Privacy Policy

A. GENERAL INFORMATION

In this section, you will learn who is responsible for processing your data, who you can contact in case of questions or complaints regarding data protection, how we protect your data, and how you can generally protect your data.

This privacy policy is designed to meet the requirements of the Swiss Data Protection Act (“DSG”). However, whether and to what extent these laws apply depends on the specific case.

I. Data Controller

The data controller for the collection and use of your personal data on our online platform and when using our services under data protection laws is:

Finturis GmbH
Baarerstrasse 78
6302 Zug

info@finturis.ch

If you have any questions regarding the collection and use of data, you can contact us at any time.

II. Data Security & Privacy-Friendly Settings

1. Data Security

Finturis takes appropriate security measures to maintain the confidentiality, integrity, and availability of your personal data to protect it against unauthorized or unlawful processing and to mitigate the risks of loss, accidental alteration, unauthorized disclosure, or unauthorized access.

2. Privacy-Friendly Settings

To remove or clean up existing cookies or similar technologies from other websites, you can set privacy-friendly settings in your browser or use specific opt-out options. Here are some steps you can take:

1. Delete Cookies:
   Most browsers offer the option to delete stored cookies. Go to your browser settings and search for the privacy section or data protection settings. You will typically find an option to manage and delete cookies there.
2. Use Incognito/Private Mode:
   Many browsers have an incognito or private mode that limits the saving of cookies and other data while browsing. You can enable this mode to prevent new cookies from being stored.
3. Use Browser Extensions:
   There are various browser extensions and add-ons that help block or control tracking by cookies and similar technologies. Look for extensions compatible with your browser and install them according to the provider’s instructions.
4. Use Opt-Out Options:
   Some companies and ad networks offer opt-out options, allowing you to decline certain tracking cookies. Visit the websites of these companies and ad networks to learn more about their privacy policies and opt-out options.

Please note that deleting cookies or adjusting browser settings may affect the functionality of certain websites or services. It is advisable to inform yourself about the effects of these changes beforehand.

B. YOUR DATA PROTECTION RIGHTS

This section outlines your data protection rights concerning your data. These rights include, among others, the right to access the data stored about you, the right to rectification, and, if legal conditions are met, the right to erasure of your data. Whenever we ask for your consent to process your data, you also have the right to withdraw your consent at any time without giving a reason.

I. Access

You have the right to request information about the processing of your personal data at any time. We will explain the data processing to you and provide an overview of the data stored about you.

When you request access to your data, we will provide you with comprehensive information on how your data is processed, where it comes from, and where it goes.

II. Rectification

If the data we have stored is incorrect or no longer up to date, you have the right to have this data corrected.

We will respond to your request promptly.

For rectification, you can provide us with the correct data, and we will take care of the rest.

III. Erasure

You can also request the erasure of your data.

If erasure is not possible due to other legal provisions, the data will be blocked so that it is only available for that legal purpose.

IV. Restriction

You can also request a restriction on the processing of your data.

While we review your rights, you can request a restriction on the processing.

V. Transfer

You also have the right to request the transfer of your data in the form of a digital copy, if you have consented to the data processing or if it is based on a contract between us.

If you request the transfer of the data you have provided to us, we will make it available to you in a portable format.

VI. Objection

You have the right to object to the processing of your data. If you object, we will check whether there are compelling reasons for the processing on our part. If not, we will no longer process the data. In the case of direct advertising, you have an absolute right to object.

VII. Withdrawal

You have the right to withdraw any consent you have given to us by sending a notification to info@finturis.ch. This means that we will no longer continue the data processing that was based on this consent in the future. The legality of the data processing carried out based on your consent until the withdrawal remains unaffected.

If you withdraw your consent, we will stop the data processing based on it.

VIII. Complaint

You also have the right to lodge a complaint with the data protection supervisory authority responsible for us. This right can be exercised at a supervisory authority in the country of your residence, your place of work, or the place of the alleged violation.

You can contact the Federal Data Protection and Information Commissioner (FDPIC) here: www.edoeb.admin.ch/edoeb/de/home/deredoeb/kontakt.html.

C. DATA PROCESSING FOR CONTRACT PERFORMANCE

In this section, we inform you about the processing of your data in connection with the initiation and/or execution of a contract related to insurance matters with us or if you have commissioned us to process your tax declaration. You will learn which categories of data we process for which purposes, and to whom we disclose your data, e.g., to service providers who support us technically or to tax authorities and insurers.

I. Processed Data

To perform our duties, we process your personal data. This includes information that can be linked to your person, such as your name, phone number, address, or email address.
Statistical data that cannot be linked to your person is not considered personal data.

As a tied insurance intermediary, we need to process certain information about you:

Initially, we need your contact details:

• Name, address, birth date, age
• Phone number, email address
• Bank account information

These details are shared with us during your registration.

Additionally, we process the following personal data:

• Marital status
• Occupation and salary
• Special categories of data (e.g., health data)
• Current insurance situation
• Family situation (partner, children)
• Living situation (current and planned)
• Hobbies and interests
• Pets
• Other personal/economic circumstances, pension requirements

We also derive your product interests from this data.

Moreover, we process your insurance data:

• Application data (data related to your application for insurance)
• Contract data for a specific contract (such as insurance policy number, sum insured, duration, premium, risk, investment amounts, loan amounts)
• Claim data (insurance cases, data related to claims or incidents)

These details are shared with us during the application for a retirement product from Liechtenstein Life Assurance AG.

Additionally, we process your tax data:

• Other personal data (e.g., date of birth, religion)
• Tax documents (e.g., tax returns, decrees)
• Income information (e.g., payslips, bookkeeping for self-employed individuals, alimony, securities income, gambling winnings, pensions from AHV and occupational pensions)
• Employment details and professional expenses (e.g., working hours, transportation costs, work-related education costs, and general work-related expenses)
• Vehicle details
• Family details (e.g., marital status, partner, children)
• Health data (e.g., medical costs, health insurance premiums)
• Housing and other real estate (e.g., current and planned, rent or mortgage interest, maintenance costs)
• Other economic circumstances (e.g., contributions to Pillar 3a, bank statements, securities receipts, donation receipts)

You provide these for the processing of your tax declaration.

II. Why Does Finturis Need My Consent?

In certain cases, we may need your consent if we share particularly sensitive personal data with third parties or record conversations. Sensitive data includes, for example, information about your health status. This information is especially necessary when we advise you on insurance products or assist with the processing of claims for health or liability insurance.

We therefore ask for your consent if you choose such a product or if we wish to record conversations for documentation, training, or quality assurance purposes. You may withdraw your consent at any time with effect for the future by notifying info@finturis.ch.

We also require your consent for promotional information, its personalization, and for analyzing the usage behavior of our websites and apps.

All consents are voluntary, and the use of our services is largely possible without them. However, please note that we may not be able to offer certain products if we are not permitted to process your health data.

III. General Information on Data Transmission to Cooperation Partners

1. Insurers

When you apply for insurance with us, we transmit the relevant personal data to Liechtenstein Life Assurance AG.

As a tied intermediary, we transmit information between you and Liechtenstein Life Assurance AG.

2. Service Providers

Part of the data processing may also be carried out by our service providers. In addition to those mentioned in this privacy policy, this includes, in particular, data centers and cloud service providers that store our website and databases, IT service providers (including cloud, software, and hosting providers) that operate and maintain our systems, consulting firms, and service providers to whom we outsource certain tasks. When we pass on data to our service providers, they may only use it for the fulfillment of tasks assigned by us.

3. Government, Legal, and Judicial Inquiries, and Other Third Parties

Furthermore, data may be transmitted in connection with governmental inquiries and requests, court orders, and legal proceedings, if we are commissioned to do so (for example, in tax returns) or if we are in good faith of the view that we are legally required to do so.

We may also disclose data to third parties such as auditors or if we believe it is necessary to detect, prevent, and prosecute fraud, unauthorized use of our product, and other harmful or illegal activities.

In legitimate cases, we may disclose data to authorities or courts.

4. Disclosure of Personal Data Abroad

In principle, when working with service providers and third parties, we only cooperate with companies that process data within Switzerland or the European Economic Area (EEA), particularly Spain, or in countries that guarantee an adequate level of data protection under a decision of the Swiss Federal Council. One of our service providers, to whom we outsource certain tasks, has subcontractors in India. In exceptional cases, your data may be processed in any country in the world.

If your data is processed outside of Switzerland or the EEA in countries without an adequacy decision, we have entered into specific contracts with service providers for processing agreements that include the standard contractual clauses of the European Commission, provided they are not already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exemption. Exceptions may apply in foreign legal proceedings, cases of overriding public interests, or when contract fulfillment requires such disclosure, if you have consented or if it involves data you have made publicly available and have not objected to its processing.

IV. DATA PROCESSING IN CONSULTATION

1. Conclusion of Insurance and Pension Products

Purpose and Use of Processing
As a tied insurance intermediary, we assist you in insurance matters—primarily pension-related matters—with products from Liechtenstein Life Assurance AG. Based on the information we have, we analyze your interests or needs as a customer to recommend suitable products. We use your personal information and insurance data, including details about your insurance contracts or individual insurance cases, to:

• Provide you with reliable and accurate information about your insurance;
• Offer you better or more affordable deals on existing insurance policies;
• Inform you of relevant news or offer you new insurance products that match your needs and are appropriate for your life situation.

Processed Data

• Contact information
• Product interests
• Signature data
• Insurance data
• Payment information
• Potentially health data

Disclosure of Data for This Purpose

Liechtenstein Life Assurance AG processes your data in Switzerland and, depending on the insurance, possibly in Liechtenstein. If, as part of an insurance, it is necessary for your data to be transferred to other countries, we will inform you beforehand.

2. Processing and Submission of the Tax Return (including Customer Portal / “Tax Wallet”)

Purpose and Use of Processing
The data processing serves the purpose of filling out and submitting your tax return. Through our customer portal, you can upload your tax documents into a “Tax Wallet.” This ensures that all potential tax deductions are applied. These documents may also contain particularly sensitive personal data.

To use our service, you may need a Finturis account.

Registration and login occur when using our services (particularly for processing the tax return).

All information relevant for using our website will be stored in your account.

Processed Data

• Account information
• Contact information

If you also upload insurance policies and pension documents, these will be analyzed to provide a price-performance indication, and you may be contacted by us for further consultation. We accompany you through the contract signing process with the insurance, during the contract period, and up to the end of the contract. We leverage the expertise of our employed advisors and sales partners, as well as the latest digital technologies, to offer you the best conditions.

Processed Data

• Contact information
• Tax information
• Insurance data

Disclosure of Data for This Purpose

This data is included in your tax return and, with your prior consent, is forwarded to the relevant tax authority(ies) for the purpose of submitting the tax return. We also utilize the services of Clark Switzerland AG, our sister company, to prepare and submit your tax return.

3. Digital Consultation

Purpose of Processing and Use

For the purpose of efficient and secure consultation and support of our customers in the areas of insurance and tax declarations, we use the service provider Demodesk. As a digital insurance broker, we use Demodesk as a specialized platform for customer meetings, assistance with insurance sign-ups, and the submission of tax declarations. This enables efficient and location-independent customer engagement in line with business requirements.
With the explicit consent of participants, meetings may be recorded for documentation, training, or quality assurance purposes.

Processed Data

• Personal data
• Product interests
• Contact information
• In case of recordings: Audio data of participants (only with explicit consent)
• Usage data

Data Transfer for This Purpose

Demodesk GmbH
Franz-Joseph Straße 9
80801 Munich
Germany

To protect your data, we have concluded a data processing agreement with Salesforce, which ensures the level of protection required by the Swiss Data Protection Act (DSG).

4. Communication

Purpose and Use of Processing

To enable you to contact us via contact form, live chat, or phone and for us to respond to your inquiry, we process your data.

The contact is for the purpose of consultation within the framework of our intermediary activity and processing the tax return.

Processed Data

• Contact data
• Communication content

5. Newsletter

Purpose and Use of Processing

We use these emails to send you information about our products, special offers, discounts, or other relevant news that might be of interest to you.

In these emails, we also embed visible and invisible image elements (as permitted), through which we can determine if and when you opened the email by retrieving it from our servers. This allows us to measure and better understand how you use our offerings and tailor them to your needs. You can block this feature in your email program; most programs are set to do this by default.

Processed Data

• Contact information
• Product interests
• Usage behavior
• IP address

Disclosure of Data for This Purpose

Salesforce Marketing Cloud

SFDC Ireland Limited
1 Central Park Block G
Leopardstown, 18 Dublin
Ireland

6. Website Hosting

Amazon Web Services (Website Host)

Our website is hosted by AWS (Amazon Web Services), an external service provider. The personal data collected on this website is stored on the servers of the host. This data may primarily include IP addresses, contact inquiries, meta and communication data, contract data, contact details, names, website access, and other data generated via a website.

Our host will process your data only to the extent necessary to fulfill its service obligations and follow our instructions regarding this data.

D. DATA PROCESSING ON THE WEBSITE

We use cookies on our websites, which allow your browser or device to be identified. A cookie is a small file sent to your computer or automatically stored by the web browser you use on your computer or mobile device when you visit our website.
We only use essential cookies that are strictly necessary for the operation of the website. These include:

• Session cookies, which are used during a session and deleted after your visit.
• Security cookies, which help ensure the security of our website.
• Preference cookies (e.g., for language selection), which save your preferences to display the website correctly.

These essential cookies are absolutely necessary to ensure the basic functionality of the website.

E. DATA PROCESSING ON SOCIAL MEDIA

We may operate our own presence on social networks and similar third-party platforms. If you communicate with us through such platforms or comment or share content from us, we collect and process the relevant data according to our privacy policy. At the same time, the platforms evaluate your use of our online presence and link this data with other information they hold about you (e.g., regarding your behavior and preferences). These platforms also process this data for their own purposes, primarily for marketing and market research purposes (e.g., to personalize advertising) and to manage their platforms (e.g., what content they show you).

We process this data primarily for communication, marketing (including advertising on these platforms), and market research. Content you publish yourself (e.g., comments on an announcement) may also be shared by us (e.g., in our advertising on the platform or elsewhere). We or the platform operators may also delete or restrict content related to you based on their usage policies (e.g., inappropriate comments).

For further information on how the platform operators process your data, please refer to the privacy notices of the platforms. There, you can also find out in which countries your data is processed, what rights you have (e.g., access, deletion), and how to exercise these rights.

F. DATA RETENTION PERIOD

We process and store your personal data as long as necessary for the fulfillment of our contractual and legal obligations or for the purposes pursued with the processing, e.g., for the entire duration of the business relationship (from initiation, processing, to termination of a contract) and beyond, in accordance with legal retention and documentation requirements. It is possible that personal data may be stored for a period during which claims can be made against our company or as long as we are legally obliged or have legitimate business interests that require such retention (e.g., for evidence and documentation purposes). Once your personal data is no longer required for the above-mentioned purposes, it will generally be deleted or anonymized, if possible.

G. FINAL PROVISIONS

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