The details provided below are intended to give you an overview of the processing of personal data by Albin Kistler AG and of your rights based on the applicable provisions of data protection law.
The designated person responsible for data protection at Albin Kistler AG can be contacted at the above postal address, by e-mail at datenschutz @ albinkistler.ch or by telephone on +41 44 224 60 24.
Personal data and processing
Personal data refers to any information relating to a specific or identifiable natural person, such as name, address, telephone number, email address, date of birth, etc. (“personal data”).
Any handling of personal data, regardless of the means and methods used, in particular the collection, procurement, storage, use, disclosure, archiving or erasure of data, is considered to constitute processing (“processing” or “processed”).
Personal data used
You or the persons concerned provide some of your personal data to Albin Kistler AG yourself by making it available to us, by using the services of Albin Kistler AG or by contacting us by e-mail or telephone. This includes, for example, name, contact details, date of birth, professional position, etc. Albin Kistler AG may also collect personal data itself, for example, if you or the company you work for use services provided by Albin Kistler AG or visit our website (see section 10). We also process personal data which Albin Kistler AG receives from job applicants. Data is also processed in connection with the requirements of the Swiss Anti-Money Laundering Act and its associated ordinances and guidelines and with other requirements that Albin Kistler AG must comply with, for example due to legal requirements or as a consequence of its status as an institution supervised by the Swiss Financial Market Supervisory Authority (FINMA) (e.g. FINMA circulars). If necessary, we also obtain detailed information that permits an evaluation of your financial situation and an assessment of your risk capacity and risk tolerance, for example regarding your professional or family circumstances in connection with your financial outgoings, salary, assets, etc. In addition to data that Albin Kistler AG receives directly from you, it also obtains and processes data about you from publicly accessible sources (e.g. the internet, lists of debtors, commercial registers, the press, etc.).
In particular, the following personal data are processed:
- Personal details (name, address and other contact details such as telephone number, mobile number, e-mail address, date of birth, place of birth and nationality)
- Identification and authentication data (e.g. identity document data)
- Mandate data (e.g. wealth management mandate or client number)
- Data from the fulfilment of contractual obligations (e.g. reports, statistics and evaluations from earlier years)
- Information about your financial situation (e.g. information about the origin of assets)
- Documentation data (e.g. recordings of conversations or telephone calls with you)
- User behaviour on our website (including our digital customer portal)
- Electronic data (e.g. IP address)
Purposes for which Albin Kistler AG uses your data
The purposes we have stated also constitute the legal basis for the processing of personal data by Albin Kistler AG where such a legal basis is required under the applicable provisions of data protection law.
To meet our obligations under a wealth management mandate
Processing of your personal data enables Albin Kistler AG to provide the services contractually agreed with you. Your personal data is used to analyse your needs, to carry out wealth management and client service activities, to enable use of the digital client portal (including the exchange of information and documentation via the portal) and to execute wealth management transactions.
Within the scope of your consent
If you have consented to a specific use of your personal data, Albin Kistler AG will use it within the scope of the consent you have given (e.g. for newsletters or cookies).
To balance and weigh up interests
To safeguard its own legitimate interests or the legitimate interests of third parties, Albin Kistler AG also processes personal data for the following purposes:
- Checking and optimising processes for analysing needs
- Providing and improving our offering, services and website
- Managing risk
- Enforcing legal claims and mounting a defence in the event of any disputes
- Preventing and investigating criminal offences
On the basis of legal requirements or in the public interest
Albin Kistler AG is subject to a number of legal obligations (e.g. Swiss Collective Investment Schemes Act, Swiss Anti-Money Laundering Act, FINMA ordinances and circulars, tax laws, etc.), supervisory requirements and related disclosure obligations. Personal data are also processed to prevent fraud and money laundering.
Service providers’ access to your personal data and processing location
Albin Kistler AG also discloses personal data to third parties as part of its business activities and for the purposes mentioned above, and to the extent it deems appropriate, whether because they process data for Albin Kistler AG (e.g. IT providers) or because they use the data on behalf of the customer (e.g. custodian bank). In this context, your personal data will be stored in Switzerland.
Retention period for your personal data
Albin Kistler processes your personal data for as long as this is required to meet contractual and legal obligations, particularly in the course of a wealth management mandate.
To meet legal retention obligations as well as any obligations to provide information-, personal data is also stored beyond the point in time at which contractually defined services (e.g. in the context of a wealth management mandate) are provided to you. This approach serves the purpose, among other things, of documenting the correct action of Albin Kistler AG in accordance with contractual, supervisory and legal requirements and proving this if required.
Your data privacy rights
Depending on the provisions of data protection law that are applicable to you at any given time, you may have the following rights:
- Right to access your personal data stored at Albin Kistler AG
- Right to rectification of this data if it is inaccurate
- Right to erasure of the personal data if Albin Kistler AG is not permitted or required to store it
- Right to restriction of processing
- Right to object to processing by Albin Kistler AG
- Right to receive your personal data that you have provided to Albin Kistler AG in a generally available, machine-readable and commonly used format
- Right to lodge a complaint with the competent data protection supervisory authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC)
Albin Kistler AG may enforce the legally prescribed restrictions on your rights as a data subject, for example, if it is obliged to retain or process certain personal data, has an overriding interest in doing so or needs it to enforce claims.
Personal data required on an ongoing basis for business relationships
Albin Kistler AG needs from you such personal data as is required to establish and conduct a business relationship, in particular a wealth management mandate, and to meet the associated contractual and legal obligations. Without this personal data, Albin Kistler AG is unable to conclude or execute a management mandate with you.
In particular, Albin Kistler AG is obliged under the provisions to combat money laundering and the financing of terrorism to identify you by means of your identity document before establishing a business relationship and in so doing to collect and establish your address, nationality, name, place of birth, date of birth and identity document data. To enable Albin Kistler AG to comply with these provisions, you are obliged to make the necessary information available. If this data should change in the course of the business relationship, you are obliged to notify Albin Kistler AG of this. If you do not make the required information available, it will not be possible to establish or continue a business relationship with you.
Albin Kistler AG protects personal data by taking appropriate measures against loss, misuse, unauthorised access, disclosure, alteration or destruction and in accordance with its contractually agreed undertaking of confidentiality. We employ appropriate technical and organisational measures for this purpose. However, Albin Kistler AG cannot guarantee that data will be absolutely secure.
Data processing as a result of use of the website
When you use the public website and/or the digital customer portal of Albin Kistler AG (referred to as the “website”), general information is automatically recorded (such as the date of your visit, time zone, web browser type and settings, version and language, your IP address, the MAC address of the device, the operating system used, the content accessed and the domain name of your internet service provider). Albin Kistler AG uses this data for administrative purposes, to improve its products and services and to ensure the functionality of the website. This data is also required to ensure the correct provision and optimisation of the website content, the long-term functionality of our IT systems and the website and to provide the law enforcement authorities with the information they need for criminal prosecution in the event of a cyber attack.
The website uses SSL encryption for security reasons and to protect the transmission of confidential data. You can recognise encrypted connection because the browser address line is prefaced with “https://” rather than “http://”.
Server log files
Der Provider dieser Webseite erhebt und speichert automatisch Informationen in so genannten "Server-Log Files", die Ihr Browser automatisch an die Albin Kistler AG übermittelt. Dabei werden insbesondere die unter Ziff. 10 eingangs aufgezählten Informationen übermittelt.
Cookies are small files that are stored on your computer or mobile device when you use the Albin Kistler AG website.
b)Essential and non-essential cookiesEssential cookies are files that are sent to the browser on your computer’s hard drive so that we can provide you with certain functions.
c)Session cookies and permanent cookies
Session cookies are deleted automatically when you leave our website.
We also use permanent cookies that remain stored on your computer or mobile device after the end of your browser session until you delete them. The next time you visit our website, your preferred inputs and settings are recognised automatically. Depending on their type, these cookies remain stored on your computer or mobile device for between one month and ten years and are disabled automatically once the specified time has elapsed. They help to make our website more user-friendly, effective and secure. For example, these cookies allow the website to show you information tailored specifically to your interests.
d)Enabling, disabling and deleting cookies
All web browsers allow users to enable, disable or delete cookies by configuring their browser settings or options accordingly. If cookies are fully or partially disabled or deleted, the full functionality of the website may no longer be available.
e)Cookies and personal data
Our cookies typically do not store any personal data. However, personal data from you that we or third-party providers commissioned by us may store (e.g. if you have a user account with us or these providers) can be linked to the technical data or the information stored in cookies and derived from them, and therefore possibly associated with your identity.
Web analytics tools
We use Google Analytics or similar services on our public website. These services are provided by third parties which may be located in Switzerland or in another country. In the case of Google Analytics, the service provider Google is based in Ireland. Google Ireland uses Google LLC (based in the USA) as a data processor (both “Google”). With these services, we can measure and evaluate the usage of the website (non-personalised). This also involves the use of permanent cookies, which are placed by the service provider. Although we can assume that the information we share with Google is not considered personal data by Google, it is possible that it might use this data, in conjunction with the data which it collects, to draw conclusions about the identity of the visitors and to link this information to their respective Google accounts. We adopt a similar approach when utilising equivalent service providers. If you have registered with the service provider yourself, it may be able to identify you as well. The service provider will then take responsibility and process your personal data in accordance with its data protection policy. The service provider only tells us how our website is used (no personal information about you).
We use Matomo on our digital customer portal. The data handled by this service does not leave the Albin Kistler infrastructure.
To deliver content accurately, we may use script libraries and font libraries on our website (such as Google Webfonts). Calling a script library or font library automatically triggers a connection to the library operator. It is possible that the operator of the library may collect data on this connection.
We use an interface to geo-specific data from Google to display location information visually. Google records and uses data on the use of the Maps function. Information on how Google uses data can be found in its data privacy information.
Links to other websites
The website contains links to other websites. Albin Kistler AG has no control over whether the operators of these websites comply with applicable data protection requirements. Albin Kistler AG accepts no responsibility or liability whatsoever for the third-party websites accessible via the links.
If you have any questions regarding the handling of your data, please do not hesitate to contact your client advisor or Albin Kistler AG’s Data Protection Officer (contact details provided above).