceedings. If we cooperate with the media and share materials with them (for example photos), this may also affect you, depending on the circumstances. The same applies if we publish content (for example photos, interviews, quotes etc.), for example on our website or in our other publications. In relation to communicating with competitors, industry organisations, associations and other bodies, data may be exchanged that also affect you.
All of these categories of recipients may involve third parties, meaning that your data may also be accessible to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks etc.).
We reserve the right to make such disclosures even of secret data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, except if we are required to do so by law). Your data nevertheless continue to be subject to adequate data protection in Switzerland and the rest of Europe, even after disclosure. For disclosure to other countries, the provisions of Section 8 apply. If you do not wish certain data to be disclosed, please let us know so that we can review whether and to what extent we can accommodate your concern (Section 2).
In many cases, even secret data must be disclosed in order to perform contracts or provide other services. Likewise, non-disclosure agreements generally do not exclude such disclosures of data nor disclosures to service providers. However, depending on the sensitivity of the data and on other circumstances, we ensure that these third parties handle the data appropriately. We cannot comply with your objection to the disclosure of data where the disclosure in question is necessary for our activities.
In addition, we enable certain third parties to collect personal data from you on our website and at events organised by us (for example press photographers, providers of tools on our website etc.). Where we have no control over these data collections, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 12 for the website.
8. Are your personal data sent abroad?
As explained in Section 7, we disclose data to third parties. These are not all located in Switzerland. Your data may therefore be processed in both Europe and the USA or, in exceptional cases, any country in the world.
If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection rules, unless the recipient is already subject to a legally accepted set of rules to ensure data protection and we are unable to rely on an exemption. An exemption may apply, for example, in case of legal proceedings abroad or in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if you have made the data available generally and have not objected to their processing.
Please note that data exchanged via the internet are often routed through third countries. Your data may therefore be sent abroad, even if the sender and recipient are in the same country.
9. For how long do we process your data?
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3 and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymise your data once the storage or processing period has expired as part of our usual processes.
Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep them together (for example in case of backups or document management systems).
10. How do we protect your data?
We take appropriate security measures in order to ensure the confidentiality, integrity and availability of your personal data, to protect them against unauthorised or unlawful processing, and to mitigate the risk of loss, accidental alteration, unwanted disclosure or unauthorised access.
Technical and organisational security measures may include encryption and pseudonymisation of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering into confidentiality agreements and monitoring. We protect your data sent through our website in transit by means of appropriate encryption. However, we can only secure areas under our control, and security risks can never be excluded completely; residual risks are unavoidable.
11. What are your rights?
Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
- The right to request information from us as to whether we process your data, and if so which data;
- The right to have us correct data if it is inaccurate;
- The right to request erasure of data;
- The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
- The right to withdraw consent, where our processing is based on your consent;
- The right to receive, upon request, further information that is helpful for the exercise of these rights.
If you wish to exercise the above rights in relation to us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of an identification document if there is no alternative means of identification).
You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. See Section 12 for the website.
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example by redacting content that concerns third parties or our trade secrets).
If you do not agree with the way we handle your rights or with our data protection practices, please let us know. If you are located in the EEA, the United Kingdom or Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.
12. Do we use online tracking techniques?
We use various techniques on our website that allow us and third parties engaged by us to recognise you during your use of our website and possibly to track you across several visits. This Section informs you about this.
In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalisation. We do not intend to determine your identity. However, the technologies we use may be designed in such a way that you can be recognised as an individual visitor each time you access the website, for example by our server (or third-party servers) assigning a unique identification number to you or your browser (in the form of a “cookie”).
Cookies are individual codes (for example a serial number) that our server or a server of our service providers or advertising partners transmits to your system when you connect to our website and that your system (browser or mobile phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognised even if your identity is unknown.
Whenever you access a server (for example when you use a website or an app, or because an e-mail includes a visible or invisible image), your visits can therefore be tracked. If we integrate offers from a provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in a particular case.
We use these technologies on our website and allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for your consent before they are used. You can access your current settings here. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword “privacy”) or on the websites of the third parties set out below.
We distinguish the following categories of cookies:
- Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies are only temporary (“session cookies”). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality etc.). These cookies remain valid for up to 36 months.
We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example by clicking a button), these providers can determine that you are using our website. If you have an account with a particular social media provider, it can assign this information to you and thereby track your use of online offers. These social media providers process these data as separate controllers.
We currently use offers from the following service providers:
13. Which data do we process on our social network pages?
We may operate pages and other online presences on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and subsequent sections. We receive these data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyse your use of our online presences and combine these data with other data they have about you (for example about your behaviour and preferences). They also process these data as separate controllers for their own purposes, in particular for marketing and market research purposes (for example to personalise advertising) and to manage their platforms (for example what content they show you).
We receive data about you when you communicate with us through online presences or view our content on the corresponding platforms, visit our online presences or are active on them (for example publish content, submit comments). These platforms also collect technical data, registration data, communication data, behavioural data and preference data from you or about you, among other things (see Section3 for explanations of these terms). These platforms regularly perform statistical analysis of the way you interact with us, how you use our online presences and our content or other parts of the platform (what you view, comment on, like, share etc.) and combine these data with other information about you (for example information about your age and gender as well as other demographic information). In that way, they create profiles about you and statistics on the use of our online presences. They use these data and profiles to display our advertisements or those of third parties and other personalised content to you on the platform and to manage the behaviour of the platform, as well as for market and user research and to provide us and other parties with information about you and the use of our online presence.
For further information on processing by platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other rights as a data subject, and how you can exercise them or obtain further information. We currently use the following platforms:
- Facebook: Here we operate the page Swiss Banking - Schweizerische Bankiervereinigung. The controller for the operation of the platform for users from Europe is Facebook Ireland Ltd., Dublin, Ireland. Its privacy notice is available here.
- LinkedIn: Here we operate the page Swiss Banking - Schweizerische Bankiervereinigung. The controller for the operation of the platform for users from Europe is LinkedIn Ireland Unlimited Company, Dublin, Ireland. Its privacy notice is available here.
- Twitter: Here we operate the page Swiss Banking - Schweizerische Bankiervereinigung. The controller for the operation of the platform for users from Europe is Twitter International Unlimited Company, Dublin, Ireland. Its privacy notice is available here.
- YouTube: Here we operate the page Swiss Banking - Schweizerische Bankiervereinigung. YouTube is a subsidiary of Google Ireland Limited, Dublin, Ireland. Its/Google’s privacy notice is available here.
14. Can we update this Privacy Notice?
This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.
Last updated: 13 October 2022