SwiKey Policy on Treatment and Protection of personal and financial data
07 May 2008
1. Personal scope of application
1 The present SwiKey Policy on Treatment and Protection of personal and financial data applies to any Internet User who access the World Wide Websites www.swikey.com, www.swikey.ch, www.swikey.net, www.swikey.biz (hereinafter generically referred to as « the SwiKey Website »). The SwiKey Website comprises all web pages and sub-web pages run by SwiKey and which are recognisable as such.
2 The present Policy does not affect the validity of any agreements concluded between the Internet User and SwiKey in regards to any specific services or products of SwiKey. In the event of contradiction between the specific agreements and the present Policy, the specific agreements shall prevail.
2 The present Policy does not affect the validity of any agreements concluded between the Internet User and SwiKey in regards to any specific services or products of SwiKey. In the event of contradiction between the specific agreements and the present Policy, the specific agreements shall prevail.
2. Materiel scope of application
1 The present Policy defines the principles governing the treatment and use of personal and financial data that the Internet User transmits to SwiKey or via the SwiKey Website. They also inform about the necessary precautions to secure the data protection.
2 The SwiKey Website may offer links to other websites that are not run or controlled by SwiKey (hereinafter referred to as « third websites »). The present Policy solely applies to the SwiKey Website. SwiKey does not give any guarantee for the handling of third websites in regard to the treatment and protection of data.
2 The SwiKey Website may offer links to other websites that are not run or controlled by SwiKey (hereinafter referred to as « third websites »). The present Policy solely applies to the SwiKey Website. SwiKey does not give any guarantee for the handling of third websites in regard to the treatment and protection of data.
3. Agreement by the Internet User
The Internet User expressly allows that SwiKey collects, stores, and treats his data in compliance with the principles provided in this Policy.
4. Applicable legislation
As regards the data of the Internet User, SwiKey complies with the law, in particular with the Federal Act on Data Protection (SR Number 235.1), the Federal Act on Combating Money Laundering in the Financial Sector (SR Number 950.0), and their respective Ordinances.
5. Data transfer to the SwiKey Website and cross-border data flow
1 SwiKey draws the Internet User's attention to the fact that the Internet is not considered as a safe environment, insofar as unauthorised persons can access the transmitted data via the Internet. Thus, the information can be disclosed or changed, and it can also cause technical problems. The data that is transmitted via the Internet may cross borders even though the sender and the addressee are located in the same country. Thus, the data may pass through a country that offers a lower level of data protection than the country of residence of the Internet User.
2 Further, SwiKey declines all responsibility in regard to the security of any data transmitted by the Internet User via the Internet. SwiKey re-emphasizes that any Internet User can, in the course of the Registration Procedure, send his data to SwiKey by mail.
3 In certain specific situations SwiKey provides an encrypted communication of data (if the User is connected with his Purse for example). In such a case, the encrypting is expressly mentioned.
2 Further, SwiKey declines all responsibility in regard to the security of any data transmitted by the Internet User via the Internet. SwiKey re-emphasizes that any Internet User can, in the course of the Registration Procedure, send his data to SwiKey by mail.
3 In certain specific situations SwiKey provides an encrypted communication of data (if the User is connected with his Purse for example). In such a case, the encrypting is expressly mentioned.
6. Type of data collected by SwiKey and use of this data, including for promotional purposes
1 Every time the SwiKey Website is visited or a SwiKey Internet Service is used, SwiKey may collect and store the following data:
any information the Internet User submits when he registers for a SwiKey Internet Service (personal, financial data and Service settings). The Internet User can verify this data at any time in his Electronic Purse, and he is obliged to proceed to the modification thereof;
any data arising from the use of the SwiKey Website and/or the SwiKey Internet Services (for example information on the duration and frequency of the use of the Service, the web pages visited by the Internet Users, information on personal data and other information transmitted by the Internet Users arising from announcements or contests posted on the SwiKey Website);
any non-personal data related to the technical treatment of the use of the SwiKey Website and/or the SwiKey Internet Services (for example IP address);
any information about the reaction of the Internet Users to any SwiKey offer that is expressly submitted to them by e-mail, mail, or telephone.
2 SwiKey does only collect, store, or treat data that is necessary for the compliance with its legal and contractual obligations, for the follow-up and development of the relationship with the Internet User, for the security of the SwiKey Website, in particular the SwiKey Electronic Payment Service, and to guarantee the quality of the provided Services and the invoicing.
3 SwiKey employs cookies in order to save the navigation language chosen by the Internet User(a “cookie” is a piece of data sent by a web server to the Internet navigator of the Internet User and stored on this computer. Cookies enable SwiKey to recognise the computer of the Internet User when he visits the SwiKey Website or uses the SwiKey Internet Services. Therefore, the Internet User should not renew the data already transmitted.). The IP address is also stored (the IP address is a code of 32 bits that identifies the sender or receiver of information transmitted via the Internet). This data is mainly collected to manage or assemble demographic information, and to supervise the use and the performance of the SwiKey Website. SwiKey shall only use cookies to facilitate the use of his Website by the Internet User (in particular when the Internet User uses his virtual shopping basket in a SwiKey e-shop).
4 SwiKey formally commits itself not to use any cookies for collecting information about the computers of its Internet Users (spyware) and not to display any advertisements when they are not connected to the Internet or when they surf outside the SwiKey Website (adware).
5 SwiKey draws the attention of the Internet Users to the fact that they can refuse the use of cookies. They can set up their navigator in a way that a warning is displayed before saving any cookie or even that any saving of cookies is prevented. The Internet User can also remove cookies that are already stored on his computer, however, in such a case, he will forfeit all the advantages of those cookies.
any information the Internet User submits when he registers for a SwiKey Internet Service (personal, financial data and Service settings). The Internet User can verify this data at any time in his Electronic Purse, and he is obliged to proceed to the modification thereof;
any data arising from the use of the SwiKey Website and/or the SwiKey Internet Services (for example information on the duration and frequency of the use of the Service, the web pages visited by the Internet Users, information on personal data and other information transmitted by the Internet Users arising from announcements or contests posted on the SwiKey Website);
any non-personal data related to the technical treatment of the use of the SwiKey Website and/or the SwiKey Internet Services (for example IP address);
any information about the reaction of the Internet Users to any SwiKey offer that is expressly submitted to them by e-mail, mail, or telephone.
2 SwiKey does only collect, store, or treat data that is necessary for the compliance with its legal and contractual obligations, for the follow-up and development of the relationship with the Internet User, for the security of the SwiKey Website, in particular the SwiKey Electronic Payment Service, and to guarantee the quality of the provided Services and the invoicing.
3 SwiKey employs cookies in order to save the navigation language chosen by the Internet User(a “cookie” is a piece of data sent by a web server to the Internet navigator of the Internet User and stored on this computer. Cookies enable SwiKey to recognise the computer of the Internet User when he visits the SwiKey Website or uses the SwiKey Internet Services. Therefore, the Internet User should not renew the data already transmitted.). The IP address is also stored (the IP address is a code of 32 bits that identifies the sender or receiver of information transmitted via the Internet). This data is mainly collected to manage or assemble demographic information, and to supervise the use and the performance of the SwiKey Website. SwiKey shall only use cookies to facilitate the use of his Website by the Internet User (in particular when the Internet User uses his virtual shopping basket in a SwiKey e-shop).
4 SwiKey formally commits itself not to use any cookies for collecting information about the computers of its Internet Users (spyware) and not to display any advertisements when they are not connected to the Internet or when they surf outside the SwiKey Website (adware).
5 SwiKey draws the attention of the Internet Users to the fact that they can refuse the use of cookies. They can set up their navigator in a way that a warning is displayed before saving any cookie or even that any saving of cookies is prevented. The Internet User can also remove cookies that are already stored on his computer, however, in such a case, he will forfeit all the advantages of those cookies.
7. Data security
1 In the SwiKey system any data of the Internet User is transmitted and stored in a protected environment (by firewalls for example). SwiKey takes all necessary measures to protect the data from any unauthorised access, abuse and loss, and ensures that its employees can only take cognizance of the data that is necessary to execute their assigned tasks.
2 Any data of an Internet User, including his e-mail address, are in no event transmitted, exchanged, or sold to third persons for promotional or economic purposes. SwiKey discloses data of an Internet User to third persons only if legal motives oblige SwiKey to do so.
3 The data of the Internet Users may be stored in another country than their country of residence. In such a case, SwiKey undertakes anything to ensure that this data benefits from a consequent protection and that any legal requirements are complied with.