Cre­dit Eu­rope Bank (Suisse) SA (he­rei­naf­ter re­fer­red to as “CEB” or “us” or “we”) res­pects your pri­vacy and pro­cesses per­so­nal data as a data control­ler in ac­cor­dance with the laws governing data protection and professional or banking secrecy, as well as the codes of conduct that are applicable to us.

 

In this Privacy Policy we explain:

• what personal data we collect and how;
• for what purposes and on what grounds we process your personal data;
• with whom we share your personal data;
• how long we keep your personal data;
• the rights you have as data subject;
• how your personal data is protected;
• our use of cookies;
• changes to this policy; and
• how you can contact us.

This Pri­vacy Po­licy ap­plies to all per­sons of whom CEB pro­cesses per­so­nal data, such as (pros­pect) cus­to­mers or their re­pre­sen­ta­tives or ul­ti­mate be­ne­fi­cial ow­ners (“UBOs”), per­sons who have sub­scri­bed to news­let­ters or events, and per­sons who have ap­plied for a job at CEB. 

 

Personal data

Per­so­nal data is any in­for­ma­tion re­la­ting to an iden­ti­fied or iden­ti­fiable na­tu­ral per­son. Per­so­nal data that we pro­cess may in­clude:

• ‘Data on who you are’ such as (i) basic information like your first and last name, prefix, title, (ii) contact details such as your e-mail address, postal address and phone number, (iii) data contained on your identity document, and (iv) your role (e.g. authorized representative, legal representative, director or guarantor);
• ‘Your transactions and payments’: name and account number of the person instructing a payment, account number of the person receiving a payment, time and location at which payments were made, amounts transferred or deposited and the balance in your account and investments orders;
• ‘Your contact history’: the subject of the contact you had with us, when did the contact occur and with which department, how (via post, email etc.) and the recording of a telephone conversation or report from a discussion;
• ‘Data needed for security and fraud prevention’: internal reference register (i.e. a list of people and institutions with whom we no longer wish to have a relationship), external reference register (official lists kept by authorities or banks containing people and institutions who have committed fraud or otherwise pose a risk to the financial sector), national, European and international sanctions lists, camera footages in our offices and payment patterns;
• ‘Your financial situation and CEB products’: your personal and business CEB products and services, the balance in your accounts and on your loans, your registration with the credit registration office, your investment profile and data on payment arrears;
•  ‘Sensitive personal data’: data on criminal or administrative proceedings or sanctions, as well as data on political activities;
• ‘Your use of our websites’: your IP address, data on your visit to our website, the device you used to visit our websites, cookies and your cookie-settings;
• ‘Data on you from external parties’: data on companies, their representatives and UBOs, provided by the companies itself or from official registers, data from public sources such as official registers, status inquiry agencies, the credit and insolvency registers, newspapers, the internet or social media;
• ‘Job Applications’: data you may provide us for the purpose of a job application, such as your full name, date of birth, address, phone number, photo, nationality, marital status and any other personal data set out in your application;
• Personal data that you provide us with for the purpose of attending events or meetings, such as access and dietary requirements; and
• Any other personal data relating to you which you may provide us with or that we may obtain in relation to the purposes and based on grounds set out below.
  We collect this personal data because you provided this data to us. For example, you may provide data when entering into an agreement with us, by entering your data on our website, by giving us your business card or by applying for a job. We may also collect your personal data from other sources, such as from local counsels, counterparties, official registers (trade registers, land registers, etc) or by using publicly available sources.

 

Purposes and legal basis for the processing of personal data

CEB processes per­so­nal data for the following pur­poses:

• To verify whether or not CEB can accept someone as a customer;
• To enter into and execute contracts with you and (other) customers;
• To ensure money can be paid and received (payments);
• To analyse personal information for investigations and statistic objectives;
• To provide information about CEB products and services (marketing);
• For prevention of fraud and unusual transactions and in general for the protection of security and integrity of your transactions and of the financial market;
• To comply with legislation (including legislation combating money laundering and terrorist financing), supervisory obligations or court orders to which CEB is subject;
• To maintain contact with you, (other) customers and/or business relations; and/or
• To handle your job application or subscription to any of our recruitment services and events.

We will pro­cess your per­so­nal data using one or more of the fol­lo­wing le­gal grounds:

• Performance of a contract;
• Compliance with a legal or regulatory obligation;
• Legitimate interest;
• Your consent.

Sharing with others

We may share your per­so­nal data with Cre­dit Eu­rope Bank NV in the Netherlands, for the pur­poses des­cri­bed in this Pri­vacy Po­licy, to ensure that our services are provided to you based on a consistent and high-quality standard across the CEB Group.

In some cases, we may also share your per­so­nal data with third par­ties. This may include, but is not li­mi­ted to:

• Other financial institutions;
• Public authorities (such as tax and customs administrations and authorities, finance intelligence units, police and justice officials, and supervisory regulators and authorities); and/or
• Service providers, auditors, professional advisers and other third parties that provide services or advice to CEB.

We will only share your per­so­nal data with these third par­ties for the pur­poses and on the le­gal grounds sta­ted in this Pri­vacy Po­licy.

To the extent that a third party pro­cesses your per­so­nal data as a data pro­ces­sor of CEB, CEB will conclude a pro­ces­sing agree­ment with such party that meets the re­qui­re­ments set out in the applicable law.
To be able to pro­vide our ser­vices, it may be ne­ces­sary for us to trans­fer your per­so­nal data to a re­ci­pient in a coun­try out­side of the Eu­ro­pean Eco­no­mic Area. In that case, CEB will en­sure that the data trans­fer is com­pliant with the ap­pli­cable law and in particular appropriate safeguards are provided.

 

Retention period

CEB will not store your per­so­nal data any lon­ger than is ne­ces­sary to achieve the purposes sta­ted in this Pri­vacy Po­licy or to com­ply with the re­le­vant laws and regulations. We follow mi­ni­mum re­cord kee­ping re­qui­re­ments that are spe­ci­fied by different le­gis­la­tions, such as tax law and delete your per­so­nal data from our sys­tems to the extent it is tech­no­lo­gi­cally pos­sible. We may keep some of your per­so­nal data lon­ger for spe­ci­fic pur­poses like risk ma­na­ge­ment, potential claims, se­cu­rity and le­gal purposes. In such si­tua­tions, we li­mit ac­cess to your per­so­nal data to ab­so­lute mi­ni­mum.

 

 

Your rights

You, as a data sub­ject, have a num­ber of le­gal rights:

• Right of access. This means you can make a request to obtain access to the personal data concerning yourself;
• The right to rectification or correction of your personal data if it is inaccurate or incomplete;
• The right to erasure of the personal data that relates to you. Please note that there may be circumstances in which we are required to retain your data in order to meet our legal and regulatory obligations;
• The right to object to or to request restriction of the processing. Again, there may be circumstances in which we are legally entitled to refuse your request;
• The right to data portability. This means that you have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• The right to object to profiling or automated decisions;
• The right to lodge a complaint with a supervisory authority; and
• The right to withdraw your consent. Again, there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

Security

CEB has ta­ken tech­ni­cal and or­ga­ni­za­tio­nal mea­sures to en­sure an ap­pro­priate le­vel of se­cu­rity to pro­tect your per­so­nal data from unau­tho­ri­zed or un­law­ful pro­ces­sing and from loss, des­truc­tion, da­mage, al­te­ra­tion or dis­clo­sure. If you have any ques­tions regarding the se­cu­rity of your per­so­nal data, or if there are in­di­ca­tions of mi­suse, please contact us at the contact details indicated below.
 

Cookies
CEB uses co­okies on its web­sites and in­ter­net ban­king ap­pli­ca­tions. CEB does not place any co­okies on your brow­ser wi­thout your consent, ex­cept for the co­okies that are functio­nally re­qui­red.

Please vi­sit the Co­okie De­cla­ra­tion page for more in­for­ma­tion on co­okies, the de­tails of co­okies we use, and to see or mo­dify your cur­rent co­okie consent sta­tus.

 

Changes
CEB may amend this pri­vacy po­licy from time to time. On this web­site, you can al­ways view the la­test ver­sion of our pri­vacy po­licy. We would ad­vise you to check the po­licy regu­larly and, in any event, whe­ne­ver you pro­vide us with per­so­nal data.

 

Contact
If you need fur­ther in­for­ma­tion or have any ques­tions or com­ments about our pri­vacy po­licy or the pro­ces­sing of your per­so­nal data, please contact us in wri­ting via: crediteurope@crediteurope.ch

 

or

 

Credit Europe Bank (Suisse) SA

Rue du Rhône 80
1204 Geneva, Switzerland

Latest update: November 2023
 

Credit Europe Bank (Suisse) SA
Rue du Rhône 80
1204 Geneva, Switzerland
Telephone: +41 (0)22 839 19 19