Privacy Policy Swiss Life Wealth Management Ltd

^{Privacy policy
As at 01.01.2024 (Version 2.1)}

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 you contact a representative of the Swiss Life Group near you or one of our Group companies via their website (https://www.swisslife.com).

Please find below an overview of the processing carried out on personal data by Swiss Life in connection with wealth management. This processing involves the following persons (referred to as “you”):

• Asset management clients;
  
• Past, current and future employers and/or their contact persons;
  
• Authorised representatives;
  
• Persons involved in our sales organisation;
  
• Contact persons of third parties (e.g. insurers, suppliers, partners or authorities).

Please also refer to our other data protection notices for our activities outside of wealth management. You can find information on this via this link.

In accordance with data protection legislation, the following company is responsible for the data processing described here:

Swiss Life Wealth Management Ltd
General-Guisan-Quai 40
P.O. Box, 8022 Zurich

For data protection concerns, you can contact us at the following address:

Swiss Life Wealth Management Ltd
- Data Protection -
General-Guisan-Quai 40
P.O. Box, 8022 Zurich
E-Mail: dataprotection@swisslife-wealth.ch

As custodian bank, Lienhardt & Partner is responsible in particular for reviewing and complying with the statutory requirements as an independent controller. Further information on data protection can be found on the website of Lienhardt & Partner (www.lienhardt.ch/datenschutzerklaerung).

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

• Master data (e.g. name, address, contact details, gender, date of birth and age, marital status, languages, country of birth and nationalities, tax domicile, data from identification documents and databases such as World Check and other data relating directly to you);
  
• Financial data (e.g. information on assets, debts, income and expenses, information on the investment profile, information on payments and receivables, payment method data, tax information and other data relating to financial situations);
  
• Contract data (e.g. information on contract conclusions and contracts and their fulfilment, enforcement and termination and other contract-related information);
  
• 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; 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).
  

We usually receive this data from you, but also potentially from third-party sources such as your family members, the 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.

We process your personal data (section 3) in connection with wealth management, 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 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 and financial data, communication data and, in some cases, behavioural data for these purposes.
  
• Initiation, conclusion, management and execution of asset management and other contracts (e.g. financial planning, investment advice, communication, risk assessment, planning, scheduling and customer care, contract management and customer data management, customer service, enforcement of contracts (collection, court proceedings etc.), accounting and communication). 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, the media, social media, the internet and 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, maintaining advertising black-lists). To that end, we also link data that we process about you and determine preference data. You may object to the processing for marketing purposes at any time by notifying us. Further information on your rights can be found in
  section 8.
  
• 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, purchasing or selling companies or assets, statistics and research, safeguarding other legitimate interests.
  

"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 preference 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 (you can find information via this link);

• 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).
  

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). 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 via this link), 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 it, we will delete or anonymise your data as part of our usual procedures.

Every time you use our website, certain data is generated for technical reasons, which is temporarily stored in log files, in particular the IP address of the end device, information about the internet service provider and the operating system of your end device, information about the referring URL, information about the browser used, date and time of access and content accessed when visiting the website. We process this data so that our website can be kept secure and stable, to optimise our website and for statistical purposes.

Our website also uses cookies (technically necessary, functional cookies as well as marketing and performance cookies), i.e. files that your browser automatically stores on your device. This allows us to distinguish between individual visitors, but usually without identifying them. Cookies may also contain information about the pages visited and the duration of the visit. We may also use other technologies, e.g. to store data in the browser, but also to distinguish between returning visitors. You can configure your browser in “Settings” if you wish to block certain cookies or similar technologies or to delete cookies and other stored data. You can find more about this in the help pages of your browser.

These cookies and other technologies may also originate from third parties. We use the following services:

• Adobe Analytics, a web analytics service. Adobe Analytics uses cookies that transmit information to Adobe about the use of the website, e.g. anonymous information about content accessed, the browser and device type used, technical performance data. This makes it impossible to identify specific persons; the IP address is only used for geolocation and is anonymised. Adobe uses this information on our behalf to evaluate the use of the website, compile reports on website activities and provide other related services.
  
• Adobe Target. This allows us to carry out so-called A/B tests, i.e. we can produce different contents and compare them with each other. Adobe Target also allows us to display context-dependent hints and provide information on current campaigns and offers. Adobe Target records user behaviour for this purpose, but not complete IP addresses or data that can be used to identify individual persons.
  
• Adform. The purpose of the service is to offer behavioural internet advertising by means of a tracking pixel embedded on our website. When visiting our website, playing videos on this landing page or another Adform customer’s website, it is stored on the visitor’s device. The cookie contains a random identification number or information about advertising activities on an advertiser’s website. With random cookie identification numbers, Adform collects and stores anonymous information in the cookie-based profiles, such as: operating system, browser version, geographic location, URL on which Adform displays advertising, or information about interactions with advertisements (e.g. number of clicks or views). When requests are sent to the Adform servers, IP addresses of internet users are accessible to Adform. These addresses are anonymised in accordance with local data protection laws. Recognition is possible on other websites. More information from Adform about the collection, processing and use of your data can be found here.
  
• LinkedIn conversion tracking. We use LinkedIn conversion tracking components on our website. This allows you to see relevant advertising based on your interests. We also receive aggregated and anonymous reports from LinkedIn about ad activities and information about how you interact with our website. For details on data collection by LinkedIn, as well as on your rights and settings, please refer to LinkedIn’s privacy policy. You can prevent your usage behaviour being analysed by LinkedIn (via settings & data protection) and interest-based recommendations being shown (opt-out).
  
• Facebook pixel, Facebook custom audiences and Facebook conversion. With the help of the Facebook pixel, Facebook can identify you as a visitor to our online offering as a target group for the display of ads (Facebook ads). Accordingly, we use the Facebook pixel to display the Facebook ads we have placed only to those Facebook users who have also shown an interest in our online offering or who have certain features (e.g. interest in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (“custom audiences”). We also use the Facebook pixel to ensure that our Facebook ads correspond to the potential interest of the users and do not harass them. The Facebook pixel also helps us to understand the effectiveness of Facebook advertisements for statistical and market research purposes, as we see whether users have been forwarded to our website after clicking on a Facebook advertisement (“conversion”). You can find further information on the protection of your privacy in facebook.com’s privacy policy. You can also deactivate the “custom audiences” remarketing function for your profile under the privacy section in settings To do this, you must be logged in to Facebook. If you do not have a Facebook account, you can disable Facebook’s usage-based advertising on the website of the European Interactive Digital Advertising Alliance.
  
• Google Ads. As part of Google AdWords, we use conversion tracking to draw attention to our attractive offers with the help of advertising media (Google Ads) on external websites. We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. We can thus show you advertisements that are of interest to you, make our website more interesting for you and achieve a fair calculation of advertising costs. Further information on conversion tracking and in particular how you can prevent the collection of data by the cookie set by Google can be found under support.google.com. You can deactivate all or part of cookie setting by our website in your browser at any time. If cookies are deactivated, you may no longer have access to all the functions of our website. More information about Google AdWords and Google conversion tracking can be found in Google’s privacy policy.
  

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 have data corrected by us if it is inaccurate;
  

• To object to our processing and to request the deletion of 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 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 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 section 2. The Swiss supervisory authority can found via this link.

We host competitions at our events and on social media platforms (e.g. Facebook, LinkedIn) and are therefore responsible for holding them. The general terms and conditions of participation can be found below:

Unless otherwise stated, a competition begins and ends in accordance with the relevant competition information, without further notification being required. Competitions cannot be entered after the deadline has expired. The prizes and other rules of the respective competition (especially the steps required to enter it) are stated in the respective competition description.

Unless otherwise stated, prizes will be sent to the winners. 

All individuals resident in Switzerland who are over 18 years of age are eligible to take part. Employees of the Swiss Life Group and any participating agencies, as well as their relatives, may not take part. Participation in the competition does not depend on ordering a product, receiving a service or making a purchase.

The winners will be informed that they have won in an appropriate form.

The prerequisites for participation are the disclosure of suitable contact details and the acceptance of the conditions of participation. In addition, a prerequisite for receiving the prize is that the winner can be contacted in electronic form immediately (within 48 hours at the latest) after the draw (or by any specified or obvious fixed date). If these conditions are not met, the prize shall be forfeited and we shall be entitled to award the prize elsewhere.

There will be no cash payment. There is no entitlement to a prize. Prizes are non-transferable. We are not liable for any defects in a prize. There is no right of appeal. With the exception of informing the winners, no correspondence will be entered into regarding the draw.

We also reserves the right to exclude participants from the competition if it is suspected or determined that there is any abuse and/or breach of these conditions of participation or if there is other good cause. We are entitled to change how the competition is run at any time and to suspend, cancel or terminate the competition prematurely if there is good cause to do so. 

The participants hereby give their express agreement to any further processing of the data provided as part of their participation in the competition for Swiss Life Wealth Management Ltd’s marketing purposes. The data will not be forwarded to third parties. Data relating to minors will not be used for marketing purposes. Participants also agree to the use of shared images for Swiss Life marketing purposes.

Personal data is processed in accordance with this Privacy Policy.

We reserve the right to amend this privacy policy from time to time so that it always complies with current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. The version published here applies in every case.

Last update: January 2024