Privacy Policy
Version from 1 May 2023
This privacy policy explains how we collect and process personal data. This is not an exhaustive description; other data protection declarations or general terms and conditions may regulate specific matters. Personal data means any information relating to an identified or identifiable individual.
If you provide us with personal data of other persons (e.g. your employees, family members, data of work colleagues), please ensure that these persons are aware of this data protection declaration and only provide us with their personal data if you are permitted to do so and if this personal data is correct.
As a company operating in Switzerland, Sostratos AG is subject to the data protection regulations of Switzerland.
Responsibility
Collection and processing of personal data
We primarily process the personal data that we receive from our customers and other business partners in the course of our business relationship with them and other persons involved or that we collect from their users in the operation of our website, our customer online portal and other applications (e.g. apps).
Insofar as this is permitted, we also take certain data from publicly accessible sources (e.g. debt enforcement registers, land registers, commercial registers, press, Internet) or receive such data from other companies within Sostratos, from authorities and other third parties. In addition to the data about you that you give us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and legal proceedings, information in connection with your professional functions and activities, information about you in correspondence and meetings with third parties, creditworthiness information, information about you that people close to you (family, advisors, legal representatives, suppliers, etc.) give us so that we can conclude contracts with you in compliance with the law. ) so that we can conclude or process contracts involving you or with you (e.g. references, your postal address for correspondence, powers of attorney), information on compliance with legal requirements, information from banks, insurance companies and other contractual partners of ours on the utilisation or provision of services by you (e.g. payments made, information from the media). (e.g. payments made, personal data from the media and Internet, if this is indicated in the specific case, e.g. in the context of an application, marketing, etc.), your residential or business addresses and, if applicable, interests and other socio-demographic data for the purpose of establishing new business relationships
Purposes of data processing and legal basis
We use the personal data we collect primarily to fulfil our contracts with our customers and business partners, in particular within the framework of risk management, insurance and occupational benefits advice and related activities with current or future business partners as well as to comply with our legal obligations at home and abroad. If you work for such a client or business partner, your personal data may of course also be affected in this capacity.
In addition, we process personal data of you and other persons, to the extent permitted and deemed appropriate, also for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:
Offering and developing our risk, insurance and professional pension advice and related activities;
Communicating with third parties and handling their enquiries (e.g. tenders, applications, media enquiries);
Examination and optimisation of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition;
Advertising and marketing (including the organisation of events), insofar as you have not objected to the use of your data (if we send you advertising as an existing customer of ours, you can object to this at any time; we will then put you on a blocking list against further advertising mailings);
Market and opinion research, media monitoring;
Assertion of legal claims and defence in connection with legal disputes and official proceedings;
Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
Guarantees of our operations, in particular IT, our website and online services offered with it as well as other platforms;
Video surveillance to maintain house rules and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to or entrusted to us (such as access controls, visitor lists, network and e-mail scanners, telephone records);
Purchase and sale of business units, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and insofar as to comply with legal and regulatory obligations as well as internal regulations of Sostratos.
Insofar as you have given us consent to process your personal data for certain purposes, we process your personal data within the scope of and based on this consent, insofar as we do not have any other legal basis and we require such a basis. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.
Cookies / tracking and social plug-ins in connection with the use of our website, Sostratos customer portal and apps: No personal data is transmitted.
We do use Google Analytics services on our website (Google Analytics, Google LLC in the USA, www.google.com), with which we can measure and evaluate the use of the website (using non-personal data). Google Analytics does not receive any personal data from us. At most, we still recognise from which country or from which canton/region a website user visits the Sostratos website. Conclusions about a determinable natural person are excluded.
The IP addresses, which are usually stored as part of the cookies for the Sostratos customer portal, are completely deleted, which means that no personal data is transmitted. Thus, we only recognise whether, for how long and at what time an anonymous website user visits Sostratos customer portal. Conclusions about a definable natural person are excluded. A region allocation of the website user is also no longer possible.
Sostratos uses social media platforms. However, we do not use social plug-ins from social networks or similar on our website. The icons on our website are simple links to the corresponding platforms. No IP addresses or personal data are transmitted during the linking process. The processing of your personal data is the responsibility of this operator in accordance with its data protection regulations. We do not receive any information about you from him.
Data transfer and data transmission abroad
In the course of our business activities and for the purposes set out in section 3, we also disclose personal data to third parties, insofar as this is permitted and appears to us to be appropriate, either because they process it for us or because they want to use it for their own purposes.
This applies in particular to the following bodies:
Service providers of ours within the Sostratos Group as well as externally, such as insurance companies, pension funds, banks, consulting firms, law firms), including contract processors (such as IT providers);
Network partners, suppliers, subcontractors and other business partners;
Customers and their legal representatives or contacts;
Domestic and, if necessary in rare cases, foreign authorities, government agencies or courts;
The public, including visitors to websites and social media;
Competitors, industry bodies, associations, organisations and other bodies;
acquirers or parties interested in acquiring divisions, companies or other parts of Sostratos;
other parties to potential or actual legal proceedings;
(hereinafter recipients).
These recipients of personal data are partly domestic, but may in rare cases also be abroad. If we transfer data to a country without adequate legal data protection, we ensure an adequate level of protection as provided for by law by using appropriate contracts (namely on the basis of the so-called standard contractual clauses of the European Commission). or rely on the legal exceptions of consent, the performance of a contract, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal data, because it is necessary to protect the integrity of the data subjects or the data subject has made the data generally available and has not expressly prohibited processing. You can obtain a copy of the aforementioned contractual guarantees at any time from the contact person named in point 1. However, we reserve the right to black out copies for reasons of data protection law or confidentiality or to supply only excerpts.
For the sake of completeness, we would like to point out that as a broker licensed in Switzerland, we exclusively serve Swiss clients. In order to fulfil our contractual obligations, it may exceptionally occur that personal data of natural persons resident in Switzerland may flow to the USA in connection with the maintenance of business relationships of our globally active clients. Furthermore, we would like to point out that US authorities are able to take surveillance measures under US legislation, according to which general storage of all data transferred from Switzerland to the USA is possible. This is done without distinction, limitation or exception based on the objective pursued and without objective criteria that would allow US authorities to restrict access to and subsequent use of personal data to specific, strictly limited purposes that justify access to such data.
Furthermore, we note that there are no legal remedies in the US for Swiss data subjects to access and correct or delete data relating to them, and that there is no effective legal protection against general access rights by the US authorities. We expressly draw your attention to this legal and factual situation so that you can make an informed decision about consenting to the use of your data.
Duration of retention of personal data
Data security
Obligation to provide personal data
Profiling
Rights of the data subject
You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing as well as to the surrender of certain personal data within the framework of the data protection law applicable to you and insofar as this is provided for therein. Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to retain or process certain data, if we have an overriding interest in doing so or if we need the data to assert claims. If you incur any costs, we will inform you in advance. Please note that the exercise of these rights may conflict with contractual agreements and may have consequences such as the premature termination of the contract or cost consequences. We will inform you in advance where this is not already contractually regulated.
The exercise of such rights usually requires you to provide clear evidence of your identity (e.g. a copy of your identity card where your identity is otherwise not clear or cannot be verified). To exercise your rights, you can contact us at the address given in section 1.
Every data subject also has the right to enforce his or her claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).