Union Swiss Brokers Holding AG Privacy Policy
Last updated on 24 November 2023
In this Privacy Policy, we, Union Swiss Brokers Holding AG (hereinafter referred to as “Union Swiss Brokers”, “we” or “us”), explain how we collect and process personal data. This is not an exhaustive description; other privacy policies may govern specific situations. Personal data include all information relating to an identified or identifiable person.
If you provide us with personal data of other persons (family members, colleagues, etc.), please ensure that these persons are aware of this Privacy Policy and only share their personal data with us if you are authorised to do so and if the personal data are correct.
This Privacy Policy is designed to meet the requirements of the Swiss Data Protection Act (DPA) and the revised Swiss Data Protection Act (revDPA). Whether and to what extent these laws are applicable depends on the specific case.
1. Data protection office
The entity responsible for the data processing described here is Union Swiss Brokers, Lyssachstrasse 9, 3400 Burgdorf, Switzerland. If you have any data protection concerns, you can contact us at the following e-mail address: burgdorf@unionsb.ch.
2. Collection and processing of personal data
We primarily process personal data (contact details of data subjects, such as their name, place of residence and e-mail address, preference data, etc.) that we receive in the context of our business relationship with our clients and other business partners or that we collect from users of our websites, apps and other services.
To the extent permitted, we also obtain certain data from publicly accessible sources (debt enforcement registers, land registers, commercial registers, the press, Internet, etc.) or receive such data from other companies, authorities and third parties (such as address providers). In addition to the data you provide directly to us, the categories of personal data we receive from third parties about you include, in particular: information from public registers; information we obtain in connection with administrative and judicial proceedings; information related to your professional functions and activities (so that we can, for example, conclude and execute transactions with your employer); information about you in correspondence and meetings with third parties; credit information (to the extent we conduct transactions with you personally); information about you that we receive from people close to you (family, advisors, legal representatives, etc.), allowing us to conclude or execute contracts with you or involving you (references, your address for deliveries, powers of attorney, compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, distributors and other contractual partners regarding the use or provision of services by you [payments made, purchases made, etc.]); information from media sources and the Internet about you (if relevant in the specific case, in the context of an application, press review, marketing/sales, etc.), your addresses, possible interests and other sociodemographic data (for marketing) and data related to the use of our website (IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location information, etc.).
We also collect personal data outside of the use of our website.
3. Purposes of data processing
We primarily use the personal data we collect to conclude and execute our contracts with our clients and business partners, particularly in the context of consultations in the field of property and personal insurance, the creation of insurance product offers, the conclusion of insurance contracts, business relationships with our clients, the purchase of services from our partner companies in the insurance and pensions sector and to comply with our legal obligations in Switzerland and abroad. If you work for such a client or business partner, your personal data may also be affected in this capacity.
In addition, we process personal data about you and other persons, to the extent permitted and as it appears appropriate to us, for the following purposes, where we (and sometimes third parties) have a legitimate interest corresponding to the purpose:
Providing and developing our offers, services and the websites, apps and other platforms on which we have a presence
Communicating with third parties and processing their requests (applications, media inquiries, etc.)
Reviewing and optimising procedures for needs analyses for the purpose of direct client contact and collecting personal data from publicly accessible sources for the purpose of client acquisition
Advertising and marketing (including conducting events), to the extent that you have consented to the use of your data for this purpose or have not objected (if we send you advertising as an existing client, you can object at any time, and we will then place you on a non-mailing list to prevent further advertising communications)
Market and opinion research, media monitoring
Assertion of legal claims and defence in connection with legal disputes and administrative proceedings
Prevention and investigation of crimes and other misconduct (conducting internal investigations, data analyses to combat fraud, etc.)
Maintaining our operations, particularly IT, our websites, apps and other platforms
Video surveillance to enforce property rights and other measures for IT, building and facility security, as well as the protection of our employees, other individuals and assets belonging to or entrusted to us (access controls, visitor lists, network and mail scanners, telephone recordings, etc.)
The purchase and sale of business units, companies or parts of companies and other corporate transactions and the associated transfer of personal data, as well as business management measures and, where necessary, to comply with legal and regulatory obligations and the internal policies of Union Swiss Brokers
To the extent that you have given us your consent to the processing your personal data for specific purposes (for example, when you subscribe to our newsletter or for a background check), we process your personal data within the scope of and based on this consent, unless we have another legal basis and require it. Consent given can be revoked at any time; however, this does not affect data processing that has already taken place.
4. Newsletter
You have the option of subscribing to our newsletter. For registration purposes, we require your e-mail address to verify whether you are the owner of the e-mail address in question and agree to receive the newsletter. We do so using a “double opt-in procedure”. Your data will be used exclusively for the purpose of sending our newsletter. Your subscription to our newsletter and the associated consent to store your data can be revoked at any time via the “Unsubscribe” link in the newsletter.
We use the online service Hubspot to send our newsletters. To receive our newsletter, you must have a valid e-mail address; this is transmitted to Hubspot during the subscription process along with your title, first name, last name and IP address. Newsletters also record on a personalised basis whether a newsletter has been opened and which links have been clicked. These data allow us to check the quality of and make improvements to our newsletter.
For more information on data protection at Hubspot, please refer to the following link: https://legal.hubspot.com/privacy-policy.
5. Cookies, tracking and other technologies related to the use of our website
We generally use cookies and similar technologies on our websites and apps that allow us to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored by the web browser you use on your computer or mobile device when you visit our website or install our app. When you revisit our website or use our app, we can recognise you, even if we do not know who you are.
In addition to cookies that are used only during a session and deleted after your visit to our website (session cookies), cookies can also be used to store user settings and other information for a certain period (e.g. two years) (permanent cookies). However, you can configure your browser to reject cookies, store them only for a session or delete them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save your user settings (e.g. language, auto-login), so that we can better understand how you use our offering and content and so that we can display tailored offers and advertising to you (this may also occur on websites owned by other companies; however, they will not know who you are unless we know it ourselves, as they only see that the same user is on their website who was also on a specific page of ours). Some cookies are set by us, while others are set by contractual partners with whom we collaborate. If you block cookies, certain functionalities (such as language selection, form submissions, uploads, etc.) may no longer work.
We also integrate visible and invisible image elements into our newsletters and other marketing e-mails, to the extent permitted, the retrieval of which from our servers allows us to determine whether and when you have opened the e-mail. This helps us measure and better understand how you use our products and services so that we can tailor them to you. You can block this in your e-mail program; most are preset to do so.
We sometimes use Google Analytics or similar services on our websites. These services are provided by third parties, which may be located in any country worldwide. In the case of Google Analytics, this is Google Ireland (based in Ireland), which relies on Google LLC (based in the USA) as a subcontractor (both hereinafter referred to as “Google”), www.google.com, allowing us to measure and evaluate website usage (non-personal). Permanent cookies, which are placed by the service provider, are also used for this purpose. We have configured the service so that visitor IP addresses are shortened by Google in Europe before being transferred to the USA, preventing them from being traced. We have disabled the “data sharing” and “signals” settings. Although we assume that the information we share with Google does not constitute personal data for Google, it is possible that Google may draw conclusions about the identity of visitors based on these data, create personal profiles and link these data to their Google accounts. If you have registered with the service provider, the provider also knows you. The processing of your personal data by the service provider is then the responsibility of the provider in accordance with its data protection policies. The provider only informs us about how our website is used (without any personal information about you).
Union Swiss Brokers uses Hubspot CRM on its website. The provider is Hubspot Inc., 25 Street, Cambridge, MA 02141, USA (hereinafter referred to as “Hubspot”). Each time the Union Swiss Brokers platform, which includes the Hubspot function, is accessed, a connection to Hubspot’s servers is established.
Hubspot is a marketing automation software that allows Union Swiss Brokers to analyse the use of the platforms. Hubspot enables Union Swiss Brokers to manage existing and potential users and their contacts. Through Hubspot, Union Swiss Brokers can record, sort and analyse user interactions across various channels (e-mail, social media, phone). The collected personal data may be evaluated and used for communication with the potential user or for marketing purposes. Union Swiss Brokers has a legitimate interest in ensuring the most efficient user management and communication experience possible.
During your first visit to our website, you will be informed about the storage and processing of personal data and asked to accept this condition. If you refuse, your information will not be collected when you visit our website. A single cookie will be used in your browser to remember that you do not want to be tracked.
We also use plug-ins from social networks such as Facebook and Instagram on our websites. This is visible to you (typically through corresponding icons). We have configured these elements to be deactivated 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 where you are, and they may use this information for their own purposes. The processing of your personal data is then the responsibility of this operator in accordance with their data protection policies. We do not receive any information about you from them.
6. Data disclosure and data transfer abroad
As part of our business activities and for the purposes mentioned in section 3, we also disclose data to third parties, to the extent permitted and as deemed appropriate, either because they process these data on our behalf or because they wish to use these data for their own purposes. The recipients include, in particular:
Our service providers (banks, insurance companies, etc.), including subcontractors (IT providers)
Dealers, suppliers, subcontractors and other business partners
Clients
Domestic and foreign authorities, agencies and courts
The media
The public, including visitors to websites and social media
Competitors, industry organisations, associations, organisations and other entities
Parties acquiring or parties interested in acquiring business units, companies or other parts of Union Swiss Brokers
Other parties involved in potential or ongoing legal proceedings
These recipients are partly located in Switzerland but may be based anywhere in the world. In particular, you should expect your data to be transferred to all countries in Europe and the USA, where the service providers we use (such as Microsoft) are based.
Clarification on data recipients in the USA and protection measures despite the lack of an adequate level of data protection
We would like to inform you that certain personal data may be transferred to recipients in the USA. It should be noted that the USA does not necessarily guarantee a level of data protection equivalent to that of Switzerland. To ensure adequate protection of your personal data, we have implemented certain measures with our data recipients in the USA. These protection measures include:
Standard contractual clauses: standard contractual clauses have been implemented to ensure that the transfer of your data complies with data protection standards.
Data Privacy Framework: if applicable, data transfers are carried out in accordance with the principles of the Privacy Shield agreement with the USA, insofar as this is legally binding.
Additional security measures: in addition to standard contractual clauses and other legal mechanisms, we have implemented appropriate technical and organisational measures to ensure the effective protection of your data.
Despite these protection measures, we would like to point out that the lack of an adequate level of data protection in the USA entails certain risks. We therefore recommend that you read our data protection policies carefully and contact us if you have any questions or concerns.
We are committed to ensuring the security of your personal data and will continue to closely monitor developments in data protection law in order to implement additional protection measures if necessary.
7. Duration of storage of personal data
We process and store your personal data for as long as necessary to fulfil our contractual and legal obligations or for other purposes pursued by the processing, for example for the duration of the entire business relationship (from initiation and execution to termination of a contract) and beyond in accordance with legal retention and documentation obligations. It is possible that personal data will be retained for the period during which claims can be made against our company and to the extent that we are legally required to do so or that legitimate business interests necessitate it (e.g. for evidence and documentation purposes). As soon as your personal data are no longer required for the aforementioned purposes, they will generally be deleted or anonymised as far as possible. For operational data (e.g. system logs), shorter retention periods of 12 months or less generally apply.
8. Data security
We take appropriate technical and organisational security measures to protect your personal data from unauthorised access and misuse, such as issuing directives, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymisation and various other controls.
9. Profiling and automated decision-making
We process your personal data on a partially automated basis to assess certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about our products. We use evaluation tools that enable us to communicate and advertise in a way that meets your needs, including market and opinion research.
For the establishment and execution of the business relationship and for other purposes, we generally do not use fully automated individual decision-making (as regulated in Article 21 DPA). Should we apply such procedures in specific cases, we will inform you separately, insofar as this is legally required, and explain your associated rights.
10.Rights of the data subject
Under the DPA, you have the right to information regarding the processing of your data and the right to data portability regarding your personal data. If applicable, you also have the right to request the correction, deletion and restriction of the processing of your data. In addition, you may object at any time to the processing of your personal data, particularly for advertising and marketing purposes. However, please note that we reserve the right to invoke the legally provided restrictions, in particular when we are required to retain or process certain data, when we have an overriding interest in doing so (to the extent we are entitled to claim it) or when we need the data to assert legal claims. If any costs apply to you, we will inform you in advance. Please note that exercising these rights may conflict with contractual agreements and may result in consequences such as early termination of the contract or additional costs. In such a case, we will inform you in advance unless this is already provided for in the contract.
Exercising such rights generally requires that you clearly prove your identity (e.g. by providing a copy of your ID if your identity is not otherwise clear or cannot be verified). To exercise your rights, you can contact us at the address provided in section 1.
Each data subject also has the right to assert their claims in court or to lodge a complaint with the competent data protection authority. The competent authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
11.Amendments
We may amend this Privacy Policy at any time without prior notice. The version currently published on our website applies. To the extent that this Privacy Policy forms part of an agreement with you, we will inform you of any amendments by e-mail or by any other appropriate means in the event of any updates.
