Swisscanto Fund Management Co. Ltd.
and Swisscanto Pensions Ltd.
Privacy statement
The protection and confidentiality of your data are of the highest priority for Swisscanto.
Swisscanto complies with the provisions of Swiss data protection law in the processing of your personal data.
Purpose of the reporting system
The reporting system (BKMS® System – Business Keeper Monitoring System) used by Swisscanto is intended to make use of information about alleged malpractices in order to discover such activities at an early date and eliminate them internally (risk management). The report of the whistleblower is handled confidentially and is received and processed by Swisscanto within a standardised process.
Restricted use
Swisscanto processes personal data exclusively in connection with the report and the associated measures. The data are stored in an external, high-security data centre of a third party provider, but this provider has no access to the data. Swisscanto makes use of an independent third party for processing of the report (attorney's office Streiff von Kaenel AG), which requires access to the personal data in order to fulfil its duties. Swisscanto ensures that this third party complies with the provisions of Swiss data protection law and processes the data only for the intended purpose.
Notification of the data subject
The persons who are affected by the processing of their data (data subjects) are notified of the processing of their data insofar as and as soon as this is permitted by the processing of the report.
Origin of the data
Only those data are processed here as are provided via this portal.
Categories of data
Depending on the content of the report, various categories of data may be processed, such as relating to situations, details concerning persons, etc.
Use of data
Swisscanto permits access to personal data only to those persons who absolutely require these data in their role and for the fulfilment of their duties. All persons who receive access to the data are obligated to maintain confidentiality. We are also subject to statutory obligations to share and disclose information, in particular with respect to public authorities.
Data processing location
The processing of your data takes place exclusively in Switzerland.
Rights of the data subject
Upon request by the data subject, Swisscanto provides information – within the scope of what is legally permitted – on the personal data concerning the data subject that are being processed by Swisscanto. If the processed data are incorrect or incomplete, the data subject has the right to correction, modification or erasure of the data. The identity of the whistleblower is excepted from the right to information.
The rights of the data subject can be complied with when the processing of the report is no longer endangered or has been concluded.
Retention period of personal data
Swisscanto retains personal data for as long as needed for the processing of the report and for implementation of the associated measures. Legally specified longer retention periods are reserved.
Use of the reporting system
Communication between the computer of the whistleblower and the reporting system takes place over an encrypted connection (SSL). The IP address is not stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie containing only the session ID is stored on your computer (a so-called session cookie). This cookie is only valid until the end of each session and expires when you close your browser. No tracking takes place.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen user name and password. This allows you to communicate securely with the competent person at Streiff von Kaenel AG either using your name or in an anonymous way. This system stores the data exclusively within the reporting system, which makes them particularly secure. It differs from regular e-mail communication.
Modifications of this privacy statement
Swisscanto can change or modify this privacy statement at any time.
Swisscanto Asset Management International S.A.
Privacy statement
The privacy statement provides information on how we handle personal data.
1 Who is responsible for the data processing and whom can I contact?
The responsible party is:
Swisscanto Asset Management International S.A.
Legal department
19, rue de Bitbourg
L-1273 Luxembourg
Luxembourg
Tel.: +352 27 84 35 99
Email: legal@swisscanto.com
As the responsible party, we take all legally necessary measures to protect your personal data.
All data subjects can contact us directly regarding all questions and matters concerning data protection. You can reach us at the address, telephone number or email specified above.
2 For what purpose do we process your data and on what legal basis?
We process your personal data in accordance with the provisions of the General Data Protection Regulation (GDPR).
Swisscanto Asset Management International S.A. processes personal data exclusively in connection with the report and the associated measures. Swisscanto Asset Management International S.A. makes use of an independent third party for processing of the report (attorney's office Streiff von Kaenel AG, Switzerland), which requires access to the personal data in order to fulfil its duties. Swisscanto Asset Management International S.A. ensures that this third party complies with the European data protection provisions and processes the data only for the intended purpose.
3 Which data and which sources do we make use of?
We process personal data that we have received within the framework of the reporting system (BKMS® System – Business Keeper Monitoring System). These reports concerning alleged malpractices are used in order to discover such activities at an early date and eliminate them internally (risk management).
The report of the whistleblower is handled confidentially and is received and processed by Swisscanto Asset Management International S.A. within a standardised process. Only those data are processed here as are provided via this reporting system.
Communication between the computer of the whistleblower and the reporting system takes place over an encrypted connection (SSL). The IP address is not stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie containing only the session ID is stored on your computer (a so-called session cookie). This cookie is only valid until the end of each session and expires when you close your browser. No tracking takes place.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen user name and password. This allows you to communicate securely with the competent person at Streiff von Kaenel AG, Switzerland, either using your name or in an anonymous way. This system stores the data exclusively within the reporting system, which makes them particularly secure. It differs from regular e-mail communication.
4 Who receives your data?
Swisscanto Asset Management International S.A. makes use of an independent third party for processing of the report (attorney's office Streiff von Kaenel AG, Switzerland), which requires access to the personal data in order to fulfil its duties.
Within the group of Zürcher Kantonalbank, those parties receive access to your data who need these data for fulfilment of their contractual and statutory obligations.
Swisscanto Asset Management International S.A. permits access to personal data only to those persons who absolutely require these data in their role and for the fulfilment of their duties. All persons who receive access to the data are obligated to maintain confidentiality. We are also subject to statutory obligations to share and disclose information, in particular with respect to public authorities.
The persons who are affected by the processing of their data (data subjects) are notified of the processing of their data insofar as and as soon as this is permitted by the processing of the report.
The processing of your data takes place in Switzerland and in the European Union.
5 How long do we store your data?
We process and store your personal data for as long as necessary for the fulfilment of our contractual and statutory obligations.
When the data are no longer required for the fulfilment of contractual or statutory obligations, they are regularly deleted, unless statutory or regulatory retention obligations apply that we must comply with.
6 What data protection rights do you have?
Every data subject has
- the right to information according to Article 15 GDPR,
- the right to correction according to Article 16 GDPR,
- the right to erasure according to Article 17 GDPR,
- the right to restriction of processing according to Article 18 GDPR,
- the right to object according to Article 21 GDPR
- and – insofar as applicable – the right to data portability according to Article 20 GDPR.
In addition, insofar as applicable to you, you have a right of complaint to a competent data protection authority (Article 77 GDPR).
7 To what extent does Swisscanto Asset Management International S.A. carry out automated decision-making?
We do not fundamentally make use of any automated decision-making as defined by Art. 22 GDPR.
8 Can this privacy statement be modified?
We reserve the right to modify the privacy statement in order to adapt it to changed legal situations or in the event of changes to the service or the data processing. Users are therefore requested to regularly check the content on our website.
9 Information about your right to object according to Article 21 GDPR
You have the right, based on reasons arising from your particular situation, to object to the processing of the personal data concerning you that takes place on the basis of Article 6(1)(e) GDPR (data processing in the public interest) and Article 6(1)(f) GDPR (data processing based on the weighing of interests).
If you object, we will no longer process your personal data unless we can attest to legitimate reasons for the processing that outweigh your interests, rights or freedoms or the processing serves for the establishment, exercise or defence of legal claims. We request that you acknowledge that in such cases, we will not be in a position to provide services and to maintain a business relationship.
The objection may be made without particular requirements concerning form and should ideally be directed to:
Swisscanto Asset Management International S.A.
Legal department
19, rue de Bitbourg
L-1273 Luxembourg
Luxembourg
Tel.: +352 27 84 35 99
Email: legal@swisscanto.com
Version from February 2019