Privacy policy for Swiss Life Wealth Management Ltd investment products

In connection with investment products, we process the following categories of personal data in particular for the purposes set out in section 4:

• Master data (e.g. first and last names, street, number, place of residence, country of domicile, gender, date of birth, age, marital status, tax domicile, languages, nationalities, country of birth, e-mail address, telephone number, type of employment, residence permit and other data relating directly to you);
• Payment data (e.g. payment method data, date and amount of incoming payments);
• Contract data (e.g. data from offers and applications including any supplementary questionnaires on the investment and risk profile for determining the investment strategy and investment preference, information on the conclusion, fulfilment, enforcement and termination of contracts and other information in connection with contracts);
• Data for the fulfilment of our legal obligations and associated clarifications and reporting, such as AEOI/FATCA and AMLA (in particular US citizens/dual citizens, clarification of economic background, beneficial owners, politically exposed persons, comparison with sanction lists);
• Behavioural and preference data (information about specific actions, e.g. payments, the use of electronic communications, interaction with social media profiles, contacts with distribution partners etc.; information about your needs and interests which we obtain from both the analysis of existing data and data from third parties);
• Communication data (e.g. type, time and place of communication and its content).

We usually receive this data from you, but also potentially from third-party sources such as your family members, custodian bank, address service providers (master data), credit reporting agencies and other information service providers (e.g. master and financial data), representatives of you and other persons associated with you (e.g. contract data), offices (e.g. information we use for preferential data) and other sources (e.g. the media or Internet).

If you act on behalf of third parties or provide us with data of third parties, we assume that you have informed these third parties about our processing of their personal data. If these persons object to our data processing, this may have an impact on the contract concluded with you.

Swiss Life processes your personal data (section 3) in connection with investment products in particular for the following purposes:

• Fulfilment of statutory and other legal requirements (e.g. from self-regulation, industry standards, official instructions and internal stipulations, e.g. on the prevention of money laundering and the financing of terrorism, clarification of legal and reputational risks, reporting, fulfilment of duties of disclosure, information provision and reporting, archiving, handling complaints and other notifications, monitoring of communication, internal or external investigations, disclosure of documents to authorities, support in the prevention, detection and investigation of criminal offences and other breaches). We process in particular master data, contract and payment data, communication data and, in some cases, behavioural data for these purposes;
• Initiation, conclusion, management and execution of contracts for investment products (in particular acquisition, advice and support as well as pension and financial analysis, financial, pension, inheritance and estate planning or for the pension and insurance check, processing and review of applications including appropriateness assessment of investment, processing and management of offers and contracts including forwarding of data to our cooperation partners and the custodian bank). For this purpose we process, in particular, master data, contract data, financial data, communication data and data of the custodian bank’s contact persons.
• Prevention, risk management, legal protection (e.g. risk assessments, prevention of misuse, internal and external investigations, legal proceedings, corporate management and development). For this purpose we process, in particular, master data, contract data and financial data, as well as behavioural and communication data.
• Market research and product development (e.g. analysing the use of our offers, evaluating and improving existing offers and developing new offers). For this purpose we process, in particular, your master, behavioural and preference data, but also communication data and information from customer surveys, other surveys and studies and other information, e.g. from media monitoring services, from the media, from social media, from the Internet and from other public sources.
• Marketing (e.g. transmission of information and advertising from us and third parties, e.g. as a newsletter or printed matter, targeted addressing of existing customers, holding customer events and competitions, personalisation of information and advertising). For this purpose, we link data that we process about you and determine preference data. You may object to processing for marketing purposes at any time by notifying us. Further information on your rights can be found in section 7.
• Additional purposes: e.g. security purposes, monitoring buildings and publicly accessible premises, internal administration, training and education, bookkeeping, data archiving, managing IT, safeguarding our rights, evaluating and improving internal processes, statistics and research, safeguarding other legitimate interests.
• Customer service: As part of our customer service, one of our service units may contact you. Swiss Life processes your personal data within the scope of our service units to make appointments for advisory meetings and manage existing customer relationships.

“Processing” means any handling of personal data, e.g. its collection, storage, use, disclosure and deletion, as well as automated evaluation and the determination of preferential data, for risk assessment purposes or to conduct statistical evaluations. This also includes profiling, i.e. automated processing for analysis and forecasting purposes (e.g. to combat money laundering and terrorism financing, to combat abuse, for customer care and for marketing purposes).

We may disclose data pursuant to section 3 in particular to the following categories of recipient to the extent required for the purposes pursuant to section 4:

• The custodian bank;

• Counterparties and banks in transactions;

• Our Group companies (for details see www.swisslife.com/en/home/about-us.html);

• Real estate brokers, address providers and brokers;

• Authorities, courts and offices;

• Other third parties, e.g. banks or cooperation partners;

• Internal and external service providers (e.g. IT service providers, address and shipping service providers, marketing, distribution, communication or printing service providers, service providers in building management, credit reporting agencies, debt collection service providers, consulting firms, auditors, etc.).

These recipients may be located abroad (e.g. when transmitting personal data to banks and other bodies in connection with assets located abroad, when purchasing IT services, in legal proceedings abroad, etc.). Your data may therefore be processed anywhere in the world, including outside the EU or the European Economic Area (e.g. in the US). Not all of these countries have a level of data protection equivalent to Swiss law. We therefore take contractual precautions and generally make use of standard contractual clauses (further information can be found at https://www.edoeb.admin.ch/edoeb/en/home/datenschutz/arbeit_wirtschaft/datenuebermittlung_ausland.html), unless an exception applies (e.g. in legal proceedings abroad, in cases of overriding public interest if the processing of a contract requires such disclosure, if you have given your consent).

We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically necessary. The storage duration is based on legal and internal regulations and the processing purposes (section 4). If these purposes have been achieved or no longer apply and there is no longer any obligation to retain your data, we will delete or anonymise the latter as part of our usual procedures.

You have certain rights as defined by the relevant legal conditions and framework:

• to request information from us as to whether and which data we process about you;
• to request us to correct data if it is inaccurate;
• to object to our processing and to request the deletion of data if we are not obliged or entitled to further processing;
• to ask us to hand over certain personal data in a conventional electronic format or transfer the data to another controller;
• to revoke your consent if our processing is based on your consent.
• If we notify you of an automated decision in a specific instance, you have the right to state your position and to request that the decision be reviewed by a natural person.

If you wish to exercise any rights against us, please contact us in writing (section 2). In order to rule out misuse, we need to identify you.

If you do not agree with our handling of your rights or data protection, please let us know as specified under section 2. You can contact the Swiss supervisory authority at https://www.edoeb.admin.ch/edoeb/en/home/adresse.html.

Swiss Life acts exclusively for customers whose head office or domicile is in Switzerland. No marketing or sales activities take place abroad.
Should you be interested in our products as a person domiciled outside Switzerland, we recommend that you contact a representative of the Swiss Life Group near you or one of our Group companies via their website (https://www.swisslife.com).

Swiss Life reserves the right to modify this data protection declaration without prior notice to take account of current statutory provisions and changed business procedures. We will actively inform persons whose contact details are registered with us about major changes as and when they occur, provided this is possible without disproportionate effort. As a general rule, the data protection declaration in its current version at the start of processing applies for data processing. This data protection declaration does not form part of the contract.

Last update: April 2024