Privacy Policy Vested Benefits Foundation Swiss Life

The purpose of the Vested Benefits Foundation Swiss Life (General-Guisan-Quai 40, 8002 Zurich) is to  maintain occupational benefits coverage in accordance with the Federal Law on Vested Benefits for  Retirement, Survivors’ and Disability Pension Plans (FZG). The Vested Benefits Foundation Swiss Life have entrusted Swiss Life Ltd (General-Guisan-Quai 40, 8002 Zurich; together with the foundations “Swiss Life” or “we”) with the  management of their policyholders. Personal data is processed as part of the implementation of employee benefits relationships.

This privacy policy provides you with an overview of the processing of personal data by Swiss Life.

The Swiss Life 3a Employee Benefits Foundation and the Vested Benefits Foundation Swiss Life have  commissioned Lienhardt & Partner Privatbank Zürich AG with the management, account and custody  account management. Lienhardt & Partner Privatbank Zürich AG therefore also processes personal data. For  information on data processing carried out by Lienhardt & Partner Privatbank Zürich AG, please consult its  privacy policy. You can find it here.

2.1 Data processing in connection with the Vested Benefits Foundation Swiss Life

If you are a policyholder of the Vested Benefits Foundation Swiss Life, the Vested Benefits Foundation Swiss Life or Swiss Life Wealth Management Ltd is responsible for the data processing described in this privacy policy.

2.2 Data processing in connection with the Swiss Life 3a Employee Benefits Foundation

If you are a policyholder of the Swiss Life 3a Employee Benefits Foundation, the Swiss Life 3a Employee  Benefits Foundation or Swiss Life Wealth Management Ltd is responsible for the data processing described in this privacy policy.

2.3  Contact details of the data controllers

If you have any questions or concerns regarding data privacy law in connection with the processing of your personal data by the Swiss Life 3a Employee Benefits Foundation or the Vested Benefits Foundation Swiss Life and/or Swiss Life Wealth Management Ltd, please contact the following office:

Swiss Life Management Ltd                                                                                                                                                Data Protection Officer                                                                                                                                                    General-Guisan-Quai 40                                                                                                                                                P.O. Box                                                                                                                                                                                8022 Zurich 

E-mail: dataprotection@swisslife-wealth.ch

We may process the following categories of personal data for the purposes set out in cl. 4:

• Master data (e.g. first and last names, street, number, place of residence, country of domicile, gender, date of birth, age, marital status, date of marriage or registration of partnership, languages, nationalities, tax residence, country of birth, social security no. (OASI), e-mail address, telephone  number, type of employment;
• Financial data: e.g. income data, account data, selected investment strategies, asset situation;
• Payment data e.g. payment method data such as IBAN, date and amount of incoming payments);
• Contract data, e.g. data from offers, applications and contracts, including the associated documents such as investment and risk profile;
• Data to fulfil our legal obligations and associated clarifications and reporting;
• Behavioural and preference data e.g. information about specific actions, such as 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 analysis of existing data but also data from third parties;
• Communication data: e.g. type, time and place of communication and its content;
• Data in connection with online communication with Swiss Life: When using our customer portal, this includes in particular the IP address, access data and detailed information on use such as behavioural and preference data;
• Data in connection with legal proceedings and disputes: e.g. data concerning complaints and differences in benefits or related contracts;
• Data from publicly accessible sources: e.g. data from the debt collection register, land registers,  commercial register, the press or internet, or data from other companies within the Swiss Life Group, from authorities or other third parties.

We usually receive personal data in the above-mentioned categories from you, from your employer and your reinsured employee benefits institution (e.g. master or contract data) but also potentially from third parties such as contractual partners, your family members, address service providers (master data), credit reporting agencies and other information service providers (e.g. master and financial data), representatives of yourself and other persons associated with you, and other sources (e.g. the media or internet).

If you act on behalf of third parties or provide us with third-party data (e.g. when designating beneficiaries), we kindly ask you to inform these third parties in advance about our processing of their personal data. We  also ask you not to disclose to us any personal data of third parties without their consent. 

We process personal data for the following purposes:

• Initiation, conclusion, management and execution of contracts with the Vested Benefits Foundation Swiss Life (in particular for 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 management of offers and contracts including forwarding of data to our cooperation partners). For this purpose we process, in particular, master data, contract data, financial data, communication data and data of the account and custodian bank’s contact persons.  
• 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 reputation 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 the  authorities, support in the prevention, detection and investigation of criminal offences and other  breaches). We process in particular master data, contract, property and payment data, communication data and, in some cases, behavioural data for these purposes;
• Prevention, risk management, legal protection (e.g. risk assessments, prevention of misuse, internal and external investigations, legal proceedings, corporate management and corporate 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, the media, social media, the Internet and other public sources.  
• 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.

Your personal data may be disclosed to the following categories of recipients insofar as this is necessary for  the purposes set out in cl. 4:

• Lienhardt & Partner Privatbank Zürich AG;
• Counterparties and banks in transactions;
• Our Group companies (for details see www.swisslife.com/en/home/about-us.html);
• Intermediaries, address providers and brokers;
• Authorities, courts and offices;
• Other third parties, such as cooperation partners of Swiss Life;
• 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.).

The aforementioned recipients may be located abroad (e.g. if the policyholder is not domiciled in Switzerland or the address for service is not in Switzerland, when transmitting personal data to banks and  other bodies in connection with assets located abroad, when purchasing IT services from abroad, in foreign  legal proceedings, etc.). Personal data may therefore be processed anywhere in the world, including outside the EU or the European Economic Area (e.g. in the USA or on other continents). 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 www.edoeb.admin.ch), 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, or if the data subject has given their consent). If further measures are required as a result of a specific instance of data transmission, we will also take this into account appropriately. Please note that while contractual provisions may partially compensate f for weaker or missing legal protection, they cannot fully exclude all risks (e.g. of government interventions  abroad). 

Swiss Life does not make any automated individual decisions based on personal data. Should this change in  the future, Swiss Life will ensure transparency and the associated rights. 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.  

Data is stored for as long as the processing purposes, statutory retention periods and legitimate interests of  the Vested Benefits Foundation Swiss Life and/or Swiss Life Wealth Management Ltd 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 (cl 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 data as part of the usual procedures at Swiss Life.

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

• To request information from us as to whether and which personal data we process about you;
• To have personal data corrected by us if it is inaccurate;
• To object to our processing and to request the deletion of personal data if we are not obliged or entitled to process it further; 
• 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 you wish to exercise any rights against us, please contact us in writing or by e-mail (contact details listed in  cl. 2). In order to rule out misuse, we will 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  cl. 2. You can contact the Swiss supervisory authority at https://www.edoeb.admin.ch.

Should the provision or disclosure of information be manifestly unfounded or not possible, in particular due to a law, a judicial order, overriding interests of third parties or for other reasons, we are entitled to refuse, restrict or postpone such provision or disclosure of information.

Swiss Life Wealth Management Ltd 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 Wealth Management Ltd 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).

Last update: August 2023