Data Protection
Privacy Policy
This data protection declaration provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name acisuisse.ch. In particular, we provide information on what personal data we process, how and where. We also provide information on the rights of individuals whose data we process.
We may publish additional data protection declarations or other information on data protection for individual or additional activities and operations.
1. Contact addresses
The responsible party in terms of data protection law is:
ACI Suisse – The Financial Market Association Switzerland
c/o Sabine Kipfer
Bungertweg 2
8700 KĂĽsnacht
Switzerland
In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.
2. Terms and legal basis
2.1 Terms
Data subject: Natural person whose personal data we process.
Personal data: All information relating to an identified or identifiable natural person.
Sensitive personal data: Data relating to trade union, political, religious, or philosophical views and activities, data concerning health, privacy, or membership of an ethnic or racial group, genetic data, biometric data. views and activities, data on health, privacy, or ethnicity or race, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures. Processing: Any handling of personal data, regardless of the means and procedures used.
Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, distributing, linking, destroying, and using personal data.
2.2 Legal basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
3. Type, scope, and purpose of personal data processing
We process personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed can be divided into the following categories: browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. Personal data may also constitute sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permissible.
We process personal data, where necessary, with the consent of the persons concerned. In many cases, we can process personal data without consent, for example to fulfill legal obligations We may also ask data subjects for their consent if their consent is not required.
We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data in particular in accordance with statutory retention and limitation periods.
4. Disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.
We may disclose personal data in the course of our activities activities and operations, in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers , cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications communication companies, insurance companies, and payment service providers.
5. CommuÂniÂcaÂtion
We process personal data in order to communicate with individuals, authorities, organizations, and companies. organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or using similar tools.
Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals themselves. In particular, they must ensure that such data is accurate and may be transmitted.
6. Data security
We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, executability, and integrity of the processed personal data, but without being able to guarantee absolute data security.
Access to our website and our other digital presence is provided using transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS) . Most browsers warn users against visiting websites without Transport Layer Security encryption.
Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the processing of personal data by secret services, police departments, and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.
7. Personal data abroad
We process personal data in principle in Switzerland. However, we may also disclose or export personal data to other countries, in particular for the purpose of processing it there or having it processed there.
We may disclose personal data to all countries around the world and elsewhere in the universe, provided that the law there ensures adequate data protection in accordance with decision of the Swiss Federal Council guarantees adequate data protection.
We may disclose personal data in countries whose laws do not guarantee adequate data protection, provided that adequate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other suitable guarantees. In exceptional cases, we may export personal data to countries without adequate or suitable data protection. data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent We will be happy to provide data subjects with information about any guarantees upon request or provide a copy of the guarantees.
8. Rights of data subjects
8.1 Data protection claims
We grant data subjects all claims in accordance with applicable law. Data subjects have the following rights in particular:
- Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage storage, any disclosure or export of data to other countries, and the origin of the personal data.
- Correction and restriction: Data subjects can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data. complete incomplete data, and have the processing of their data restricted.
- Opportunity to express one's own point of view and human review: Data subjects may object to decisions based solely on automated processing of personal data that have legal consequences for them or significantly affect them. processing of personal data and have legal consequences for them or significantly affect them (automated individual decisions), they can express their own point of view and request a review by a human being.
- Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects can request the disclosure of personal data the disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict, or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any prerequisites that must be met in order to exercise their data protection rights. . For example, we may refuse to provide information in whole or in part on the grounds of confidentiality obligations, overriding interests, or the protection of other persons. We may also refuse to delete personal data in whole or in part, for example with reference to statutory retention obligations.
We may charge a fee for exercising these rights in exceptional cases. We will inform the persons concerned in advance of any costs that may be incurred.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
8.2 Legal protection
Data subjects have the right to enforce their data protection claims through legal action or to file a complaint with a data protection supervisory authority. .
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
9. Use of the website
9.1 Cookies
We may use cookies. Cookies—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data that are stored in the browser. Such stored data is not necessarily limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable, in particular, a browser to be recognized the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated, restricted, or deleted at any time in the browser settings. Browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request explicit consent to the use of cookies, at least to the extent required by applicable law.
For cookies used to measure success and reach or for advertising, a general opt-out is available for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
9.2 Logging
We may log at least the following information for each access to our website and other digital presence, provided that this information is determined or transmitted to our digital infrastructure as standard during such access: Date and time, including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed, status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. This information is necessary in order to provide our digital presence in a permanent, user-friendly, and reliable manner. The information is also necessary to ensure data security, including by third parties or with the help of third parties.
9.3 Tracking pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to collect at least the same information as is logged in log files.
10. NotiÂfiÂcaÂtions and commuÂniÂcaÂtions
10.1 Success and reach measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels may also collect personal data on the use of notifications and communications. We require this statistical collection of usage data for success and reach measurement in order to send notifications and communications effectively and in a user-friendly, permanent, secure, and reliable manner based on the needs and reading habits of the recipients. user-friendly, secure, and reliable.
10.2 Consent and objection
You must always to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including IP address and timestamps for evidence and security reasons.
You can always object to receiving notifications and communications such as newsletters at any time. By doing so, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.
10.3 Service providers for notiÂfiÂcaÂtions and commuÂniÂcaÂtions
We send notifications and communications with the help of specialized service providers.
In particular, we use:
- Brevo: Establishing and maintaining relationships with customers and users, in particular via email and instant messaging; provider: Sendinblue GmbH (Germany); information on data protection: Data protection declaration, “Data protection and data security,” and “Security and data protection.”
11. Social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities. In connection with such platforms, personal data may also be processed outside Switzerland.
The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-Ă -vis the respective platform, including, for example, the right to information.
12. Third-party services
We use the services of specialized third parties to enable us to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services enable us, among other things, to embed functions and content in our website. When embedding such content, the services used collect the IP addresses of users, at least temporarily, for technical reasons.
For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to be able to offer the respective service.
In particular, we use:
- Google services: Providers: Google LLC (USA)/Google Ireland Limited (Ireland), in some cases for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Data protection and security principles”, “More information on how Google uses personal data,”, Privacy Policy, ”Google is committed to complying with applicable data protection laws", “Guide to data protection in Google products”, “How we use data from websites or apps on which our services are used,”, Cookie Policy, “Advertising you can control” (settings for personalized advertising).
- Microsoft services: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland, and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; General information on data protection: “Data protection at Microsoft”, “Data Protection and Privacy”, Data Protection & shy;erklärung, “Data and dataÂprotectionÂsettings”.
12.1 Digital infraÂstrucÂture
We use services from specialized third parties in order to be able to utilize the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
- Hostpoint: Hosting; provider: Hostpoint AG (Switzerland); information on data protection: Privacy policy.
12.2 Social media functions and social media content
We use third-party services and plugins to embed functions and content from social media platforms and to enable content to be shared on social media platforms and by other means.
In particular, we use:
- LinkedIn Consumer Solutions Platform: Embedding LinkedIn features and content, for example with plugins such as the ”Share Plugin"; provider: Microsoft; LinkedIn-specific information: “Privacy”, Privacy Policy, Cookie Policy, Cookie Management & Opting Out of Email and SMS Communications from LinkedIn, Opting Out of Interest-Based Advertising.
12.3 Maps
We use third-party services to embed maps in our website.
In particular, we use:
- Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific information: ”How Google uses location information".
12.4 Digital content
We use services from specialized third parties to integrate digital content into our website. Digital content includes, in particular, image and video material, music, and podcasts.
In particular, we use:
- YouTube: Video platform; Provider: Google; YouTube-specific information: “Data Protection and Security Center”, “My data on YouTube”.
12.5 Documents
We use third-party services to embed documents in our website. Such documents may include PDF files, presentations, tables, and text documents. This allows us not only to view such documents, but also to edit or comment on them.
In particular, we use:
- Microsoft 365: Text documents, presentations, and tables; provider: Microsoft; Microsoft 365-specific information: “Privacy and security with Microsoft 365”.
13. Extensions for the website
We use extensions for our website to enable additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure.
In particular, we use:
- Cloudflare Turnstile: Spam protection (distinguishing between desired content from humans and unwanted content from bots and spam); Cloudflare Inc. (USA); data protection information: “Turnstiles, a user- and data-friendly alternative to CAPTCHA”, “Data protection”, Data protection declaration.
14. Success and reach measurement
We try to measure the success and reach of our activities and operations. In this context, we can also measure the impact of third-party references or check how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content, or make improvements.
In most cases, the IP addresses of individual users are recorded for success and reach measurement. In this case, IP addresses are always shortened (“IP masking”) in order to comply with the principle of data minimization through appropriate pseudonymization.
Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.
15. Real Cookie Banner
We use the consent tool “Real Cookie Banner” to manage the cookies and similar technologies (tracking pixels, web beacons, etc.) we use and the related consents. Details on how “Real Cookie Banner” works can be found at https://devowl.io/knowledge-base/real-cookie-banner-data-processing/.
The legal basis for the processing of personal data in this context is Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide personal data. If you do not provide personal data, we cannot manage your consents.
16. Final notes on the data protection declaration
We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.