Last updated: March 2020
The Pillar 3 pension foundation of Zürcher Kantonalbank (the "Foundation") is also committed to an open, transparent and customer-friendly approach when it comes to the issue of data protection. By "personal data", the Foundation means information that relates to an identified or identifiable person. The Foundation interprets "processing" as referring to any handling of personal data, irrespective of the means and methods used; it particularly refers to the collection, storage, use, adaptation, publication, archiving or destruction of personal data.
Section 3 of the November 2019 version of the General Terms and Conditions (GTC) of Business contains general information about data protection, in particular in connection with the performance of contracts.
The Foundation is particularly bound by its duty of confidentiality and data protection law to protect your privacy in line with the applicable laws. To this end, the Foundation takes numerous precautions such as the implementation of technical and organisational security measures (for example, the use of firewalls and personal passwords as well as encryption and authentication technologies, access restrictions and awareness-raising and training for employees).
The Foundation can process the following categories of personal data, depending on which products and services it provides for you. In doing so, the Foundation will process the minimum amount of personal data necessary.
The Foundation processes customer data. These include the following in particular:
The Foundation processes data relating to potential customers and visitors (i.e. those who visit Zürcher Kantonalbank branches or the websites of Zürcher Kantonalbank or the Foundation in particular). The Foundation considers this to mean the following data in particular:
In order to fulfil the purposes set out in section 2.4, the Foundation can collect personal data originating from the following sources:
The period for which personal data is stored is determined according to statutory retention obligations and the purpose for which the data in question are processed.
As a rule, the Foundation stores personal data for the duration of the business relationship or term of the contract and then for a further ten years. This corresponds to the interval of time within which legal claims can be brought against the Foundation. Current or anticipated legal or supervisory authority proceedings can lead to data being stored beyond this period.
The Foundation can process the personal data described under section 2.1 in connection with the provision of its own services as well as for its own purposes or those required by law. These include the following in particular:
Depending on which services the Foundation may provide for you or the purpose for which the personal data are processed, the data processing is carried out on the following basis:
* Consent obtained for other reasons, for example due to the provision on the duty of confidentiality according to Article 86 of the Federal Law on Occupational Retirement, Survivors‘ and Disability Pension Plans (BVG / LPP), is not affected by this section.
If personal data processed by the Foundation are necessary in order to fulfil statutory or regulatory obligations or for the conclusion or performance of a contract or the commencement of a business relationship with you, it may be the case that the Foundation cannot accept you as a pension fund member or cannot provide you with products or services if the Foundation is unable to process this personal data. In this case, we will inform you accordingly.
The Foundation also reserves the right in future to analyse and evaluate pension fund members’ data (including data of affected third parties, see section 2.1) in automated form in order to recognise key personal characteristics of the pension fund member or predict developments and create customer profiles. These are particularly used for business reviews and to provide individual consultations as well as offers and information that the Foundation and the Zürcher Kantonalbank Group companies may make available to the member of the pension fund.
Customer profiles may in the future also lead to automated individual decisions, for example in order to accept and execute orders submitted by the pension fund member in eBanking by automated means.
The Foundation will ensure that a suitable contact person is available if the pension fund member wishes to discuss an individual automated decision; this opportunity of expression is provided for by law.
Within the Foundation and Zürcher Kantonalbank, which is entrusted with the management of the Foundation, access to your personal data will only be granted to those departments requiring them for the conclusion or performance of a contract or the commencement of a business relationship in order to fulfil statutory or regulatory obligations or perform duties in the public interest.
The Foundation only discloses pension fund members’ data to third parties in the following cases – depending on the nature of the products and services used:
Contract processors are third parties who process personal data on behalf of and for the purposes of the Foundation, for example IT, marketing, sales or communication service providers, collection agencies, fraud prevention agencies or consulting firms. If personal data is communicated to such contract processors, they may only process the received personal data in the same way as the Foundation itself. The Foundation selects its contract processors carefully and places them under a contractual obligation to guarantee confidentiality and professional secrecy in Switzerland as well as the security of the personal data.
Depending on which product or service is being used, personal data may under certain circumstances also need to be disclosed to third parties (including contract pro- cessors) based in countries in which no adequate level of data protection prevails. For example, the United States of America does not provide for an adequate level of data protection. When communicating personal data to such a country, the Foundation requires the recipient to take appropriate measures to protect personal data (for example, by agreeing to "EU standard clauses", other precautions or on the basis of justifying grounds; we can provide you with a copy of the EU standard clauses free of charge).
You have the right to information, rectification erasure, restriction, objection, as well as – where applicable – the right to data portability. In addition, you have the right to lodge a complaint with a competent data protection supervisory authority (see section 5).
The Pillar 3 pension foundation of Zürcher Kantonalbank accepts information requests in writing together with a clearly legible copy of a valid official identity document (for example, a passport, identity card or driving licence) at the following address:
Vorsorgestiftung Sparen 3 der Zürcher Kantonalbank
The right to erasure and the right to object are not unlimited rights. Depending on the individual case, overriding interests may necessitate further processing. The Foundation will examine each individual case and notify you of the result. If personal data are processed for the purpose of direct marketing, your right to object also extends to direct marketing, including profiling for marketing purposes. You can lodge an objection to direct marketing at any time by sending the Foundation a notification to this effect (see section 5).
You can always revoke any consent you may have given to the Foundation to process personal data. Please note that such a withdrawal of consent only has effect for the future. Processing which took place prior to withdrawal of consent is not affected.
If the Foundation fails to meet your expectations with respect to the processing of personal data, if you wish to complain about the Foundation’s data protection practices or if you wish to exercise your rights, please notify the Foundation of this (see section 5). This will give the Foundation the opportunity to address your concerns and make improvements, if need be. In order to assist the Foundation in responding to your enquiry, please provide the relevant details in your notification. The Foundation will look into your concerns and reply within an appropriate period of time.
The Foundation is obliged to process the personal data accurately and keep it up to date. Please notify the Foundation of any changes to your personal data.
The Foundation is responsible for the processing of personal data:
Vorsorgestiftung Sparen 3 der Zürcher Kantonalbank
You can address general questions, suggestions and comments to your account manager or customer support.
You can address your questions in connection with data protection to the address listed above for the Pillar 3 pension foundation.
If you are not satisfied with the Foundation’s response, you have the right to lodge a complaint with the data protection authority.
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