The purpose of this privacy policy is to inform you about which personal data we process in connection with our activities and operations, including our finanzplatz-zuerich.ch website. In particular, it is to inform you about for what purpose, how and where we process which personal data. Furthermore, we provide information about the rights of data subjects whose data we process.
Additional data protection regulations as well as other legal documents, such as general terms & conditions, terms of use or conditions of participation may apply for individual or additional activities and operations.
We are subject to Swiss data protection law as well as, as the case may be, to applicable foreign data protection law, such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection legislation provides an adequate level of data protection.
1. Contact addresses
Responsibility for processing personal data:
Zurich Banking Association
Weinbergstrasse 25
8001 Zurich
In individual cases, there may be other controllers for processing personal data, or joint controllership with at least one other controller.
2. Terms and legal bases
2.1 Terms
Controller is a business, organisation, natural person, or Federal authority that determines (alone or jointly with others) the purpose and means of the processing of personal data Data subject is a natural person whose personal data is processed
Processing includes any handling of personal data, irrespective of the means and procedures used, e.g. retrieving, matching, adjusting, archiving, keeping, selecting, announcing, obtaining, entering, collecting, deleting, disclosing, arranging, organising, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the member countries of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) understands processing of personal data to mean any operation performed on personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law, in particular, in accordance with the Federal Act on Data Protection (Data Protection Act, FADP), and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process –if and insofar as the General Data Protection Regulation (GDPR) is applicable– personal data pursuant to at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract to which the data subject is party, or in order to take measures prior to entering into a contract.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental freedoms and rights or interests of the data subject. Legitimate interests are, in particular, to be able to perform and communicate about our interests, our activities and operations consistently and in a user-friendly, safe and reliable manner, ensuring information security, protection against abuse, the enforcement of own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data for compliance with a legal obligation to which we are possibly subject to pursuant to applicable law of member countries within the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data to carry out a task that is in the public interest.
- Art. 6 para. 1 lit. a GDPR for the processing of personal data with consent given by the data subject.
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or of another natural person.
3. Type, scope and purpose
We process personal data needed in order to perform our activities and operations consistently and in a user-friendly, safe and reliable manner. Such personal data may, in particular, fall into the categories of inventory and contact data, browser and device data, content data, metadata, marginal data and usage data, location data, sales data and contract and payment data.
We process personal data for as long as required for the respective purpose or purposes or as required by law. Personal data which no longer needs processing shall be anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we make use of. We also guarantee data protection at such third parties.
In principle, we process personal data only with consent of the data subjects. If and insofar as processing is permitted for other legal reasons, we may waive the requirement to obtain consent. Processing without consent may, for instance, be permissible for the performance of a contract, in order to comply with legal obligations or to protect overriding interests.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of conducting our activities and operations, if and insofar such processing is permissible for legal reasons.
4. Communication
We process personal data in order to communicate with third parties. In this context, we process, in particular, data that a data subject transmits when making contact, e.g., by letter or e-mail. We can store such data in an address book or using comparable tools.
Third parties who transmit data about other persons are obliged to guarantee data protection vis-à-vis these data subjects. The accuracy of the transmitted data must, inter alia, be ensured.
5. Data security
We take appropriate technical and organisational measures to provide for data security appropriate to the respective risk. With our measures we ensure, in particular, the confidentiality, availability, transparency and integrity of the processed personal data, however, without guaranteeing absolute data security.
Access to our website and our other online presence is secured through transport encryption (SSL / TLS, in particular, with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption by showing a small padlock in the address bar.
Our digital communication –like all digital communications– are subject to mass surveillance without cause or suspicion through security agencies in Switzerland, in the rest of Europe, in the United States of America (USA) and in other countries. We cannot exert any direct influence on the corresponding processing of personal data by secret services, police forces or other security agencies. Furthermore, we cannot rule out the possibility that individual data subjects may be under specific surveillance.
6. Personal data abroad
On principle, we process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, in particular, in order to process personal data there or to have personal data processed there.
We may export personal data to all countries and territories on earth and elsewhere in the universe, provided that pursuant to a decision of the Swiss Federal Council the law in such places guarantees adequate data protection and –if and insofar as the General Data Protection Regulation (GDPR) is applicable– adequate data protection is guaranteed pursuant to a decision of the European Commission.
We may transmit personal data to countries whose laws do not guarantee adequate data protection if data protection is guaranteed for other reasons, in particular, on the basis of standard data protection clauses or with other appropriate guarantees. In exceptional cases, we may export personal data to countries without adequate or suitable data protection if the special data protection requirements are met for doing so, e.g. the express consent of the data subjects or a direct connection with entering or performing a contract. On request, we will gladly provide data subjects with information about any guarantees, or provide a copy of any guarantees.
7. Rights of data subjects
7.1 Data protection rights
We grant data subjects all rights pursuant to applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what personal data this concerns. Furthermore, data subjects shall receive information that is needed in order to make their data protection claims and to guarantee transparency. This includes the processed personal data per se, as well as, inter alia, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and on the origin of the personal data.
- Rectification and restriction: Data subjects may rectify incorrect personal data, complete incomplete data and have the processing of their data restricted.
- Erasure and objection: Data subjects may have their personal data erased (“Right to forgetting”) and may object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request that their personal data be disclosed or transferred to another controller.
We may defer, restrict or deny the exercising of rights of data subjects within a legally permissible framework. We may draw the data subjects’ attention to any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in full or in part with reference to trade secrets or to the protection of other persons. We may, for example, also refuse in full or in part to erase personal data with reference to legal retention obligations.
In exceptional cases, we may stipulate costs for the exercising of rights. We shall inform data subjects in advance of any costs.
We are obliged to take appropriate measures to identify data subjects who request information or who assert other rights. Data subjects are under the obligation to cooperate.
7.2 Legal protection
Data subjects have the right to enforce their data protection claims by taking legal action, or through reporting or lodging a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for data subjects to report to against private controllers and federal authorities in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities for complaints of data subjects –if and insofar as the General Data Protection Regulation (GDPR) is applicable– are organised as members within the European Data Protection Board (EDPB). In some member countries of the European Economic Area (EEA), the data protection authorities are structured federally, in particular in Germany.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies –own cookies (first-party cookies) as well as cookies of third parties whose services we use (third-party cookies)– are data stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies may be stored temporarily in the browser as “session cookies” or for a certain period of time as “permanent cookies”. “Session cookies” are automatically deleted when the browser is closed. “Permanent cookies” have a specific storage period. Cookies allow for, in particular, a browser to be recognised on a next visit to our website and, thus, make it possible to measure the reach of our website, for example. However, “permanent cookies” may, for example, also be used for online marketing.
Cookies may be fully or partly deactivated or deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. We actively request express consent to the use of cookies – at least if and insofar as necessary.
For cookies that are used to measure success and reach or for advertising, a general objection (“opt-out”) is possible for several services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
8.2 Logging
We may log at least the following information for every access to our website and our other online presence, insofar as this information is transmitted to our digital infrastructure during such accesses: date and time including time zone, IP address, access status (http status code), operating system including user interface and version, browser including language and version, individual subpage accessed on our website including amount of data transferred, last website accessed in the same browser window (referrer).
We log such information that may also constitute personal data in log files. This information is necessary in order to make our online presence available in a consistent, user-friendly and reliable manner. The said information is required, furthermore, in order to ensure data security – also by third parties or with the support of third parties.
8.3 Tracking pixels
We may integrate tracking pixels in our online presence. Tracking pixels are also referred to as web beacons. Tracking pixels –also those of third parties whose services we use– are typically small, invisible images or scripts written in JavaScript that are automatically retrieved when accessing our online presence. Tracking pixels can be used to collect at least the same information as log files.
9. Third-party services
We use the services of specialised third parties, in order to carry out our activities and operations in a consistent, user-friendly, secure and reliable manner. By using such services, we can, inter alia, embed functions and content in our website. In the case of such embedding, the services used record the IP addresses of the users at least temporarily for technically compelling reasons.
Third parties whose services we use may for necessary security, statistical and technical purposes process data in connection with our activities and operations in aggregated, anonymised and pseudonymised form. This concerns, for example, performance or usage data to be able to offer the respective service.
Digital infrastructure
We utilise the services of specialised third parties in order to be able to use necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services of selected providers.
We use in particular:
- METANET: Hosting; Provider: METANET AG (Switzerland); Data protection information: Privacy policy, “Technical and organizational measures”.
10. Website enhancements
We use enhancements for our website in order to be able to utilise additional functions. We may use selected services of suitable providers, or use such enhancements on our own server infrastructure.
We use in particular:
- Imagify: Image optimisation: Provider: WP MEDIA (France); Data protection information: “Terms of Service”, “Frequently Asked Questions”.
11. Measuring success and reach
We endeavor to determine how our online offering is used. In this context, we may, for example, measure the success and reach of our activities and operations, as well as the effect of third-party links to our website. But we may also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can, in particular, correct errors, bolster popular content or make improvements to our online offering.
In most cases, the IP addresses of individual users are stored in order to measure success and reach. In such cases, IP addresses are generally shortened (“IP masking”) so as to comply with the principle of data minimisation by way of the corresponding pseudonymisation.
Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information about the size of screen or browser window and the –at least approximate– location. On principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services which users are registered with may be able to track the use of our online offering to the user account or user profile of the respective service.
12. Final provisions
We may amend or supplement this privacy policy at any time. We will inform about any such amendments and supplements in an appropriate form, in particular, by publishing the respective current privacy policy on our website.