Privacy statement

The following privacy statement is geared to the requirements of the Swiss Federal Act on Data Protection (FADP), the European Union's General Data Protection Regulation (GDPR) and the United Kingdom's General Data Protection Regulation (UK GDPR). Whether and to what extent these laws are applicable depends on the specific individual case. In terms of compulsory occupational benefit schemes, the special data protection provisions of the Federal Law on the Occupational Old-Age, Survivors' and Disability Benefit Plans (LOB) apply.

All persons involved in providing as well as monitoring or supervising the provision of occupational benefits are subject to the duty of confidentiality in accordance with Art. 86 LOB in respect of third parties.

Swisscanto VBF may process personal data in accordance with applicable data protection law.

Data processing entails all handling of personal data regardless of the tools and procedures used, particularly the procurement, saving, storage, use, modification (including pseudonymization and anonymization), disclosure, archiving, deletion/erasure or destruction of data. The processing must not unlawfully infringe the personality rights of data subjects, and any processing may be based on the following principles under data protection law:

• Existence of a contract with Swisscanto VBF
• Legitimate interests of Swisscanto VBF
• Law
• Consent
  

Swisscanto VBF processes personal data for the purpose of operating obligatory and supplementary occupational benefit schemes and in order to maintain benefit coverage in line with the tasks entrusted to it.

The personal data processed by Swisscanto VBF includes data that has been provided by data subjects, collected from them, or is publicly accessible. Data categories include:

• Communication data
• Contract details
• Master data
• Beneficiary data (e.g. first name, last name, address, place of residence, Old Age and Survivors' Insurance (OASI) number, payroll amount, start and leave dates, working hours, interruption of employment and cause, purchase (voluntary payment) calculations, advance withdrawals, e.g. to finance residential property or in connection with a divorce, information about capacity to work)
• Banking, financial and asset-related data
• Claims data
• Health data
• Registration data
• Technical data
• Data regarding behaviour and preferences
• Security, warranty and compliance data
• Other data (e.g. powers of attorney, official certifications, etc.)
  

The policyholder or beneficiary is obliged to provide the data required to assess the risk, manage the contract and handle claims. If this obligation is not met, Swisscanto VBF may refuse to conclude the contract or parts thereof or to pay all or part of the claim.

Swisscanto VBF or parties it engages may, to the extent required, obtain relevant personal data from third parties to ensure optimum handling of business processes, the conclusion of contracts or contract management, and to provide services. On the basis of the insurance application forwarded or the claim (for benefits) notified, these third parties are released from their duty of confidentiality toward Swisscanto VBF and the parties it engages.

Concluding the contract or providing services may require Swisscanto VBF not only to obtain relevant information from third parties, but also to disclose personal data to third parties involved in the contract (such as reinsurers, commissioned parties, service providers, authorities, etc.). For this reason, Swisscanto VBF is not subject to any duty of confidentiality in this regard under the FADP. In addition, Swisscanto VBF obliges third parties to handle the data appropriately, in accordance with its sensitivity and with other circumstances. The data may be passed on to recipients in Switzerland and abroad if the circumstances of the data processing so require. For further details, please refer to the "List of recipients and countries".

Profiling refers to any kind of automated processing of personal data comprising the analysis of specific personal aspects, such as economic situation, health, interests, reliability, behaviour, or relocation. Swisscanto VBF may use profiling to analyse certain personal characteristics (interests and preferences) of data subjects, so that it can send them personalized advertising or offers, but also in order to identify fraud and security risks. The use of data analysis processes also enables Swisscanto VBF to compile statistical information. If an individual decision is made in a fully automated manner and that decision has negative legal consequences for the data subject or results in a considerable impairment for them, Swisscanto VBF will inform them accordingly and the data subject may contact Swisscanto VBF to have the corresponding decision reviewed by a human being. However, any fully automated decisions are always based on Swisscanto VBF's pre-determined rules for the weighting the information.

Swisscanto VBF takes adequate technical and organizational measures when processing personal data to prevent unauthorized access and other unauthorized processing. These measures are based on the international standards in this area and are checked regularly and adjusted if necessary.

Swisscanto VBF processes personal data for as long as is necessary to fulfil the processing purposes, to comply with the statutory retention periods, to meet legitimate interests, such as for the purposes of documentation or evidence, or for as long as claims may be brought against Swisscanto VBF or storage is required for technical reasons, as is the case, for example, with backup copies.

Further information on respective storage periods can be found in the sections under " Data processing in connection with websites and online services". If there are no legal or contractual obligations to the contrary, we will delete or anonymize your data after the storage period has expired as part of our usual procedures.

The right to request information from Swisscanto VBF on whether and, if so, what personal data it is processing and to receive a copy of that data.

The right to have inaccurate data rectified.

The right to request the erasure of personal data, to the extent that Swisscanto VBF is no longer obliged or entitled under applicable laws or regulations to retain it.

The right to object at any time to the future processing of personal data, insofar as that processing is not absolutely essential for contract performance and/or Swisscanto VBF is not obliged or entitled to process it under applicable laws or regulations.

The right to object to the processing of personal data, in particular insofar as processing is based on legitimate in-terests or where data is processed for the purposes of direct marketing, and the right to revoke consent insofar as data processing is based on consent.

The right to request that Swisscanto VBF transfer certain personal data.

The right of the data subject to express their point of view in the case of exclusively automated decisions and to re-quest that decisions be reviewed by a human being.

Data subjects have the right to lodge a complaint with the competent data protection authority.

Contact details of regulatory authority

• The Swiss regulatory authority may be contacted here.
• The contact details for the data protection office of Liechtenstein are available here.
  
• You will find a list of the the relevant authorities within the EEA here.
  
• You can reach the UK's regulatory authority here.
  

Swisscanto VBF would like to remind data subjects that the Internet is an open, global network that is accessible to everyone. Communication via e-mail is not usually encrypted and takes place only during regular office hours. It is possible that data may be lost or intercepted and/or manipulated by third parties, for example, to make it appear authentic. Swisscanto VBF takes appropriate technical and organizational security measures to prevent this from happening within the Swisscanto VBF system. Nevertheless, the confidentiality of data transmitted by e-mail cannot be guaranteed. This applies, in particular, to the transmission of sensitive personal data (such as health data). E-mails may be delayed, deleted, misrouted or shortened during transmission due to transmission errors, technical defects or other malfunctions. External access devices (Internet users' PCs, smartphones, etc.) and parts of the infrastructure used for transmission between the sender and Swisscanto VBF are located outside the secure area over which Swisscanto VBF has control. It is the responsibility of each Internet user to find out about the necessary security precautions and to take appropriate measures (e.g. up-to-date anti-virus software, etc.). Swisscanto VBF is not liable for any damage or consequences arising from the electronic exchange of information, particularly from the misuse of the e-mail system, for which Swisscanto VBF itself is not responsible. Swisscanto VBF reserves the right to seek indemnification from the data subject for any intentional damage it suffers as a result of its business dealings with the data subject via the electronic exchange of information. Swisscanto VBF reserves the right not to respond via e-mail in individual cases or to request that orders placed or information sent by e-mail be confirmed in another form (e.g. using a signed form).

The providers of Swisscanto VBF websites collect and store data in the form of log files when those websites are accessed. This includes the following data:

• IP address of the website user
• User name (user ID) when using the customer portal
  
• Date and time of access to the Swisscanto VBF website
  
• Designation of the websites accessed
  
• Definition of the files accessed (downloads)
  
• Notification of successful access
  
• Previously visited sites
  

This data is not stored together with other personal data of the user. Furthermore, this data is collected only for statistical purposes relating to website use, security and optimization of the offering and the website, and is not passed on to third-parties for any other purpose.

This data is deleted as soon as it is no longer needed to fulfil the purpose for which it was collected, or if there is no legal basis for its storage.

As this access data is absolutely necessary for providing the website, it is not possible to object to this form of data processing.

Swisscanto VBF uses the technological services of third parties when organizing webinars, brown-bag sessions and other online events. When participating in online events, the names and e-mail addresses of the participants, as provided during registration, enrolment or upon joining, are usually communicated to third-party providers for the purposes of technical implementation of the event. As a rule, the data is hosted in Switzerland. It cannot be ruled out that this data will be stored outside Switzerland, is subject to other legal systems and/or will be passed on to other third parties by the third-party providers. The respective privacy policy of the service provider(s) applies. Swisscanto VBF itself does not pass on any other customer data in connection with the organization of events and the deployment of third-party providers. As a rule, Swisscanto VBF collects participants' details during the registration process for events. This may involve information about persons other than those completing the registration. On completion of the registration process, Swisscanto VBF obliges the person carrying out registration to inform all those registered by name about Swisscanto VBF's privacy statement. Swisscanto VBF assumes, once registration has been completed, that the persons registered by name have been adequately informed about data processing at Swisscanto VBF. All data entered is used solely in connection with the organization and staging of the event and is deleted within a reasonable and/or the statutory period. Data may be passed on to third parties if, for example, lists of names have to be disclosed for the organization of events. For further details, please refer to the "List of recipients and countries". As a rule, the disclosure is evident from the circumstances of the registration (e.g. registration for travel, a stay in a hotel or a restaurant booking); otherwise, Swisscanto VBF reserves the right to provide separate information in the login mask. The retention period for the data is based on the purpose and is limited to what is absolutely necessary. Data is deleted within the corresponding time period.