The protection of your personal data is important to the BNP Paribas Group, which has adopted strong principles in that respect for the entire Group. As you may know, the entry into force on May 25, 2018, of the General Data Protection Regulation (EU 2016/679 “GDPR”) imposes higher standards of personal data protection which have an extra-territorial effect. The Swiss Data Protection Act is being revised and will contain similar provisions. In this regard, BNP Paribas (Suisse) SA (“we” or “us”) is adapting its policies concerning the handling and use of your personal data. We therefore request that you read this Data Protection Notice which provides you with detailed information relating to the protection of your personal data and to bring this Data Protection Notice to the attention of any individual whose information you provide to us. Furthermore, some of the information you provide us with may be protected by Banking Secrecy statutes which prohibit the disclosure of your information to third parties, unless otherwise authorised by you. For the avoidance of doubt, the present Notice does not constitute a waiver of Banking Secrecy. Its purpose is to inform you on the manner in which your information is handled and collected within the contractual framework agreed with the Bank. In addition, this Notice is to inform you on the data collected by us, the reasons we collect and (may) share it and how long we keep it. In connection thereto, we draw your attention to your rights and how they may be exercised.
1. WHICH PERSONAL DATA DO WE USE ABOUT YOU?
We collect and use your personal data provided you have given your consent to this, for advertising use, i.e. processing that serves the preparation, implementation or follow-up of advertising measures, and specifically to provide marketing services, such as the newsletter, printed articles, as well as personal data that is required for website functions. We may collect various types of personal data about you, including:
- identification information (e.g. name, gender, IP address);
- contact information (e.g. postal address and e-mail address, phone number);
- data relating to your habits and preferences;
- data from your interactions with us: our branches (contact reports), our internet websites, our apps, our social media pages, meetings, calls, chats, emails, interviews, phone conversations. We never ask for personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data, data concerning your sexual orientation or data relating to criminal convictions and offences (“Criminal Record Data”) unless it is required through a legal obligation. The data we use about you may be directly provided by you or obtained from service providers in order to verify or enrich our databases.
2. WHY AND ON WHICH BASIS DO WE USE YOUR PERSONAL DATA?
a. To fulfil our legitimate interest We use your personal data in order to deploy and develop our products or services, to improve our risk management and to defend our legal rights, including analysing your habits and preferences in the various channels (emails or messages, visits to our website, etc.) or processing your personal data for establishing exercise or defence of legal claims.
b. To respect your choice if we request your consent for specific processing In some cases we require your consent to process your data, for example:
- To share your personal data with third parties, for example for advertising purposes, to provide services or we require your consent to use your data for specific advertising purposes.
- If we need to carry out further processing for purposes other than those below in section 3, we will inform you and, where necessary, obtain your consent.
3. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In order to fulfill the aforementioned purposes, but subject to applicable law relating to information sharing, we only disclose your personal data to:
- Service providers which perform services on our behalf;
- Financial, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law.
4. DOES PROFILING TAKE PLACE?
We partly process your data in an automated manner with the objective to evaluate certain personal aspects (profiling). Profiling is used by us, for instance, to be capable to purposefully informing you about products and providing you with advice, we use evaluation instruments. These allow for a demand-focused communication and advertising, including market research and opinion research.
5. TRANSFERS OF PERSONAL DATA OUTSIDE SWITZERLAND OR THE EEA
In some circumstances, we may transfer your data into another country. In case of international transfers to a country for which the competent Authority has recognised that it provides an adequate level of data protection, your personal data may be transferred on this basis. For transfers to a country where the level of personal data protection has not been recognised as “adequate” by the competent Authority, we will either rely on derogation applicable to the specific situation or implement standard contractual clauses approved by the competent Authority to ensure the protection of your personal data. To obtain a copy of these safeguards or details on where they are available, you can send a written request to us as set out in section 9. There may be other notices or policies detailing how we process your personal data applicable in certain territories outside of the European Economic Area (EEA). In the event that the provisions of such notices or policies conflict with those within this Data Protection Notice, the former notices or policies shall take precedence.
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We only retain your personal data as long and as far as required for the above mentioned services. Afterwards, we will immediately delete your personal data, unless, its further processing is required by statutory provisions or for safeguarding evidence within the framework of the statutes of limitations.
7. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
Depending on the data protection laws which apply to your situation, you have the following rights:
- To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
- To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
- To erase: you can require the deletion of your personal data, to the extent permitted by law.
- To restrict: you can request the restriction of the processing of your personal data.
- To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
- To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
- To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party. If you require further information, or if you wish to exercise the rights listed above, please send an e-mail to the address set out in section 9. In accordance with applicable regulation, in addition to your rights above you are also entitled to lodge a complaint with the competent supervisory authority.
8. HOW CAN YOU KEEP UP WITH CHANGES TO THIS DATA PROTECTION NOTICE?
In a world of technological change, we may need to update this Data Protection Notice from time to time. We invite you to review the latest version of this notice online (www.bnpparibasmarkets.ch) and we will inform you of any material changes through our website or through our other usual communication channels.
9. HOW TO CONTACT US?
If you have any questions relating to our use of your personal data under this Data Protection Notice, or if you would like a copy of this Data Protection Notice in your native language, please contact our Data Protection Officer: firstname.lastname@example.org. Please include a scan/copy of your identity card for identification purpose. If you wish to learn more about Privacy and Security, please refer to the concerned policies on our website www.bnpparibas.ch.
- collect information on an anonymous basis to gain better insight into the browsing behaviour of visitors to our website;
- draw up statistical reports about activities on the website, e.g. the number of visitors and the web pages they view;
- temporarily store information that you enter in tools, such as calculators or demonstrations on our website;
We use two types of cookies. Session cookies are temporary and are used to identify surfing behaviour of a user during a specific visit. They are deleted as soon as you close your browser. Persistent cookies store your personal preferences, such as a preferred language on websites that are offered in several languages, so that on a subsequent visit you immediately obtain the desired variant on your screen. Persistent cookies are stored on your computer until they naturally expire or you delete them. Cookies remember questions you have previously been asked, e.g. a request to participate in an online survey. A persistent cookie prevents you being asked to answer the same questions each time you visit the website.
3. Cookies from third parties
We work together with third parties who, on our behalf, investigate the use of our website and the activities on it. In this context, they might place a cookie on your computer. These cookies do not contain any personal data. We also work together with third parties to examine the effectiveness of our advertising and promotions on third-party websites. Such cookies also do not contain any personal data.
4. Accepting or refusing cookies
You can change your cookie settings here: