Startseite Privacy Policy

Privacy Policy

This Privacy Policy (hereinafter referred to as “Privacy Policy”) sets out the principles according to which Globalance Bank AG (hereinafter referred to as “Bank”, “we” or “the Controller”) processes personal data that the Bank collects via this website www.globalance.com (hereinafter referred to as “the Website”) or in any other way. In particular, it informs you about what personal data we collect, for what purposes it is processed, with whom it can be shared, for how long we will retain it and what rights and possibilities you have in relation to the use of your personal data. “Personal data” means any information about an identified or identifiable natural person, such as e.g. name, address, e-mail address, online identifier or telephone number. “Processing” includes any manner of data processing, such as collecting, capturing, storing, organising, arranging, using, disclosing by transmission, linking and erasing.

This Privacy Policy applies insofar as the processing activities are not subject to other privacy policies or are provided for by applicable law. Please read this Privacy Policy carefully. By using our services, you consent to the collection and processing of your personal data in accordance with this Privacy Policy.

If you provide us with personal data of other persons (e.g. another person to accompany you during an event), please provide their personal data only if you are authorised to do so in accordance with the applicable data protection laws and only if the other person agrees to you providing us with their personal data for the purposes of data collection and processing in accordance with our Privacy Policy.

CONTENTS

Controller of Data Processing
How Do We Process Personal Data
Fr om Whom Do We Collect and Process Personal Data
Data Sources
What Personal Data Do We Collect for Which Processing Purposes
5.1 Automatically Transmitted Information
5.2 Information You Provide Via the Online Form, E-Mail or Phone
5.3 Information Collected or Generated in Connection with the Registration of or Login to a User Account
5.4 Information Collected or Generated in Connection with a Personal Advisory Activity, whether Remunerated or Not
5.5 Information That We Collect from Our Business Partners and Process
5.6 Newsletters and Other Information for Promotional Purpose
5.7 Automatically Transmitted Information
5.8 Information We Collect in the Context of a Job Application
On What Legal Basis Do We Process Your Personal Data
To Whom Will We Pass on Your Personal Data
Transfer of Personal Data to Countries outside the EEA
For How Long Do We Store Information About You
Cookies, Google Services and Social Media Plug-Ins
No Automated Decision-Making, Including Profiling, with Legal Effect
Security
Privacy Policies of Third Parties
Rights of the Data Subject
Changes to Our Privacy Policy

1. Controller of Data Processing

The controller and thus the person responsible for processing the personal data in accordance with this Privacy Policy is:

Globalance Bank AG
Gartenstrasse 16
CH-8002 Zurich, Switzerland

Globalance Bank AG determines the purposes and means for processing your personal data and is therefore responsible for the processing and use of your personal data in accordance with this Privacy Policy (i.e. is the controller).

In case of any questions regarding this Privacy Policy, the data subject may contact the data protection officer of Globalance Bank AG:

Globalance Bank AG
Data Protection Advisor
Gartenstrasse 16
CH-8002 Zurich, Switzerland
E-mail: [email protected]

2. HOW WE DO PROCESS PERSONAL DATA

All personal data collected by the Bank through the Website or otherwise will be processed in accordance with the provisions of the Swiss Data Protection Act and the European General Data Protection Regulation (GDPR). The General Data Protection Regulation has established itself on a worldwide basis as a standard for strong data protection. However, it depends on the individual case in question whether and to what extent the GDPR is applicable.

We collect and process personal data carefully and for the purposes described in this Privacy Policy. All our business processes are designed in such a way that we offer you the highest level of confidentiality and security. In accordance with the applicable law, we may also use your personal data in other ways than those described in this Privacy Policy. In this case, we will provide specific privacy policies or notifications at the time of collection and obtain your consent, if necessary. We always endeavour to collect reasonable information in anonymised or pseudonymised form so that we will not be able to gain knowledge of your identity.

3. From Whom Do We Collect and Process Personal Data

The Bank collects and processes personal data in principle from the following persons:

Users of our Websites (including social media such as Facebook and LinkedIn);
Persons interested in our services and products;
Potential and existing clients;
The client’s representative or caregiver;
The legal guardian of the client;
The client’s beneficial owner;
The client’s contractual partner;
Employees of clients and business partners;
Webinar participants;
Recipients of newsletters and other personalised and non-personalised promotional information;
Job applicants.

4. Data Sources

The Bank primarily processes data that it collects directly from the data subject via the Website or that it receives as a result of a business relationship and that is necessary for this purpose. In addition, the required data is also obtained from other financial institutions, external asset managers, intermediaries, relatives (family members) and publicly available sources, in particular debtor registers, land registers, commercial registers, as far as this is necessary for the fulfilment of our tasks.

5. What Personal Data Do We Collect for Which Processing Purposes

5.1 Automatically Transmitted Information

The Bank collects and stores information that your browser automatically transmits to us when you visit our Website in “server log files”. The data collection is based on your willingness and interest to visit our Website and our legitimate interests in operating the Website. The data collected might include the following:

Browser type and browser version;
Operating systems used;
Referrer URL (website visited before);
Host name of the accessing computer;
Date and time of the server request;
Internet protocol address (IP address);
Amount of data transferred;
Other similar data and information used for hazard prevention in the event of attacks on our IT systems.

This data will not be merged with any data from other sources. We store this data for a short period of time until it is automatically erased after a period of three to six months.

The Bank also collects personal data through cookies that are used on our Websites. More information about our cookies can be found in Section 10 below and in our Cookie Policy here.

This data is processed for the purpose of the proper functioning and administration of our Website, e.g. to establish a connection, to ensure stability and uninterrupted system security, to improve our services, to protect our systems and for statistical purposes in the event of attacks on the network infrastructure on which the Website is made available.

These purposes constitute the legal basis for our legitimate interests (point f of Art. 6 (1) of the GDPR) to process your personal data accordingly.

5.2 Information You Provide Via the Online Form, E-Mail or Phone

We collect and generate information that you provide to us actively and voluntarily, with your consent and/or prior to entering into a contract with us, through an online form, by registering for an online webinar or event, by sending a message to our contact e-mail address, by post or by telephone. This may include the following personal data, whereby the data requested in fields marked with * in the form is mandatorily required to enable the processing of your request:

First name, surname, street/no., post code/town, telephone number, e-mail address, other information about you;
Your interests, desired contact person, contact;
- Opt-in to our General Terms and Conditions, opt-in to receiving the print edition by post, opt-in for the electronic provision of various manners of information about our products and services (incl. to download such product and service information);
- Whether you will be attending an event alone or accompanied by another person;
Image material (e.g. photographs or video recordings) taken during a webinar or event;
Voice recordings of telephone conversations conducted with the Bank.

We will use the information you provide to process and respond to your request or for the legitimate purposes arising from the relevant circumstances, which may include the following purposes:

To best answer your questions or requests about our products and services, to ask you questions, and to provide you with additional information about our products and services that is tailored to your request or interests;
To communicate with you (e.g. about our services, including customer service), to process registrations, to arrange appointments and to provide you with the best information you need from us before, during or after the termination of a contract;
To record and store telephone conversations with the Bank for evidence purposes in accordance with the law;
To register for and to perform online webinars and events;
To use the image material for business and advertising purposes (such as e.g. to document events organised by us in images and report on them positively to a larger public);
For personalised marketing and promotional purposes;
For statistical and analytical purposes, to develop new and/or improve existing products and services;
To comply with legal or other regulatory requirements and internal regulations;
To establish, exercise and/or defend against actual or potential legal claims, investigations or similar proceedings;
For other legitimate purposes, insofar as such processing is the result of the circumstances or was specified at the time of collection.

These purposes constitute the legal basis for our legitimate interests (point f of Art. 6 (1) of the GDPR) in offering you an optimum service or prior to entering into a contract with you (point b of Art. 6 (1) of the GDPR).

We collect and generate information when you wish to register for a user account on our Website. This may include the following personal data, whereby the data requested in the fields marked with * are mandatorily required for the processing of the requested services:

E-mail address, password, IP address, time of the respective user action, further information about you.

If you already have a user account, we will collect the following personal data when you log in:

E-mail address, password, IP address, time of the respective user action, further information about you.

The communication of this personal data is always voluntary, on the basis of your consent or a contract, in order to fulfil the services requested by you. Please note that without the provision of this information, the requested service, for which the information is required, cannot be provided or not in the desired quality.

We will use the information collected from you to best perform the services you request, which may include the following purposes:

To manage your address information;
To provide the client portfolio and further information on asset investments;
For statistical and analytical purposes in order to develop new and/or improve existing products and services.

These purposes form the legal basis for our legitimate interests (point f of Art. 6 (1) of the GDPR) in offering you a secure and optimum service or prior to entering into a contract with you and/or for the establishment and execution of a contract with you (point b of Art. 6 (1) of the GDPR).

The user accounts are not public and cannot be indexed by search engines, such as e.g. Google. The client may erase their user account at any time. In this case, any client portfolios and asset investments will be made available by other means (e.g. by post) at the request of the client.

5.4 Information Collected or Generated in Connection with a Personal Advisory Activity, Whether Remunerated or Not

We collect and generate information when you have chosen to make use of a consulting service or a product. This may include the following personal data:

Legitimation and contact details: to contact the data subject (e.g. first name and surname, date and place of birth, address, nationality, e-mail address, telephone number);
Politically exposed persons (PEP) status to prevent money laundering;
Order and revenue data: to carry out account management (e.g. account number, deposit number, IBAN, deposits and withdrawals, bank transfer);
Financial situation: to check whether and which product or service can be offered (when purchasing financial instruments, among other things, e.g. origin and value of assets, information on creditworthiness, payment behaviour, income, expenses, insurance, company shareholdings, information on real estate);
Other socio-demographic characteristics: to be able to carry out requirement analyses (e.g. marital status, occupation, education, family relationship);
Tax data: in order to pay the tax due to the competent tax office (e.g. tax number, tax identification number, tax allowances, tax residence) within the framework of the tax deduction;
Activities: such as hobbies and membership in associations and similar, as far as this is necessary from a compliance perspective (such as the CDB (Agreement on the Swiss Banks’ Code of Conduct with regard to the Exercise of Due Diligence) and KYC obligations).

The provision of this personal data will always be made on a voluntary basis, based on your consent to use our products or services or to provide the products or services requested by you on the basis of a contract with us. Please note, however, that you are obliged to disclose such personal data that the Bank is legally obliged to process and that is necessary for the establishment and execution of the contractual relations. Without the personal data to be processed, the Bank will usually not be able to conclude a bank-typical contract with the data subject and to fulfil the contractual and legal obligations. For example, anti-money laundering regulations require the Bank to identify its contractual partner, any persons and beneficial owners acting on their behalf prior to establishing the business relationship or prior to performing a transaction. If changes occur in the course of the business relationship, the data subject shall notify the Bank of these changes without delay. Otherwise, the Bank may not enter into or continue the desired business relationship.

We will use the information collected from you to best perform the services you request, which may include the following purposes:

To enable you to select, order, pay for the services selected, and to enable us to perform it;
For providing advisory services under a typical banking contract, to perform and fulfil the contract;
For billing our services;
For providing customer services;
For communicating with you and to give you the best possible advice that you would like us to provide before or during a contract;
For answering your questions or requests about our services in the best possible way, to ask you questions and to provide additional information, tailored to your request or interests, in connection with our services, including personalised marketing and advertising information;
For requirement analyses and product optimisation;
For statistical and analytical purposes, to develop new and/or improve existing products and services;
In order to comply with legal or other regulatory requirements and internal regulations (e.g. the processing of the status as a politically exposed person is a significant public interest for combating money laundering and is thus required under the Money Laundering Act);
For security reasons (e.g. any video recordings serve to prevent and prosecute any potential criminal acts);
To establish, exercise and/or defend against actual or potential legal claims, investigations or similar proceedings;
For other legitimate purposes, insofar as such processing is the result of the circumstances or was specified at the time of collection.

The processing takes place for the purpose of providing contractual services in the context of a bank-typical contract (point b of Art. 6 (1) of the GDPR) as well as within the scope of fulfilling legal obligations (point c of Art. 6 (1) of the GDPR) or of our legitimate interests in the context of storing, archiving or advertising of our products and services (point f of Art. 6 (1) of the GDPR).

5.5 Information That We Collect from Our Business Partners and Process

We collect and process personal data about you, as an employee or as a person acting on behalf of a business partner (e.g. contractual partner of the client, clients and other business partners and service providers) (hereinafter referred to as “Business Partners”), by e-mail, by telephone, by mail, or in any other way in connection with the conclusion or fulfilment of a contract with you or our Business Partner. This may include the following personal data:

Surname, first name, company addresses, e-mail address, telephone number, IP address, passwords, additional information about an employee;
The Business Partner’s message or request;
Invoice data, order data. We need this data for the proper establishment and performance of the contractual relationship and the fulfilment of the associated contractual obligations or if this is required by law. If we do not receive this information, we will generally be unable to conclude or perform the contract with our contract partner or to provide the service in the desired quality.

We will use the information collected from our Business Partners to provide the best possible consulting and customer service, which may include the following purposes:

To fulfil and perform our contractual obligations towards our contractual partners and our clients (e.g. preparation of offers, order handling, settlement, confidentiality agreement);
To answer your questions or requests about our products and services in the best possible way, to ask you questions and to provide additional information in connection with our products and services that is tailored to your request or interest;
To communicate with you and to advise you in the best possible way if you ask us to do so prior to or during a contract;
To register for and perform online webinars and events;
For personalised marketing and promotional purposes;
For requirement analyses and product optimisation;
For statistical and analytical purposes, to develop new and/or improve existing products and services;
To comply with legal or other regulatory requirements and internal regulations;
To establish, exercise and/or defend against actual or potential legal claims, investigations or similar proceedings;
For other legitimate purposes, provided that such processing is the result of the circumstances or was indicated at the time of collection.

5.6 Newsletters and Other Information for Promotional Purposes

Newsletter registration with us involves the collection of personal data, whereby the data in the fields marked with * must obligatorily be provided in order for us to be able to process the requested newsletter:

First name, surname, street/no., place/town, e-mail, acceptance of our general terms and conditions.

We will use the data saved as part of the registration for the newsletter exclusively for our newsletter. If you want to unsubscribe from the newsletter, you will find a link at the bottom of the newsletter itself or may write an e-mail to [email protected].

In addition, we might install coding (e.g. web beacons or pixel tags) in the newsletters. These coding in newsletters helps us to obtain information about the address file used, the subject and the number of newsletters sent. In addition, it is possible to see which addresses have not yet received the message, to which address the newsletter was sent and at which addresses delivery has failed. In addition, the coding can indicate which addresses have opened the newsletter and which addresses have cancelled the subscription.

We will use this data for statistical purposes and to optimise the content and structure of the newsletter.

With the data we would also send other informational and promotional material related to the bank. If you register for an event, the data will also be used to send further information and advertising material. The information and advertising material will be sent to you on a regular basis.

In the event of an inquiry about services or products (e.g. Zukunftsbeweger magazine and/or events), we reserve the right to send you information and advertising material.

However, the recipient can block this application in their e-mail programme or they can unsubscribe from the newsletter at any time if they do not agree with the application of this technology. As recipient can have your contact details deleted at any time by sending an e-mail to [email protected].

5.7 Information We Collect in the Context of a Job Application

We collect information that you provide to us actively and voluntarily, with your consent and/or prior to a potential employment contract with us by sending your application documents via our contact e-mail address or by telephone. This may include the following personal data:

Information that you provide to us during the application process, such as title, surname, first name, address, e-mail address, telephone number, spoken language, CV, qualifications, written work references, school diplomas, further training courses, experience, your skills and abilities, extract from the debt register and criminal record (insofar as such are necessary for the position advertised), further information about you;
Information we collect during our interview and appraisal process, including queries made with previous employers, if you agreed to such collection;
Publicly available professional data about you, such as e.g. data published on business and employment-related social networks (“Professional Data from Social Networks”).

We process such job application and social network data for the following purposes:

To process your application;
To assess qualifications and personal experience;
To provide you with information about your job application and to make your application process as supportive and effective as possible.

After completing the applicant selection process, your application data will be erased within three months if you were unsuccessful in the applicant selection process.

6. on what lEGAL BASIS DO WE PROCESS YOUR PERsONAL DATA

The processing of your personal data might be based on the following legal bases:

Your consent, only if it can be withdrawn at any time (e.g. newsletter, tracking cookies) (point a of Art. 6 (1) of the GDPR);
For the performance of a contract with you or for the intention to conclude a contract with you (e.g. for advisory activities in the context of asset investments and financial services) (point b of Art. 6 (1) of the GDPR);
To comply with a legal or regulatory obligation (e.g. for tax reasons or to comply with legal requirements under the Money Laundering Act. In this respect, the Bank needs the data for purposes such as to verify your identity, for tax control and reporting obligations, fraud and money laundering prevention, as well as the assessment and management of risks, or for the purpose of judicial investigations or procedures.) (point c of Art. 6 (1) of the GDPR); or
For the purposes of public interest (e.g. some processing procedures are carried out on the basis of the performance of tasks carried out in the public interest. These include, in particular, the tax control and reporting obligations and the fight against money laundering and against the financing of terrorism.) (point e of Art. 6 (1) of the GDPR).
For the purpose of our legitimate interests, e.g. to maintain and improve our internal business administration, organisation, operation, protection of systems and premises, to prevent fraud and other crimes, to ensure an effective, efficient, secure and harmonised service, to comply with legal or other regulatory requirements and internal regulations, and to establish, exercise and/or defend actual or potential legal claims, investigations or similar procedures (point f of Art. 6 (1) of the GDPR). However, this is only done if these interests prevail after weighing up with the opposing interests of the data subject.

Insofar as the processing is based on your consent or our legitimate interests, you may withdraw the consent, at any time, or object to such processing by contacting us directly by e-mail at [email protected]. Please note, however, that the withdrawal of your consent does not affect the lawfulness of the processing prior to your withdrawal.

7. tO WHOM WILL WE PASS ON YOUR PERSONAL DATA

Within the Bank, only those entities that need your data for performing their tasks will have access to it. Furthermore, service providers and vicarious agents of the Bank will receive personal data for the aforementioned processing purposes if they respect the business and banking secrecy and the data transfer is otherwise based on one of the aforementioned legal bases.

We may disclose your personal data to the following possible categories of recipients in accordance with the purposes and legal bases of the processing described above, insofar as this is necessary for the intended data processing or, where applicable, is provided for by law and only those data, whereby we will only disclose such data that is necessary for the performance of individual tasks:

Other group entities;
Service providers that process personal data on our behalf of and at our instructions (these are referred to as “processors”, such as e.g. in the area of IT, hosting, support and printing companies);
Payment transaction and securities services providers, financial institutions;
Customers, sales partners, logistics companies, consultants, insurance companies and other Business Partners;
Telecommunication, marketing and media agencies, visitors to websites and social media of the Bank (e.g. via our social media plugins);
Industry organisations, associations and other bodies;
Purchasers or prospective buyers of business units, undertakings or other parts of the group;
Courts, arbitration bodies, law enforcement authorities, supervisory authorities, lawyers and other parties involved in potential or actual judicial proceedings, where this is necessary for the purpose of complying with the law or of establishing, advising, exercising or defending rights or legal claims

We select our partners and processors very carefully, and work with them only if sufficient guarantees exist that they have implemented appropriate technical and organisational measures in accordance with the legal requirements. Our processors may only process personal data after receiving documented instructions from us. They are all subject to strict confidentiality requirements and may use your personal data only to the extent necessary to fulfil the purpose for which your personal data were collected, unless otherwise required by law.

8. Transfer of Personal Data to Countries Outside the EU/EEA

The personal data we collect will, as a rule, be stored in Switzerland and in the EEA area, where adequate data protection is guaranteed. In addition, we can transfer, store and process your personal data at data locations around the world. Therefore, we may transfer your personal data outside the European Economic Area (EEA) if required for the processing of data described in this Privacy Policy in accordance with applicable law.

Whenever data is transferred to countries that do not ensure an adequate level of data protection, the Bank ensures an adequate level of data protection by providing appropriate safeguards, such as contractual safeguards (e.g. based on EU standard clauses), or the transfer takes place only to the extent that:

It is necessary for the fulfilment and performance of a contract with you;
It is required by law;
It is necessary for the establishment, exercise or enforcement of legal claims; or
You have given your express consent.

For more information about our adequate security precautions, please contact us by e-mail to [email protected].

For reasons of completeness, we hereby point out to users who are residents of or who have their domicile in Switzerland and the EU that the USA has measures in place which allow US authorities to store all personal data by all persons whose data are transferred to the US from Switzerland. This takes place generally without differentiation, limitation or exception with regard to the purpose and without any objective criterion that limits access of US authorities to the data and later its use to specific, strictly limited purposes that may justify the intervention in connection with both access to and use of these data. In addition, please note that Swiss data subjects do not have sufficient legal remedies available that might ensure access to their data and enforcing their rectification or erasure; and there is no effective judicial relief in place against general access rights by US authorities. We explicitly point out these legal circumstances to you to allow you to take appropriately informed decisions about giving your consent to the use of your personal data.

Users with a residence within a member state of the EU, the EEA or Switzerland should further be advised that, from the point of view of the European Union and Switzerland – based on the topics specified in this section, among others –, the USA does not have in place an appropriate level of data protection. Insofar as we stated within this Privacy Policy that there might be recipients of data whose registered office is in the USA (e.g. Google), we will ensure on the basis of contractual regulations with these companies that your data will be protected to an appropriate level by our partners.

9. For How Long Do We Store Information About You

We store your personal data for as long as it is necessary to fulfil the purposes for which your personal data was collected. For this reason, we will erase or anonymise personal data as soon as it is no longer necessary to achieve the purposes for which it was collected, but subject to (i) applicable legal or regulatory requirements to store personal data for a longer period of time (e.g. for tax or commercial reasons), or (ii) if we have an overriding interest (e.g. for evidence reasons to establish, exercise and/or defend actual or potential legal claims, investigations or similar procedures, including legal provisions that we can enforce to preserve relevant information, or if we have an interest in a non-personal analysis). To the extent that the Bank requires data and documents relating to persons as evidence for the assertion, exercise or defence of legal claims, the Bank primarily refrains from an erasure in accordance with the respective limitation periods, which might normally be up to 10 years. In special cases, the documents and data concerned will be kept for a longer period of time as evidence in accordance with current case-law, in consideration of the legitimate interests.

On this basis, we will generally process personal data in compliance with the following rules and obligations:

The personal data you provide to us in connection with the use of our services and products offered on our Website or which you transfer to us via the e-mail contact address will generally be kept by us until you ask us to erase it, have withdrawn your consent to its storage (e.g. newsletter) or the purpose for data storage has ceased to exist (e.g. after your inquiry has been finally processed).
The personal data you provide us with in connection with a user account will generally be kept by us until you erase the data (incl. user account), you ask us to erase it, your consent to store it is withdrawn or the purpose for data storage has ceased to exist (e.g. after your inquiry has been finally processed).
For contract-related personal data (including business records and notices), we will store personal data for as long as the contractual relationship exists, and thereafter for ten additional years after the termination of the contractual relationship, unless (i) a shorter or longer legal retention obligation applies in individual cases, (ii) the retention is required for evidence reasons or for another valid reason under applicable law, or (iii) the erasure of the data is required earlier (e.g. because the data is no longer required or we must erase the corresponding data).
The personal data you submit to us in connection with an open job application will be erased within six months after the completion of the applicant selection procedure if you were unsuccessful in the applicant selection procedure, unless we have your express consent to keep the application data for a longer period of time (e.g. for another vacancy that we could have for you).

10. Cookies and Social Media Plug-Ins

10.1 Cookies, Google Services and Social Media Plug-Ins

When you access or use the Website, we may place cookies – which are small text files – or similar tools on your computer. We use these cookies to identify you as a user of the Website, to customise contents, to improve the performance of the Website and to improve your user experience.

Types of cookies used on this website:

Necessary and functional cookies

These cookies are necessary for the basic functions of the website.

Domain	Cookie Name	Purpose of use	Duration of storage
globalance.com	autoTriggerPopUp	To determine whether the pop-up window has already been executed or not.	1 day
globalance.com	PHPSESSID	Stores information about the visit to the website such as login or logout.	As long as the session is active
globalance.com	wk_consent_plus	Storage of the decision on cookie settings.	Until the cache is cleared

Marketing cookies

These cookies are used to further optimise the user experience.

Domain	Cookie Name	Purpose of use	Duration of storage
globalance.com	_gid	Conversion link from Google Analytics to Google Ads to measure online marketing measures.	1 day
globalance.com	_gat_UA-XXXXXX	Measurement of website traffic for statistics and user analysis via Google Universal Analytics	As long as the session is active
globalance.com	_ga_XXXXXX und _ga	Measurement of website traffic for statistics and user analysis via Google Analytics 4.	1 year
globalance.com	_hjSessionUser_, _hjFirstSeen, _hjIncludedInSessionSample_, _hjSession_ and _hjAbsoluteSessionInProgress	Measurement of website traffic to optimise user flow and marketing measures via Hotjar.	As long as the session is active

You can delete all or part of the cookies in your browser at any time under “Settings”. The deletion of the technical cookies has the consequence that all functions of our website are no longer available to you.

a) Categories of Cookies That We Use

Depending on the function and purpose of use, the cookies we use can be divided into the following categories:

Necessary (also: essential or absolutely necessary) cookies: on the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
Functional cookies: these cookies serve a variety of purposes for the presentation, functionality and performance of a website and in particular to improve the experience and enjoyment of website visitors. They enable a website to store information already provided (e.g. user name, location or language selection) and offer visitors improved, more personal functions. Functional cookies will be used, for example, to remember things like your access data. These cookies will not be able to track your movement on other websites.
Performance cookies: these cookies are used to collect information about how a website is used – for example, how visitors came to our website, what pages a visitor opens most often, how they navigated our website during their visit, and whether they receive error messages from a page. We may also use these cookies to receive certain statistical and analytical information, such as e.g. how many visitors came to our website. These cookies are used to monitor the level of activity of the website and improve the performance of the website.
Personalisation cookies: furthermore, cookies are usually also used in the context of reach measurement and when the interests of a user or their behaviour (e.g. viewing certain content, using functions, etc.) individual websites are saved on in a user profile. Such profiles serve to show users, for example, contents that correspond to their potential interests. This process is also referred to as “tracking”. If we use cookies or “tracking” technologies, we will inform you separately in our Privacy Policy or in the context of obtaining a consent.
Advertising cookies allow us or a third-party provider to place advertisements on our Website or on third-party websites for products that the user likes, so that the advertisements the user sees may be more relevant to the user’s preferences or interests (sometimes also referred to as “targeting cookies”). They may also be used to assess the effectiveness of advertising and sales promotion.
Temporary cookies (also called session cookies): temporary cookies will be erased no later than after a user has left a website and has closed their browser.
Permanent cookies: permanent cookies remain stored even after the browser is closed. This enables, for example, the login status to be stored or preferred content can be displayed directly when the user comes back to a website. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.

These cookies may be placed by us or by a third party on our behalf. For more information on cookies and how they are used, please visit http://www.allaboutcookies.org/.

For more information about the cookies we use, please see our cookie settings in the cookie settings.

b) Google

We use a wide variety of Google services to improve our company’s visibility and in order to optimise our offers. For more information about the Privacy Policy and the Terms of Use of Google, please see here. Google LLC’s parent company is Alphabet Inc., both based in Mountain View, 1600 Amphitheater Parkway, CA 94043, USA. The company Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland, is responsible for all Google services in Europe. Below, we will discuss, in detail, the Google services that we use.

1) Google Analytics

We use the analysis tracking tool Google Analytics (GA) of the American company Google LLC on our Website. Google Analytics collects data about your behaviour on our website. For example, if you click on a link, this action is logged in a cookie and will be sent to Google Analytics. The reports generated from this, which we receive from Google Analytics, help us to continuously improve our Website and our service.[A1]

Google Analytics uses a tracking code to create a random, unique ID associated with your browser cookie. This is how you will be recognised as a new visitor. The next time you visit our website, you will be recognised as a “returning” visitor. All collected data will be stored together with this user ID. Identification such as cookies and app instance IDs measure your interactions on our Website. If you also use other Google systems (such as e.g. a Google account), data generated by Google Analytics can be linked to third-party cookies. Google does not share any Google Analytics data. Exceptions may occur when required by law.

The information generated by the cookie about your use of our Website might be transferred to a Google server in the USA and stored there. We have activated the IP anonymisation feature on our Website. Your IP address will be abbreviated by Google within the European Union or other parties to the Agreement on the European Economic Area prior to their transmission to the United States. Only in exceptional cases will the complete IP address be transmitted to a Google server in the USA and abbreviated there.

The IP addresses transmitted within the scope of Google Analytics will not be merged with any other data of Google.

This information may include the number of visits to the website by a user, the date of the first and last visit, the duration of visits, the page from which the user accessed the website, the search engine with which the user accessed the website, or the link they clicked, the location in the world from which the user accessed the website, etc. Google will use this information on our behalf to analyse your use of the Website, to compile reports on website activities and to provide us with other services relating to the use of the Website and the Internet.

We use Google Analytics on the basis of our legitimate interests to analyse and regularly improve our Website, as well as to regularly improve our services and make them more interesting for you on the basis of the statistics gained. Furthermore, the use of Google Analytics is based on your consent to tracking your surfing behaviour on our webpages and its analytical evaluation.

You may refuse the use of cookies by clicking on “Reject” in our cookie banner; or by making the corresponding settings in your browser. Please note, however, that in this case you might not be able to use all the features of this Website. In addition, you may object to the collection and use of data (cookies and IP address) by Google by downloading and installing the browser plug-in available at this link (https://tools.google.com/dlpage/gaoptout?hl=en).

In addition, Google may monitor the use of the Website by the user and combine this data with data from other Google-monitored websites that the user has visited and use the results for its own benefit (e.g. to control advertising) under its responsibility and on the basis of its own privacy policy that is available here (https://policies.google.com/). For more information about Google Analytics and the processing of personal data, please see here (https://policies.google.com/technologies/partner-sites).

c) Management of Cookies

If you do not wish to accept these cookies, you may change your browser settings so that certain cookies are erased or will not be placed on your computer or device without your consent. Each browser is different in the way it manages cookie settings. This is usually described in the “Help” menu of each browser. This information for the most popular browsers can be found at the following links:

Internet Explorer: support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: support.mozilla.com/en-US/kb/Cookies
GoogleChrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en
Safari: support.apple.com/de-ch/HT201265.

Please note, however, that disabling the cookie function in your browser settings may prevent you from using all the functions of the Website.

d) Social Media Plug-Ins

We use the social media plug-ins below on our Website to make our company better known. The advertising purpose behind this is to be regarded as a legitimate interest within the meaning of point f of Article 6 (1) of the GDPR. The responsibility for a data protection-compliant operation must be guaranteed by their respective providers. Data processing in connection with these plug-ins takes place when you use these plug-ins with your consent.

If you use the services of these social networks independently or in connection with our Website, the social networks will evaluate your use of the plug-in. In this case, information will be passed to social networks through the plug-in.

1) Facebook

Our Website uses plug-ins from the Facebook social network offered by Meta Platforms, Inc., 1601 Willow Road Menlo Park, CA 94025, USA. The Facebook plug-ins are marked with a Facebook logo or the addition “Like” or “Share”. An overview of the Facebook plug-ins and their appearance is available at: https://developers.facebook.com/docs/plugins.

If you access a page of our Website that contains such a plug-in, your browser will establish a direct connection to the Facebook servers. The content of the plug-in will be transmitted by Facebook directly to your browser and embedded into the page.

Through this embedding, Facebook receives the information that your browser has accessed the corresponding page of our Website even if you do not have a Facebook account or are not currently logged in to Facebook. This information (including your IP address) will be transferred directly by the browser to a Facebook server in the US and stored there.

If you are logged into Facebook, Facebook can immediately associate your visit to our Website with your Facebook profile. If you interact with the plug-ins, e.g. by pressing the “Like” button, this information will also be transmitted directly to a Facebook server and stored there. The information will also be published on your Facebook profile and displayed to your Facebook friends.

For further information on the purpose and the extent of the collection and processing of data by Facebook and on your associated rights and settings options for the protection of your privacy, please refer to the privacy policy of Facebook at: www.facebook.com/policy.php.

2) LinkedIn

Our Website contains plug-ins from the social network LinkedIn Corporation, 1000 West Maude Avenue Sunnyvale, California 94085, USA. The LinkedIn plug-in (“LinkedIn Recommended” button) can be recognised by the LinkedIn logo. If you access a page on our Website that contains such a plug-in, a direct connection will be established between your browser and the LinkedIn server. LinkedIn receives the information that you have visited our Website with your IP address. If you click the LinkedIn button while you are logged into your LinkedIn account, you can link the contents of our pages to your LinkedIn profile. If you do so, LinkedIn can assign your visit to our Website to your user account. Please note that we, the Website provider, do not have any knowledge of the content of the data transferred or its use by LinkedIn. For more information, please visit: www.linkedin.com/legal/privacy-policy.

3) YouTube

We have embedded YouTube videos on our Website. To allows us to always be able to present you with current videos directly on our site. YouTube is a video portal that has been a subsidiary of Google LLC since 2006. The portal is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a page on our Website in which a YouTube video is embedded, your browser automatically connects to the servers of YouTube or Google. This involves the transmission of different data (depending on the settings). Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all data processing in Europe.

YouTube sets at least one cookie that stores your IP address and our URL. If you are logged into your YouTube account, YouTube can usually also assign your interactions on our Website to your profile with the help of cookies. This includes data such as session duration, bounce rate, approximate location, technical information such as browser type, screen resolution or your Internet service provider. Additional information may include contact details, any rating, sharing content via social media, or adding to your favourites on YouTube.

For more information on how Google uses and processes your data, please visit: https://policies.google.com/privacy?hl=en.

4) Instagram

Our Website uses the plug-in of the social network Instagram offered by Meta Platforms, Inc., 1601 Willow Road Menlo Park, CA 94025, USA.

Data will not be sent to the social media provider until the user activates the social media plug-ins by clicking on the selected plug-in. The user may thus choose when to activate them. In this case, Facebook may establish a direct connection with the user during your visit to the Website, which allows Facebook to gain knowledge of the user’s visit and to analyse the relevant information. The personal data will be further processed under the responsibility of Facebook in accordance with the data protection laws and the data protection guidelines published on its website (https://help.instagram.com/ 519522125107875/?helpref=hc_fnav&bc[0]=Instagram-Hilfebereich&bc[1]=Richtlinien%20und%20 Meldungen[A3] ). Please read the privacy policies of your social networks carefully to obtain detailed information about the collection and transfer of personal data, your rights, and how to achieve privacy settings that are satisfactory to you.

5) Twitter

Our Website integrates plug-ins from the short-message network Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA. You can recognise the Twitter plug-ins (“Twitter” button) by the Twitter logo and the text “Tweet”. If you access a page on our Website that contains such a plug-in, a direct link will be established between your browser and the Twitter server. Twitter will then receive the information that you have visited our Website with your IP address. If you click the Twitter button while you are logged into your Twitter account, you can link the contents of our pages to your Twitter profile. If you do so, Twitter will be able to assign your visit to our Website to your user account.

Please note that as the provider of the websites, we have no knowledge of the contents of the transferred data or its use by Twitter. For more information, please visit: http://twitter.com/privacy.

6) Vimeo

We use Vimeo videos on our Website. Vimeo is a video portal operated by Vimeo LLC, 555 West 18th street, New York, New York 10011, USA. When you visit a page on our Website in which a Vimeo video is embedded, your browser will automatically establish a connection to the servers of Vimeo in the USA. Depending on the settings, different data will be transmitted, such as your IP address or which of our pages you visited. This also applies if you are not logged into Vimeo or do not have an account with Vimeo. The information collected by Vimeo is transmitted to the Vimeo server in the USA.

If you are logged into your Vimeo account, Vimeo may also assign your interactions on our website to your profile using cookies [A5] . This includes data such as session duration, bounce rate, approximate location, technical information such as browser type, screen resolution or your Internet service provider. Additional information may include contact details, any rating, sharing content via social media, or adding to your favourites on Vimeo. You can prevent this by logging out of your Vimeo account. For more information on how to handle user data, see the Vimeo privacy policy at: https://vimeo.com/privacy.

e) Tracking with fusedeck
The fusedeck tracking solution from Capture Media AG (hereinafter “Capture Media”) is integrated on this website. Capture Media is a Swiss company based in Zurich that measures the use of this website in the context of engagements and events. Tracking is anonymous, so that no reference can be made to specific or identifiable persons.

Further information on data protection and the rights of data subjects in connection with fusedeck, including the option to opt out, can be found in the privacy policy and objection policy.

11. No Automated Decision-Making, Including Profiling, with Legal Effect

We will not make any decision about you that is based solely on automated processing – including profiling – and that has legal effect against you or affects you in a similarly significantly manner.

12. Security

We have taken various technical and organisational measures to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where the processing involves the transfer of data through a network, as well as from all other unlawful forms of processing and misuse.

We use the https solution for our Website to transfer data securely on the Internet. We ensure the protection of confidential data by using TLS (transport layer security), an encryption protocol for secure data transfer. A small padlock symbol at the top left of your browser and “https” (instead of http) at the beginning our Internet address indicate the use of this secure transfer system.

The Bank may use third parties as processors to collect and process your personal data. The data processors we engage will process your personal data only according to our instructions and are legally obliged to take strict security precautions when dealing with personal data.

Unfortunately, the transmission of information via the Internet is not entirely secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. For this reason, you are always free to provide your personal data to us by other means, e.g. by telephone. Once we have received your information, we will apply strict procedures and security measures to prevent any unauthorised access.

13. Privacy Policies of third parties

Please note that when you click on a link to a website of a third-party provider (e.g. Google or other websites), you will be redirected to a website that we do not control and our Privacy Policy will no longer apply. Your browsing and interactions on another website are subject to the terms of use and the privacy policies and notices of these third-party websites. In addition, we cannot guarantee the correctness and up-to-dateness of these links.

We recommend that you read the terms of use and the privacy policies and notices of other websites carefully before you transfer any personal data through this Website. We are not responsible or liable for the information content on such third-party websites.

14. Rights of the data subject

You may request access to information from the Bank about whether personal data about you is being processed. In addition, you have the right to request the rectification, erasure or restriction of personal data about yourself and to object to the processing of personal data. Insofar as the processing is based on your consent or our legitimate interests, you may withdraw the consent at any time or object to such processing by contacting us directly by e-mail at [email protected]. In the event of an objection, the personal data concerned will generally no longer be processed by the Bank. In exceptional cases, the data will nevertheless continue to be processed if compelling legitimate grounds are demonstrated which override the interests, rights and freedoms of the data subject, or if the processing serves to assert, exercise or defend legal claims. In certain cases, you have the right to receive personal data arising from the use of online services in a structured, commonly used and machine-readable format that allows for a further use and transfer.

Requests in this respect should be sent to the Bank by e-mail to the following address: [email protected]. The Bank reserves the right to restrict your rights under applicable law, e.g. not to disclose comprehensive information or to erase data.

If we refuse your request or if you are not satisfied with our processing, you are also entitled to lodge a complaint with the competent supervisory authority and to exercise the right to a judicial remedy. For users based in Switzerland, the competent public authority is the Eidgenössischer Datenschutz- und Informationsbeauftragter [Federal Data Protection and Information Commissioner in Switzerland] (http://www.edoeb.admin.ch). For users resident in EU countries, a list of supervisory authorities is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

15. Changes to Our Privacy Policy

This Privacy Policy is subject to change from time to time and without notice. All changes to this Privacy Policy will be effective when published on the Website, unless otherwise noted. If we make any material changes to the Privacy Policy, we will notify you by e-mail and/or via a prominent notice on our Website or in any other appropriate manner prior to the effective date of the change and update the “Effective Date” at the top of this page. Insofar as the Privacy Policy is part of an agreement with you, we will notify you of any changes in the course of an update by e-mail or by any other appropriate means.