Personal information collected by CFinAG
Personal information collected
CFinAG collects personal information to provide you with CFinAG’s Services. When CFinAG requires specific personal information from users, it is because such information is relevant for certain purposes. Any information you provide to CFinAG that is not required is voluntary.
For example, CFinAG collects personal information when you use or request information about CFinAG’s Services, subscribe to marketing communications, request support, complete surveys, or sign up for a CFinAG event or webinar. CFinAG may also collect personal information from you offline, such as when you attend one of CFinAG’s events, or when you contact your relationship manager. CFinAG may use this information in combination with other information CFinAG collects about you.
You are free to choose whether to provide CFinAG with the types of personal information described below, but CFinAG may not be able to serve you as effectively, or offer you some or all of CFinAG’s Services, when you choose not to share certain information with CFinAG.
Here are some examples of the types of personal information CFinAG collects and how CFinAG may use it:
- When you become a Client of CFinAG (or its subsidiaries, respectively), CFinAG, or CFinAG’s external service provider may collect personal information. The following information may be collected: your name, date of birth, driver number, personal ID or passport, address, phone, email, full bank account details, tax or corporate identification number, company legal status, information that CFinAG needs for establishing the controlling person of operating legal entities and partnerships or regarding the identity of the beneficial owner of non-operating entities or information regarding individuals with signatory powers (first and last name, address, email, curriculum vitae), or authorised traders (first and last name, nationality, date of birth, etc.). CFinAG will use this information to fulfil your requests and provide the relevant Services.
- Whenever you contact CFinAG or respond to CFinAG’s communications (e.g., email, telephone, in writing), CFinAG will receive your contact information and any other personal information you choose to provide CFinAG. CFinAG will use such information to fulfil your requests or to provide Services.
How personal information is used
CFinAG’s primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, CFinAG uses personal information to create, develop, operate, deliver, and improve CFinAG’s Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how CFinAG may use this information include:
- To provide you with CFinAG Services and the client support that you request.
- To process transactions and send notices about your transactions.
- To verify your identity by comparing your personal information against third-party databases.
- To send administrative or account-related information to you.
- To better understand CFinAG’s clients and the way they use and interact with CFinAG-owned and/or CFinAG-operated websites and Services.
- To provide a personalised experience, and to implement the preferences that you request.
- To customise, measure, and improve CFinAG and the content and layout of CFinAG’s website and applications.
- To enhance security, prevent fraud, monitor and verify identity or service access, and to combat spam or other malware or security risks.
- To deliver marketing, service update notices, and promotional offers based on your communication preferences.
- To communicate with you about CFinAG’s events and/or CFinAG’s partner events.
- To prevent and investigate potentially prohibited or illegal activities, and/or violations of CFinAG’s posted user terms.
- To resolve disputes, collect fees, and troubleshoot problems.
- To comply with legal obligations.
- To enforce CFinAG’s agreements with third parties.
- For quality control and staff training.
CFinAG will not use your personal information for purposes other than those CFinAG has disclosed to you without your permission. From time to time, CFinAG may request your permission to allow CFinAG to share your personal information with third parties. You may choose not to have your personal information shared with third parties where CFinAG relies on consent as the lawful basis for processing your personal information. You may also choose not to allow CFinAG to use your personal information for any purpose that is incompatible with the purposes for which CFinAG originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or CFinAG Services may not be available to you.
Information from third party sources
From time to time, CFinAG may obtain information about you from third party sources as permitted by applicable law, such as public databases and ID verification partners: CFinAG obtains information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publically available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. The legal basis for such processing is to comply with CFinAG’s legal obligations, such as anti-money laundering laws. In some cases, CFinAG may process additional data about you based on public interest grounds to ensure CFinAG’s Services are not used fraudulently or for other illicit activities.
CFinAG also processes such information to provide support to you as part of CFinAG’s contractual obligations to you. Lastly, CFinAG processes such information in the public interest because it helps CFinAG monitor, prevent, and detect fraud.
Collection and use of information collected automatically
CFinAG receives and stores certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly, but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer), and your Internet Protocol (IP) address/MAC address/device identifier.
For example, CFinAG automatically receives and records information on CFinAG’s server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g., country or city-level location), and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. CFinAG may also collect information about how your device has interacted with CFinAG’s website, including pages accessed and links clicked. CFinAG may use identifiers to recognise you when you arrive at the website via an external link, such as a link appearing on a third party site.
How CFinAG protects and stores personal information
CFinAG understands how important your privacy is, which is why CFinAG maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to CFinAG.
CFinAG may store and process all or part of your personal and transactional information, including certain payment information, in Switzerland, and elsewhere in the world, where CFinAG’s service providers are located. CFinAG protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, CFinAG uses computer safeguards such as firewalls and data encryption, CFinAG enforces physical access controls to CFinAG’s buildings and files, and CFinAG authorises access to personal information only for those employees who require it to fulfil their job responsibilities.
However, CFinAG cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with CFinAG’s Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to notify CFinAG immediately if you become aware of any unauthorised access to or use of your account.
How CFinAG protects and stores personal information
CFinAG takes care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. CFinAG will never sell or rent your personal information. CFinAG will only share your data in the following circumstances:
- CFinAG may share your information with service providers under contract who help with parts of CFinAG’s business operations such as marketing and technology services. CFinAG’s contracts require these service providers to only use your information in connection with the services they perform for CFinAG, and prohibit them from selling your information to anyone else.
- CFinAG shares your information with financial institutions with which CFinAG partners to process payments you have authorised.
- CFinAG may share your information with any third parties where required to do so by applicable law or any court or other authority to which CFinAG is subject in any jurisdiction; or CFinAG believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the CFinAG Agreements and any other applicable policies.
- CFinAG may share your information with other third parties with your consent or direction to do so.
How CFinAG share personal information with other parties
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting your relationship manager. However, this right is limited where personal information is needed for regulatory purposes.
Rights in the relation to the use of your personal information
You have a right of access to the personal information that CFinAG holds about you under the Federal Act on Data Protection (and the General Data Protection Regulation) and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
You can object to CFinAG’s use of your personal information for direct marketing purposes at any time, and you may have the right to object to CFinAG’s processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact CFinAG as set out below.
Retention of personal information
CFinAG will retain your personal data for as long as is necessary for the purposes of CFinAG’s business relationship with you, to perform CFinAG’s contractual obligations to you, or if longer, as required for legal and regulatory purposes.
CFinAG has established internal policies for the deletion of data from client accounts following termination of a client’s subscription to a Service.
How to contact us