Data protection statement – Inyova

Below, Inyova AG (hereinafter “Inyova” or “we”) provides you with an overview of how Inyova processes your personal data and what rights you have according to data protection law. What data is processed in each individual case and in what way it is utilised, depends on the services requested or agreed upon. You will be asked to share information with current and future authorised representatives and beneficial owners. These include, for example, beneficiaries in the event of death and authorised signatories.

Controller

The controller is:
Inyova AG
Data Protection Department
Limmatstrasse 123
8005 Zurich
Email: gdpr@inyova.ch

Processing of personal data

Inyova processes personal data that it receives as a result of its business relationship with you. This happens when you contact Inyova, e.g. as a prospective customer, applicant or customer. This is also the case if you are interested in Inyova’s products, sign up for online services or contact Inyova via email, phone or application, and if you use our products and services within the framework of an active business relationship. In all of the above-mentioned cases, Inyova collects, stores, utilises, transfers or deletes personal data.

When necessary for the performance of the service, Inyova also processes personal data that it has permissibly received (e.g. to execute orders, perform contracts or because you have given your consent) from other companies, e.g. Intrum AG, or other third parties (other service providers of Inyova). Furthermore, Inyova processes data that it has permissibly obtained from publicly available sources (e.g. land registers, trade and association registers, the Federal Gazette, press, media, internet) and data it is allowed to process.

In certain cases, Inyova collects personal data from potential clients and prospective customers.

Where required, Inyova also collects personal data from persons who do not have any direct relationship with Inyova and who belong, for instance, to one of the following categories:

  • Family members
  • Co-applicants
  • Legal representatives (proxies)
  • Customers’ beneficiaries
  • Customers’ beneficial owners
  • Shareholders
  • Representatives of legal persons
  • Employees of service providers or business partners

(1) If you enter a contract and use products/services, we may collect, process and store personal data

Inyova processes the following personal data:

  • Identity information: e.g. name and surname, ID or passport number, nationality, date and place of birth, sex, photo, IP address
  • Contact information: address, email address and phone number
  • Tax information: tax ID, tax status
  • Bank, finance and transaction data: e.g bank details (IBAN), money transfers to your account/portfolio, assets, investment profile communicated
  • Information on habits and preferences: IP addresses, information on your use of our products and services with regards to banks, finance and transaction data, information on interactions between you and Inyova (website access, personal meetings, phone calls, chat histories, email communication, interviews)
  • Information on your sustainability preferences: preference for a sustainable business focus (handprint), preference for sustainable business practices (footprint), exclusion criteria, excluded companies (exclusion list), favoured companies (favourites list)
  • Security transactions: information on your knowledge/experience with financial instruments, your risk profile, information on your education and profession (e.g. level of education, occupation, name of your employer, income), financial situation including your capacity to bear financial losses (capital, liabilities, income, e.g. from (self-)employment/business, spending), foreseeable changes in your financial situation (e.g. retirement age, education of children), concrete goals/major concerns in the future (e.g. planned acquisitions, payment of liabilities), marital status and family situation, documentation data (e.g. suitability reports)
  • Interest, currency and liquidity management: information on your knowledge/experience with interest-bearing/currency products/investments, investment behaviour/strategy (amount, frequency, risk profile), occupation, financial situation (capital, liabilities, income, e.g. from (self-)employment/business, spending), foreseeable changes in your financial situation (e.g. retirement age, education of children), concrete goals/major concerns in the future (e.g. planned acquisitions, payment of liabilities), tax information, documentation data (e.g. suitability reports)
  • Customer contact information: further personal data emerged due to the initiation of business and during our business relationship, especially through contact in person, by phone or in writing, initiated by you or us, e.g. information on the contact channel, date, occasion and result, (electronic) copies of correspondence, information on your participation in direct marketing campaigns, as well as information about your interests and wishes that you have communicated to Inyova.
  • Audiovisual data: information from the video identification procedure, recorded calls

Inyova generally does not process personal data about racial or ethnic background, political opinions, religious or ideological beliefs, trade union membership, genetic data, biometric data for clear identification of individuals, data on your sex life, sexual orientation or health data, except where necessary for payment of church tax or when this personal data is identifiable from the copy of your ID that Inyova needs to comply with the money-laundering act.

(2) Visiting our website

If you access Inyova’s website, the browser used on your device/computer automatically sends information to Inyova’s server. This information is temporarily stored in a so-called log file. The following information is recorded automatically and stored until automated deletion:

  • IP address of the requesting computer (or device)
  • Date and time of access
  • Name and URL of the file viewed
  • Website from which you came (referrer URL)
  • Your browser, and possibly your computer’s (or device’s) operating system, as well as the name of your access provider

(3) Supplier data

Inyova collects personal data of its suppliers in connection with their collaboration to ensure a smooth business connection. Inyova collects the data of the contact persons within the organisation, e.g. name, phone number and email address. Inyova also collects bank data to be able to make payments to its suppliers.

(4) Means and ends of digital data processing on our website

  1. Our website
    • Ensuring the establishment of a smooth connection with the website inyova.ch
    • Ensuring convenient usage of our website
    • Analysis of system security and stability, as well as analyses for further administrative purposes

  2. Cookies

    We use cookies to optimise the functionality of our website www.inyova.ch with regards to user-friendliness, as well as to collect and analyse statistical usage data, in order to optimise our web services for you.

  3. Google Analytics

    We use tracking measures to ensure user-friendly design and continuous optimisation of our website, as well as to obtain statistical evaluations of its usage.

  4. Google conversion tracking
    • In connection with the Google Ads service, we use what is known as conversion tracking. If you click on an ad placed by Google, a cookie for conversion tracking is stored on your computer/device. These cookies expire after 30 days, do not contain any personal data, and thus do not serve for personal identification. The information collected by the conversion cookies is used to compile conversion statistics for Ad customers, who have opted for conversion tracking. This data is processed in a pseudonymised form within Google marketing services. This means that Google does not save and process, for instance, the names or email addresses of users, but rather it processes relevant data from individual cookies within pseudonymised user profiles. Futhermore, this means that from Google’s viewpoint, ads are not managed and displayed for an identified, concrete person, but for a cookie owner, irrespective of who this cookie owner is. This does not apply if you actively allow Google to process your data without this pseudonymisation. The user data collected by Google marketing services is transmitted to Google and is stored on Google’s servers in the USA.
    • The Google marketing services we use include, among others, the online advertising programme, Google Ads. In particular, we make use of the remarketing function within the Google Ads service. With Google Ads, every Ads customer receives a different conversion cookie. Cookies thus cannot be tracked across the websites of different Ads customers. The information collected with the conversion cookies is used to compile conversion statistics for Ads customers who have opted for conversion tracking. As an Ads customer, we only get to know the total number of users who clicked on our ad and were referred to a site with a conversion tracking tag. We do not receive any information that would allow us to identify individual users personally.

  5. Facebook Pixel

    Inyova uses the Facebook Pixel from the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA, on its website. This means that there are so-called tracking pixels integrated on our website. If you visit our website, the tracking pixel establishes a direct connection between your browser and the Facebook server. Facebook thus receives information from your browser that our website has been accessed on your device, among other things. If you are a Facebook user, Facebook can link your visit of our website to your Facebook account. We would like to point out that we as the provider of the website do not know the content of the data transmitted to Facebook and how they are used. We merely have the option to choose which segments of Facebook users (age, interests) should see our ads. When the pixel is accessed from your browser, Facebook can also see whether a certain Facebook ad has been successful, e.g., in that it has led to the conclusion of an online contract. This helps us to assess the effectiveness of Facebook ads for statistical and market research purposes.

    Please click here if you do not wish your data to be collected via pixel Facebook. Alternatively, you can deactivate the Facebook Pixel on the Digital Advertising Alliance’s website via the following link: http://www.aboutads.info/choices/.

    6. Compliance with data protection regulations

    Inyova processes the personal data mentioned above in accordance with the provisions of the Federal Act on Data Protection (FADP) and the related ordinance (DPO).

    As a financial service provider, Inyova is subject to various further legal obligations. This means that we have to meet the statutory requirements, as well as the requirements of banking supervisory law. The purposes of data processing includes, among others, identity and age checks, prevention of fraud and money laundering, meeting requirements of sanctions and embargoes, answering official requests from competent state or judicial authorities, complying with tax-law-related monitoring and reporting obligations, as well as the assessment and management of risks at Inyova.

    Receivers of personal customer data

    Within Inyova, those units that need your personal data to fulfil the contractual and legal obligations have access to your data. Service providers and vicarious agents contracted by Inyova may also receive data for these purposes, if they safeguard banking secrecy and maintain Inyova’s written data protection regulations.
    With regards to the transmission of data to receivers outside of Inyova, please note that Inyova is bound to keep all customer-related facts and valuations that it becomes aware of, confidential.
    Inyova is allowed to share information about you only if statutory provisions demand, if you have given your consent or if processors contracted by Inyova equally guarantee compliance with banking secrecy and with the provisions of the General Data Protection Regulation/the Federal Data Protection Act. Subject to these conditions, recipients of personal data may, for example, be any of the following:

    • Public authorities and institutions in the case of legal or official obligation
    • Other credit or financial service institutions, comparable institutions, and processors to whom Inyova transfers personal data to maintain its business relationship with you. These companies are also legally or contractually obliged to handle personal data with due diligence.
    • Brokers
    • Service providers who support Inyova with the following activities: support/maintenance of EDP/IT applications, archiving, call centre services, compliance services, controlling, data screening for anti-money-laundering purposes, customer administration, marketing, reporting, risk controlling, expense reporting, telephone services, video identification, investment services, stock record, auditing services, payment transactions, compiling tax data and reports
    • Members of certain regulated professions such as lawyers, notaries, or auditors
    • Further data recipients may be those entities for which you have given your consent to data transmission

    Note: Under no circumstances will personal data be sold to third parties.

    Normally no data transmission to third countries or international organisations

    Data is transmitted to countries outside of Switzerland, the EU, or the EEA (so-called third countries) only as far as necessary for the execution of your orders (e.g. payment and securities orders), or if required by statutory law (e.g. tax reporting obligations), if you have given your consent or in the case of processing by sub-contractors. If we contract service providers in a third country, they are bound by written instruction and obliged to comply with the European level of data protection due to the EU standard contractual clauses. If you need a printout of these provisions or information on their availability, you can contact Inyova in writing.

    Data storage period

    Inyova processes and stores your personal data for as long as required to fulfil its contractual and legal obligations. It should be noted that our business relationship is a continuing obligation with an intended duration of several years. Once data is no longer required to fulfil contractual and legal obligations, it is deleted at regular intervals unless further processing – limited in time – is necessary for the following purposes:

    • Compliance with statutory retention periods. This includes obligations arising from the Swiss Code of Obligations, the Accounting Ordinance, the Consumer Credit Act, the Money Laundering Act, the Financial Institutions Act, the Federal Act on Financial Services, and tax law. The periods prescribed there for storage or documentation is up to 10 years.
    • Conservation of evidence within the limitation period. The limitation period may be up to 30 years, the regular limitation period being 10 years.

    For applicants without subsequent conclusion of a contract, the storage period lasts until the applicant’s revocation.

    Protection of personal data

    Inyova implements reasonable and appropriate measures to protect stored and processed information from misuse, loss, and unauthorised access. To do so, Inyova has taken a series of technical and organisational measures.

    If you suspect that your personal data has been misused, lost, or accessed by unauthorised persons, please inform us as soon as possible.

    Rights of the data subject

    Every data subject has the right of access, the right to rectification, the right to erasure, the right to restriction of certain processing, the right to object to certain processing activities, as well as the right to data portability.

    The right of access includes:

    • the right to obtain information on the purpose of processing,
    • the category of the personal data processed,
    • the categories of data recipients to whom personal data was or is disclosed,
    • the planned storage period,
    • the existence of a right to rectification,
    • erasure,
    • restriction of processing,
    • objection or data portability,
    • the existence of a right to complain,
    • the origin of the data if they have not been collected by Inyova,
    • the existence of automated decision-making including profiling,
    • if applicable, meaningful information on the details thereof.

      • You can ask for the rectification of inaccurate or completion of incomplete personal data collected by Inyova at any time.

      You can ask for erasure of your personal data stored at Inyova if the processing of such data is not required in order to exercise the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest, or to assert, exercise or defend legal claims. If none of these cases apply, Inyova will delete the data. Inyova will usually also enter your name in a list of persons who do not wish to be contacted. By doing so, Inyova minimises the chance that you are contacted in the future if your data is collected separately under different circumstances.

      Under certain conditions, you may ask Inyova to restrict the processing of your personal data. This means that Inyova will only store your data in the future and will not carry out any further processing activities until: (i) one of the conditions listed below has been eliminated; (ii) you have given your consent; or (iii) further processing is necessary to assert, exercise or defend legal claims, to protect other persons’ rights, or if the processing is necessary due to legitimate public interest. Under the following conditions, you may ask Inyova to restrict the processing of your personal data:

      • If you contest the accuracy of your personal data that Inyova processes. In this case, processing of your personal data by Inyova is restricted until the accuracy of the data has been checked.
      • If you object to the processing of your personal data by Inyova according to Inyova’s legitimate interest. In this case, you may obtain restriction of the data while Inyova verifies its reasons for processing your personal data.
      • If processing of your personal data by Inyova is unlawful but you prefer to restrict processing by Inyova instead of having the data deleted.
      • If it is no longer necessary for Inyova to process your personal data, but you need the data to assert, exercise or defend legal claims.

      You can obtain the personal data that you have made available to Inyova in a structured, common, and machine-readable format or obtain transfer of the data to another controller.

      If a decision to conclude or implement a contract has been made merely on the basis of an automated process and if this decision takes legal effect for you, or you are substantially affected by it in a similar way, you can ask Inyova to verify the decision manually, after having laid out your point of view to Inyova and applied for manual verification. In the case of such decision, Inyova will notify you separately about the reason, as well as the implications and the intended effects of such data processing.

      Furthermore, you have the right to complain. You can contact our data protection coordinator at gdpr@inyova.ch to do so. You can also contact the Federal Data Protection and Information Commissioner as the supervisory authority.

      You can revoke your consent to the processing of your personal data vis-a-vis Inyova at any time. Please note that your revocation will only take effect for the future. Data processing that has occurred before your revocation is not affected by this. The separate notice at the end of this privacy statement also relates to this.

      If you revoke your consent, Inyova must stop the related activities. This applies, except where Inyova can prove that it has urgent, legitimate reasons for the processing that override your interests, or that the data is being processed to assert, exercise or defend a legal claim.

      Obligation to provide data

      Within the framework of our mutual business relationship, you are obliged to provide the data that is necessary to start and maintain a business relationship and to fulfil the related contractual obligations or that Inyova is legally required to collect. Without this data, Inyova will usually have to decline to conclude the contract, decline to execute the order, or will not be able to continue performing an existing contract and may have to terminate it. In particular, Inyova is obliged by the provisions of the Money Laundering Act to identify you before entering a business relationship, for example by reference to your ID card, and to collect and record your name, date and place of birth, nationality, address and ID data for this purpose. To enable Inyova to fulfil this statutory obligation, you must provide Inyova with the necessary information and documentation and immediately report any changes that may arise in the course of the business relationship. If you do not provide Inyova with the necessary information and documents, Inyova may refrain from entering or continuing the desired business relationship.

      Automated decision-making

      In principle, Inyova does not use any fully-automated decision making to start and maintain the business relationship. Should Inyova use these procedures in individual cases, you will be notified of this separately, insofar as this is required by law.

      Profiling

      Inyova processes your data partly in an automated manner, with the aim of assessing certain personal aspects (profiling). Inyova uses profiling in the following case, for example:

      • Inyova is obliged by statutory regulations to combat money laundering and fraud. This also includes certain data analyses (e.g., relating to payment transactions). These measures also serve to protect you.

      Revision clause

      This data protection statement is valid as of May 2022. Inyova reserves the right to amend this data protection statement from time to time. Please check on a regular basis, and especially before contracting any service, whether a new version has been published. You can always access and print the current version of the data protection statement on our website at www.inyova.ch. Inyova will keep you posted on fundamental changes, through its website and via the usual communication channels.

      Information on your right to object to data processing for promotional purposes.

      Right to object to data processing for promotional purposes

      In limited cases, we process your personal data for direct advertising. You have the right to object at any time to the processing of your personal data for such promotional purposes. This also applies to profiling, insofar as it is connected to such direct advertising. If you object to data processing for direct advertising purposes, we will no longer use your personal data for such purposes.

      No forms are required, and the best way to object is by email at gdpr@inyova.ch.

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