PRIVACY POLICY OF COREFINANZ AG

If there are variances, the German version has priority over the English translation

1 What is this privacy statement about?

Corefinanz AG (hereinafter also referred to as “we“, “us“) obtains and processes personal data concerning you or also other persons (so-called “third parties“). We use the term “data” here synonymously with “personal data“.

In this Privacy Policy, we describe what we do with your information when you use www.corefinanz.ch (the “Site“), obtain our services or products, otherwise interact with us under a contract, communicate with us, or otherwise deal with us. Where appropriate, we will provide you with timely written notice of additional processing activities not mentioned in this Privacy Policy.

If you transmit or disclose data about other persons such as family members, work colleagues, etc., we assume that you are authorized to do so and that this data is correct. By submitting data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act ( “DSG” ) and the revised Swiss Data Protection Act (“revDSG“). However, whether and to what extent these laws are applicable depends on the individual case.

2 Who is responsible for the processing of your data?

Corefinanz AG, Badenerstrasse 15, 8004 Zurich, is responsible for the data processing of Corefinanz AG described in this data protection declaration, . Unless otherwise communicated in individual cases, e.g. in further data protection declarations, on forms or in contracts .

You can contact us for your data protection concerns and the exercise of your rights under Section 11 as follows:

Corefinanz AG
Badenerstrasse 15
CH-8004 Zurich
dataprotection@corefinanz.ch

3 What data do we process?

Technical data: When you use our website or other electronic offerings, we collect the IP address of your terminal device and other technical data to ensure the functionality and security of those offerings. This data also includes logs recording the use of our systems. We generally retain technical data for 6 In order to ensure the functionality of these offers, we may also assign an individual code to you or your end device (e.g. in the form of a cookie, cf. sec. 12). The technical data in itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they can be linked to other data categories (and thus possibly to your person).
Registration data: Certain offers and services, such as newsletter delivery, can only be used with a user account or registration, which can be done directly with us or through our external login service providers. In doing so, you must provide us with certain data and we collect data about the use of the offer or service. Access controls to certain facilities may generate registration data; depending on the control system, biometric data may also be generated. We generally retain registration data for 12 months after the end of the use of the service or the termination of the user account.
Communication Data: When you are in contact with us via the contact form, email, telephone, letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the boundary data of the communication. If we want or need to establish your identity, we collect data to identify you (e.g., a copy of an identification document). We generally retain this data for 12 months from the last exchange with you. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally retained for at least 10
Master Data: We refer to Master Data as the basic data that we need, in addition to Contractual Data (see below), to process our contractual and other business relationships or for marketing and promotional purposes, such as name, contact details and information about, for example, your role and function, bank account(s), date of birth, customer history, powers of attorney, signature authorizations and consent forms. We process your master data if you are a customer or other business contact or work for one (e.g. as a contact person of the business partner), or because we want to address you for our own purposes or the purposes of a contractual partner (e.g. as part of marketing and advertising, with invitations to events, with newsletters, etc.). We receive master data from you yourself (e.g. when you make a purchase or as part of a registration), from bodies for which you work, or from third parties such as our contractual partners, associations and address dealers, and from publicly accessible sources such as public registers or the Internet (websites, social media, etc.). We may also collect master data from our shareholders and investors. We generally retain this data for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons . For pure marketing and advertising contacts, the period is usually much shorter, usually no more than 2 years since the last contact.
Contract data: This is data that arises in connection with the conclusion or execution of a contract, e.g., information about contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract that is required or used for processing . We generally collect this data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third-party sources (e.g. providers of creditworthiness data) and from publicly available sources. We generally retain this data for 10 years from the last contractual activity, but at least from the end of the contract. This period may be longer, insofar as this is necessary for reasons of evidence or to comply with legal or contractual requirements or is technically required.
Behavioral and preference data: Depending on our relationship with you, we try to get to know you and better tailor our products, services and offers to you. To do this, we collect and use data about your behavior and preferences. We do this by evaluating information about your behavior in our area, and we may also supplement this information with information from third parties – including publicly available sources. Based on this, we can, for example, calculate the probability that you will use certain services or behave in a certain way. The data processed for this purpose is partly already known to us (e.g. when you use our services), or we obtain this data by recording your behavior (e.g. how you navigate on our website). We anonymize or delete this data when it is no longer meaningful for the purposes pursued, which may be between 12 weeks and 24 months (for product and service preferences) depending on the nature of the data. This period may be longer to the extent necessary for evidentiary reasons or to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in para. 12.
Other data: We also collect data from you in other situations. In connection with official or judicial proceedings, for example, data is collected (such as files, evidence, etc.) that may also relate to you. We may also collect data for health protection reasons (e.g. as part of protection concepts). We may obtain or produce photos, videos and sound recordings in which you may be recognizable (e.g. at events, through security cameras, etc.). We may also collect data about who enters certain buildings when or has corresponding access rights (incl. during access controls, based on registration data or visitor lists, etc.), who participates in events or campaigns (e.g. competitions) and when, or who uses our infrastructure and systems. Finally, we collect and process data about our shareholders and other investors; in addition to master data, this includes information for the relevant registers, regarding the exercise of their rights and the holding of events (e.g. general meetings). The retention period for this data depends on the purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras and usually a few weeks for contact tracing data, to visitor data that is usually kept for 2 months, to reports on events with pictures that can be kept for a few years or longer. Data about you as a shareholder or other investor is retained in accordance with company law requirements, but in any case for as long as you are invested .

Much of the information contained in this sec. 3 you give us yourself. You are not obliged to do so, subject to individual cases, e.g. as part of binding protection concepts (legal obligations ). If you wish to conclude contracts with us or claim services, you must also provide us with data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.

Unless this is inadmissible, we also take data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the Internet incl. social media) or receive data from other companies within our group, from public authorities and from other third parties (such as credit agencies, address traders, associations, contractual partners, Internet analysis services, etc.).

4 For what purposes do we process your data?

We process your data for the purposes we explain below. Further information for the online area can be found in para. 12 and 13. These purposes or the underlying objectives represent legitimate interests of us and, if applicable, of third parties. You will find further information on the legal basis for our processing in para. 5.

We process your data for purposes related to communication with you, in particular to respond to inquiries and assert your rights (para. 11) and to contact you in the event of queries. For this purpose, we use in particular communication data and master data and, in connection with offers and services used by you, also registration data. We retain this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

We process data for the establishment, administration and processing of contractual relationships.

We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalized advertising about products and services from us and from third parties. This can take place, for example, in the form of newsletters and other regular contacts (electronically, by mail, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, etc.) and may also include free services (e.g. invitations, vouchers, etc.). You can refuse such contacts at any time (see at the end of this section). 4) or refuse or revoke your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the Internet more specifically to you (see Sec. 12).

We further process your data for market research, to improve our services and operations, and for product development.

We may also process your data for security and access control purposes.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations (“Compliance“).

We also process data for the purposes of our risk management and as part of prudent corporate governance, including operational organization and corporate development.

We may process your data for other purposes, e.g. as part of our internal processes and administration or for training and quality assurance purposes.

5 On what basis do we process your data?

Insofar as we ask for your consent for certain processing, we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time with future effect by written notification (by post) or, unless otherwise stated or agreed, by e-mail to us; you will find our contact details in para. 2. For the revocation of your consent for online tracking, cf. para. 12. Where you have a user account, revocation or contacting us may also be possible via the relevant website or other service. Once we have received notification of the withdrawal of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The revocation of your consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Where we do not ask for your consent for processing, we base the processing of your personal data on the fact that the processing is necessary for the initiation or execution of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, such as, in particular, in order to fulfill the obligations set out above under section 4. 4 described above and to be able to implement appropriate measures. Our legitimate interests also include compliance with legal requirements, insofar as this is not already recognized as a legal basis by the applicable data protection law in each case (e.g., in the case of the GDPR, the law in the EEA and Switzerland). However, this also includes the marketing of our products and services, the interest to better understand our markets and to safely and efficiently manage and develop our business, including operations.

If we receive sensitive data (e.g. health data, information on political, religious or ideological views or biometric data for identification purposes), we may also process your data on the basis of other legal grounds, e.g. in the event of disputes due to the need for processing for a possible lawsuit or the enforcement or defense of legal claims. In individual cases, other legal grounds may come into play, which we will communicate to you separately where necessary.

6 What applies to profiling and automated individual decisions?

We may add certain of your personal characteristics to those listed in sec. 4 purposes mentioned in section 4 on the basis of your data (para. 3) automatically (“profiling”), if we want to determine preference data , but also to determine abuse and security risks, to perform statistical evaluations or for operational planning purposes. For the same purposes, we may also create profiles, i.e. we may combine behavioral and preference data, but also master and contract data and technical data assigned to you, in order to better understand you as a person with your different interests and other characteristics.

If you are a customer of ours, we can, for example, use “profiling” to determine which other products are likely to interest you based on your purchases. However, we can also use it to check your creditworthiness before offering you a purchase on account. Automated analysis of data can also check, for your protection, the likelihood of a particular transaction being fraudulent. This allows us to stop the transaction for clarification. To be distinguished from this are “profiles”. This refers to the linking of various data in order to gain clues about essential aspects of your personality (e.g. what you like or how you behave in certain situations) from the totality of this data. Profiles can also be used for marketing, for example, but also for security purposes.

In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. If these can have legal effects or significant disadvantages for you, we generally provide for a manual review.

7 Who do we disclose your information to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other interests described in para. 4 we also transfer your personal data to third parties, in particular to the following categories of recipients:

Service providers: We work with service providers in Germany and abroad who process data about you on our behalf or under joint responsibility with us or who receive data about you from us under their own responsibility. For information on the service providers used for the website, see para. 12. Central service providers in the IT area for us are Bexio, Integrately, Google, Mailchimp, Microsoft, Pipedrive and Central service providers in the area of credit reports are Moneyhouse and OLMeRO.
Contractual partners including customers: This initially refers to customers (e.g. service recipients) and other contractual partners of ours, because this data transfer arises from these contracts. If you work for such a contractual partner yourself, we may also transfer data about you to them in this The recipients also include contractual partners with whom we cooperate.
Authorities: We may disclose personal data to offices, courts and other authorities in Germany and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The authorities process data about you that they receive from us on their own responsibility.
Other persons: This refers to other cases where the inclusion of third parties arises from the purposes set forth in para. 4 results.

All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).

8 Does your personal data also end up abroad?

As described in para. 7 we also disclose data to other entities. These are not only located in Switzerland. Your data may therefore be processed both in Switzerland and in Europe; in exceptional cases, however, in any country in the world.

If a recipient is located in a country without adequate legal data protection, we contractually oblige the recipient to comply with the applicable data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? ), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have consented or if it is a matter of data made generally available by you, the processing of which you have not objected to.

Please also note that data exchanged via the Internet is often routed via third countries. Your data may therefore end up abroad even if the sender and recipient are in the same country.

9 How long do we process your data?

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. Further information on the respective storage and processing periods can be found under the individual data categories in section 3. 3 or for the cookie categories in para. 12. If there are no legal or contractual obligations to the contrary, we will delete or anonymize your data after the storage or processing period has expired as part of our normal processes.

10 How do we protect your data?

We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal information, to protect it against unauthorized or unlawful processing, and to protect against the risks of loss, accidental alteration, unauthorized disclosure or access.

11 What rights do you have?

Applicable data protection law grants you the right to object to the processing of your data in certain circumstances, in particular that for direct marketing purposes, profiling used for direct marketing and other legitimate interests in processing.

To help you control the processing of your personal data, you also have the following rights in connection with our data processing, depending on applicable data protection law:

The right to request information from us as to whether and what data we are processing from you;
the right to have us correct data if it is inaccurate;
the right to request the deletion of data;
the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
the right to withdraw consent, insofar as our processing is based on your consent;
the right to receive, upon request, further information necessary for the exercise of these rights;

If you wish to exercise any of the above rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; our contact details are set out in para. 2. In order for us to exclude misuse, we must identify you (e.g. with a copy of your ID card, if this is not otherwise possible).

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (e.g., to protect third parties or trade secrets). We will inform you accordingly if necessary.

If you do not agree with our handling of your rights or data protection, please inform us or our data protection officer (para. 2). In particular, if you are located in the EEA, the United Kingdom or Switzerland, you also have the right to complain to the data protection supervisory authority in your country.

12 Do we use online tracking and online advertising techniques?

On our website, we use various techniques with which we and third parties engaged by us can recognize you during your use and possibly also track you over several visits. In this section we inform you about it.

In essence, this is so that we can distinguish accesses by you (via your system) from accesses by other users, so that we can ensure the functionality of the website and carry out evaluations and personalizations. In doing so, we do not want to infer your identity, even if we can do so to the extent that we or third parties engaged by us can identify you through a combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognized as an individual visitor each time you access the site, for example by our server (or the servers of third parties) assigning you or your browser a specific recognition number (so-called “cookie”).

We use such techniques on our website and allow certain third parties to do so as well. You can program your browser to block, deceive, or delete existing cookies from certain cookies or alternative techniques. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword “Privacy”) or on the websites of the third parties that we list below.

The following cookies are distinguished (techniques with comparable functionalities such as fingerprinting are included here):

Necessary cookies: Some cookies are necessary for the functioning of the website as such or certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies only exist temporarily (“session cookies”). If you block them, the website may not work. Other cookies are necessary so that the server can store decisions or entries made by you beyond one session (i.e. one visit to the website), if you request this function (e.g. selected language, given consent, the function for an automatic login, etc.). These cookies have an expiration date of up to 24
Performance cookies: In order to optimize our website and corresponding offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, possibly even beyond the session. We do this through the use of third-party analytics services. We have listed these below. Before we use such cookies, we ask for your consent. Performance cookies also have an expiration date of up to 24 Details can be found on the websites of the third-party providers.
Marketing Cookies: We and our advertising partners have an interest in targeting advertising, i.e. displaying it only to those we want to target. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – also use cookies that can be used to record the content accessed or contracts concluded. This allows us and our advertising contractors to display advertisements that we think you will be interested in, on our website, but also on other websites that display advertisements from us or our advertising contractors. These cookies have an expiration period ranging from a few days to 12 months, depending on the situation. If you consent to the use of these cookies, you will be shown appropriate advertising. If you do not consent to these cookies, you will not see less advertising, but simply any other advertising.

In addition to marketing cookies, we use other techniques to control online advertising on other websites and thereby reduce wastage. For example, we may transmit the e-mail addresses of our users, customers and other persons to whom we want to display advertising to operators of advertising platforms (e.g. social media). If these persons are registered there with the same e-mail address (which the advertising platforms determine by matching), the operators show the advertising we have placed to these persons in a targeted manner. The operators do not receive personal e-mail addresses of persons who are not already known. In the case of known e-mail addresses, however, they learn that these persons are in contact with us and which content they have accessed.

We may also integrate further third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (e.g. by clicking a button), the corresponding providers can determine that you are on our website. If you have an account with the social media provider, it can assign this information to you and thus track your use of online offers. These social media providers process this data under their own responsibility.

We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set on your computer for advertising purposes):

Google Analytics: Google Ireland (based in Ireland) is the provider of the “Google Analytics” service and acts as our order processor. Google Ireland relies on Google LLC (based in the USA) as its order processor (both “Google“). Google thereby tracks the behavior of visitors to our website (duration, frequency of pages viewed, geographic origin of access, etc.) through performance cookies (see above) and creates reports for us on the use of our website on this basis. We have configured the service so that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the USA and thus cannot be traced. We have turned off the “Data Forwarding” and “Signals” settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these individuals. If you consent to the use of Google Analytics, you explicitly agree to such processing, which also includes the transfer of personal data (in particular usage data about the website and app, device information and individual IDs) to the USA and other countries. Information on the data protection of Google Analytics can be found here https://support.google.com/analytics/answer/6004245 and if you have a Google account, you can find further details on processing by Google here https://policies.google.com/technologies/partner-sites?hl=de.

13 What data do we process on our pages in social networks?

We may operate pages and other online presences (“fan pages”, “channels”, “profiles”, etc.) on social networks and other platforms operated by third parties and use there the information described in para. 3 and hereinafter described data about you. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g., when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g., about your behavior and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalize advertising) and to control their platforms (e.g. which content they show you).

We process this data for the purposes described in para. 4 in particular for communication, for marketing purposes (including advertising on these platforms, cf. 12) and for market research. You will find information on the corresponding legal basis in para. 5. Content published by you yourself (e.g. comments on an announcement) may be further disseminated by us (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments).

For further information on the processing of the platform operators, please refer to the data protection notices of the platforms. There you can also find out in which countries they process your data, which rights of access, deletion and other data subjects you have and how you can exercise these or obtain further information. We currently use the following platforms:

Linkedin: Here we operate the site https://ch.linkedin.com/company/corefinanz. Their data protection information is available at https://www.linkedin.com/legal/privacy-policy? Some of your data will be transferred to the USA.

14 Can this privacy policy be changed?

This privacy policy is not part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated: 17.07.2023