Version from 15.10.2018
Privacy Statement of CB Financial Services AG
1. General scope of application
This document is a translation. In the event of any dispute as to the interpretation of any of these conditions, the official German language version shall prevail.
This privacy statement explains how CB Financial Services AG, Aueli 3,7304 Maienfeld, Switzerland (hereinafter referred to as “CBFS” or “we”) are committed to maintaining the privacy of every current, former and prospective customer and website user and collects and processes personal information. This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation and similar documents may regulate specific circumstances. Personal data means all information relating to a specific or identifiable person.
If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please make sure that these persons are aware of the present data protection declaration and only provide us their personal data if you are allowed to do so and if this personal data is correct.
This privacy statement is based on the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union, it is of importance to us. The Swiss Data Protection Act (DPA) is strongly influenced by EU law, and companies outside the European Union or the European Economic Area (EEA) must comply with the GDPR under certain circumstances.
2. Person in charge/ data protection officer/ the representative
The person responsible has a data protection officer in accordance with Art. 37 DSG-VO:
CB Financial Services AG is responsible for the data processing that we describe here, unless otherwise stated in individual cases. If you have any data protection concerns, you can send them to us at the following contact address: firstname.lastname@example.org.
Responsible is CB Financial Services AG, Aeuli 3, 7304 Maienfeld, Switzerland.
3. Collection and processing of personal data
We primarily collect and store personal data which you make available to us as part of one of our services, for example in the case of an identification (e.g. online- or video identification). This includes in particular personal data (name, address and other contact data, nationality, copy of your identification document, including images (e.g. ID card data), screen shots, videos and sound data documenting the identification and biometric data to ensure and verify your identity (e.g. comparison of ID photo with your face photo), where only the result is communicated to the client, we are performing the identification for. No biometric data is stored.
On the other hand, information is automatically stored when you use the CBFS website. This includes, for example, data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages called up and content, functions used, referring website, location information).
If permitted and necessary in connection with one of our services, we also extract data from publicly accessible sources (e.g. debt enforcement register, land register, commercial register, press, Internet) or receive such data from other companies, authorities or other third parties that are in cooperation with CBFS. In particular, this data includes information from public registers, information in connection with official or judicial proceedings, information on your professional functions or activities, creditworthiness information (insofar as we conduct business with you personally), your address for any deliveries, information on compliance with legal requirements such as the fight against money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the use of or provision of services by you (e.g. payments made, activities carried out, purchases made), information from the media and the Internet regarding your person (insofar as this is indicated in the specific case, e.g. in the context of an application, press review, marketing/sales, etc.).
4. Purposes of data processing and legal basis
We use the personal data collected by us primarily in order to conclude and process our contracts with our clients and business partners, in particular within the framework of video- and online identification, online sales with our clients and the purchase of products and services from our suppliers and subcontractors, as well as to fulfil our legal obligations at home and abroad. If you work for one of our clients or business partners, you may also be affected in this function regarding your personal data.
In addition, we process personal data from you and third parties, if we are allowed to do so and in case of a justified interest for example in the following business purposes:
– Offer and further development of our offers, services and websites, apps and other platforms on which we are present;
– Communication with third parties and processing of their enquiries (e.g. applications, media enquiries);
– Checking and optimizing needs analysis procedures, in order to address customers directly and to collect personal data from publicly accessible sources in order to acquire customers;
– Advertising and marketing (including the execution of events), insofar you have not objected to the use of your data (in case you receive an advertising from us as an existing customer, you can object to this at any time; we will then place you on a blocking list against further advertising mailings);
– Market and opinion research, media monitoring;
– Assertion of legal claims and defense in connection with legal disputes and official proceedings;
– Prevention and clarification of criminal offences and other misconducts (e.g. conducting internal investigations, data analyses to combat fraud);
– Warranties of our operations, in particular IT, our websites, apps and other platforms;
– Safeguarding house rules through access controls, visitor lists and other measures for IT, building, floor security and the protection of our employees and other persons and assets belonging to or entrusted to us (such as network and mail scanners);
– Purchase and sale of business units, companies or parts of companies and other transactions under company law and the related transfer of personal data as well as measures for business management and to the extent necessary to comply with legal and regulatory obligations and internal regulations of CB Financial Services AG.
If you have given us your consent to process your personal data for certain purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis. A given consent can be revoked at any time, but this has no effect on data processing that has already taken place.
5. Who gets access to the personal data
Access to your data may be gained both inside and outside our company. Within the company, only positions or employees may process your data insofar as they need it to fulfil our contractual or legal obligations and to safeguard legitimate interests. Outside our company, our client, for whom we carry out a video- or online identification, will have access to this data and process it within the scope of his business relationship with you. Other group companies, service providers or vicarious agents may also receive personal data for these purposes in compliance with the applicable legal confidentiality provisions. Contract processors are in particular companies which carry out the video- or online identification on our behalf and IT service providers. In addition, QuoVadis receives your name and telephone number as part of the video- and online identification in order to issue your certificate.
The data will only be transmitted abroad if our client, for whom we carry out the video- or online identification, is located abroad. In this case, the data transfer is based on your contract with our client and with your consent.
6. Cookies / Tracking and other technologies related to the use of our website
We typically use “cookies” and similar techniques on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser used when you visit our website. When you return to this site, we may recognize you even if we do not know who you are. In addition to cookies, which are only used during a session and are deleted after your website visit (“session cookies”), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) (“permanent cookies”). However, you can set your browser so that it rejects cookies, saves them only for one session or otherwise deletes them prematurely. Most browsers are preset so that you accept cookies. We use permanent cookies so that we can save user settings (e.g. language, autologin), better understand how you use our offers and contents and to display offers and advertisements tailored to you (which can also happen on websites of other companies; however, we will not tell them who you are even if we have knowledge of it). Some of the cookies are set by us, some also by contract partners with whom we cooperate. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.
In our newsletters and other marketing e-mails, we partly and to the extent permitted also incorporate visible and invisible picture elements, by whose retrieval from our servers we can determine whether and when you have opened the e-mail, so that we can also here measure and better understand how you can use our offers and tailor them to you. You can block this in your email program; most are preset to do so, and by using our websites and opting in to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not agree, you must set your browser or e-mail program accordingly.
7. Google Analytics
We may use Google Analytics or similar services on our websites. This is a service provided by third parties who may be located in any country of the world (in the case of Google Analytics, it is Google LLC in the USA, www.google.com), with which we can measure and evaluate the use of the website (not personal). Permanent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us (nor does it keep any IP addresses), but can track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by service providers, and use this information for its own purposes (e.g. advertising control). If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider merely informs us how our respective website is used (no information about you personally).
8. Social Media
We also use so-called plug-ins from social networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram on our websites. This is visible to you in each case (typically via corresponding symbols). We have configured these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and can use this information for their purposes. The processing of your personal data then takes place under the responsibility of this operator in accordance with its data protection regulations. We do not receive any information about you from them.
9. Duration and storage of personal data
We process and store your personal data as long as it is necessary for the fulfilment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond that according to the legal storage and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so, or justified business interests require this (e.g. for purposes of proof and documentation). If the data are no longer necessary for the fulfilment of contractual or legal obligations or for the protection of our legitimate interests (achievement of purpose) or if a consent given is revoked, they will be deleted, unless further processing is necessary due to the contractual or legal retention periods and documentation obligations or for reasons of preservation of evidence during the duration of the applicable statute of limitations.
10. Data security
We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, controls.
11. Obligation to provide personal data
As part of our business relationship, you must provide the personal information necessary to establish and conduct a business relationship and to fulfill the contractual obligations associated therewith (you do not usually have a legal obligation to provide us with information). Without this information, we will generally not be able to enter into or complete a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.
12. Profiling and automated decision making
For the establishment and execution of the business relationship and also otherwise we do not use any fully automated decision making (as regulated in Art. 22 GDPR, for example). Should we use such procedures in individual cases, we will inform you separately, insofar as this is prescribed by law, and inform you of the rights associated with it.
13. Rights of data subjects
You have the right to receive information, to be able to correct and the right to restrict data processing, object to our data processing and to the transmission of certain personal data for the purpose of transfer to another location (so-called data portability) within the framework of the data protection law applicable to you (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the legally stipulated restrictions on our part, for example if we are obliged to store or process certain data, if we have an overriding interest on it (insofar as we may invoke it) or if we need it for the assertion of claims. If you incur any costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that the exercise of these rights may conflict with contractual agreements and this may have consequences such as premature termination of the contract or cost consequences. In this case, we will inform you in advance if this has not already been contractually agreed.
The exercise of such rights usually requires that you prove your identity unambiguously (e.g. by a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To exercise your rights, you may contact us at the address provided in paragraph 1. In addition, every person concerned has the right to assert their claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
We may change this privacy statement at any time without notice. The current version published on our website applies.
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