Data protection declaration for mortgages

Swiss Life AG (hereinafter "Swiss Life" or "we") takes the protection of your privacy and personal data
extremely seriously. Accordingly, the relevant principles of data protection legislation and other statutory and regulatory requirements apply in everyday practice at Swiss Life.

This includes ensuring that Swiss Life adequately and consistently protects your personal data and assigns top priority to confidentiality, integrity, availability, traceability and proportionality requirements when processing your data.

Please find below an overview of the processing activities of personal data carried out by Swiss Life. This
description is not exhaustive. Other matters relevant to data protection are additionally dealt with in other specific data protection declarations or general policy conditions and terms and conditions of business, entry conditions and similar documents.

Further information on data protection in relation to individual products or business activities, as well as the processing of your data on our website, can be found at https://www.swisslife.ch/privacy.

In accordance with data protection legislation, the following company is responsible for the data processing described here:

Swiss Life AG
General-Guisan-Quai 40
P.O. Box, 8022 Zurich

For queries concerning data protection law, you can contact us at the following address: 

Swiss Life AG
Data Protection Officer
General-Guisan-Quai 40
P.O. Box, 8022 Zurich
E-Mail: datenschutz@swisslife.ch

If the framework mortgage contract and the credit relationship(s) or rights/claims thereunder as well as the associated collateral (and/or rights to collateral) are assigned to the Swiss Life ESG Mortgage Fund  (represented by its fund management company, Swiss Life Asset Management AG) or to Münchener Hypothekenbank eG, we will inform you of this in the confirmation of the product agreement.

In both cases, Swiss Life AG remains responsible for the management and administration of the mortgage (including invoicing).

At https://www.muenchenerhyp.de/datenschutz, Münchener Hypothekenbank eG, Karl-Scharnagl-Ring 10,  80539 Munich, provides information on your rights as a data subject, the collection and processing of your data, the purposes of processing and their legal basis, and is available to answer any questions you
might have about data protection.

In connection with the conclusion and management of mortgages, we process the following categories of personal data in particular for the purposes set out in section 4:

• Master data (e.g. first and last names, street, number, place of residence, country of domicile, gender, date of birth, age, marital status, languages, nationality, residence permit, e-mail address, telephone number, type of employment);
• Income data (in particular gross income, bonuses for the past three years, information on alimony, information on other financial obligations, information on debt collection proceedings);
• Financing data (e.g. in particular equity, savings capital, pension assets, prepayment of inheritance or gift, third-party loans, amount of financing, purchase price);
• Data on the object of financing (in particular type of property, address of object of financing,  description of property, existing estimate of market value, photos, details of building rights);
• Payment data (e.g. payment method data, date and amount of incoming payments, reminders);
• Contract data (e.g. data from offers, applications and contracts);
• Data for the fulfilment of our legal obligations and associated clarifications and reporting, such as AEOI/FATCA and AMLA (in particular US citizens/dual citizens, clarification of economic background, beneficial owners, controllers, politically exposed persons, comparison with sanction lists);
• Behavioural and preference data (information about specific actions, e.g. payments, the use of electronic communications, interaction with social media profiles, contacts with distribution partners etc.; information about your needs and interests which we obtain from both the analysis of existing data and data from third parties);
• Communication data (e.g. type, time and place of communication and its content).

We usually receive this data from you, but also potentially from third-party sources such as your family members, address service providers (master data), credit reporting agencies and other information
service providers (e.g. master and financial data), representatives of you and other persons associated with you (e.g. contract data), offices (e.g. information we use for preferential data) and other sources (e.g. the media or Internet).

If you act on behalf of third parties or provide us with data of third parties, we assume that you have informed these third parties about our processing of their personal data. If these persons object to our
data processing, this may have an impact on the contract concluded with you.

Swiss Life processes your personal data (section 3) in connection with the conclusion and management of a
mortgage in particular for the following purposes:

• Fulfilment of statutory and other legal requirements (e.g. from self-regulation, industry standards, official instructions and internal stipulations, e.g. on the prevention of money laundering and the financing of terrorism, clarification of legal and reputational risks, reporting, fulfilment of duties of disclosure, information provision and reporting, archiving, handling complaints and other notifications, monitoring of communication, internal or external investigations, disclosure of documents to authorities, support in the prevention, detection and investigation of criminal offences and other breaches). We process in particular master data, contract, property and payment data, communication data and, in some cases, behavioural data for these purposes;
• Initiation, conclusion, management and execution of mortgage contracts (in particular acquisition, advice, support and preparation of an offer, processing and administration of offers and contracts including forwarding of data to our cooperation partners and experts). Review of the granting of a loan and safeguarding customer service with regard to any granting of loans. We process in particular master data, income, financing and property data for this purpose.
• Prevention, risk management, legal protection (e.g. risk assessments, prevention of misuse, internal and external investigations, legal proceedings, corporate management and ‑development). For this purpose we process, in particular, master data, contract data and financial data, as well as behavioural and communication data.
• Market research and product development (e.g. analysing the use of our offers, evaluating and improving existing offers and developing new offers). For this purpose we process, in particular, your master, behavioural and preference data, but also communication data and information from customer surveys, other surveys and studies and other information, e.g. from media monitoring services, from the media, from social media, from the Internet and from other public sources. 
• Marketing (e.g. transmission of  information and advertising from us and third parties, e.g. as a newsletter or printed matter, targeted addressing of existing customers, holding customer events and competitions, personalisation of information and advertising). For this purpose, we link data that we process about you and determine preference data. You may object to processing for marketing purposes at any time by notifying us. Further information on your rights can be found in section 7.
• Additional purposes: e.g. security purposes, monitoring buildings and publicly accessible premises, internal administration, training and education, bookkeeping, data archiving, managing IT, safeguarding our rights, evaluating and improving internal processes, statistics and research, safeguarding other legitimate interests.
• Customer service: As part of our customer service, one of our service units may contact you. Swiss Life processes your personal data within the scope of our service units to make appointments for advisory meetings and manage existing customer relationships.

“Processing” means any handling of personal data, e.g. its collection, storage, use, disclosure and deletion, as well as automated evaluation and the determination of preferential data, for risk assessment purposes or to conduct statistical evaluations. This also includes profiling, i.e. automated processing for analysis and forecasting purposes (e.g. to combat money laundering and terrorism financing, to combat abuse, for customer care and for marketing purposes).

We may disclose data pursuant to section 3 in particular to the following categories of recipient to the extent required for the purposes pursuant to section 4:

• Counterparties and banks in transactions;
• Our Group companies (for details see www.swisslife.com/en/home/about-us.html);
• Swiss Life ESG Mortgage Fund or Münchener Hypothekenbank (see section 2)
• Real estate brokers, address providers and brokers;
• Experts 
• SwissFex mortgage portal
• Authorities, courts and offices;
• Other third parties, e.g. banks or cooperation partners;
• Internal and external service providers (e.g. IT service providers, address and shipping service  providers, marketing, distribution, communication or printing service providers, service providers in building management, credit reporting agencies, debt collection service providers, consulting firms, auditors, etc.).

These recipients may be located abroad (e.g. when transmitting personal data to banks and other bodies in connection with assets located abroad, when purchasing IT services, in legal proceedings abroad, etc.). Your data may therefore be processed anywhere in the world, including outside the EU or the European Economic Area (e.g. in the US). Not all of these countries have a level of data protection equivalent to Swiss law. We therefore take contractual precautions and generally make use of standard contractual clauses (further information can be found at www.edoeb.admin.ch), unless an exception applies (e.g. in legal proceedings abroad, in cases of overriding public interest if the processing of a contract requires such disclosure, if you have given your consent). 

We process your data for as long as our processing purposes, the statutory retention periods and our  legitimate interests in processing for documentation and evidence purposes require or storage is technically necessary. The storage duration is based on legal and internal regulations and the processing purposes (section 4). If these purposes have been achieved or no longer apply and there is no longer any
obligation to retain your data, we will delete or anonymise the latter as part of our usual procedures.

You have certain rights as defined by the relevant legal conditions and framework:

• to request information from us as to whether and which data we process about you;
• to request us to correct data if it is inaccurate;
• to object to our processing and to request the deletion of data if we are not obliged or entitled to further processing;
• to ask us to hand over certain personal data in a conventional electronic format or transfer the data to another controller;
• to revoke your consent if our processing is based on your consent.

If we notify you of an automated decision in a specific instance, you have the right to state your position and to request that the decision be reviewed by a natural person.

If you wish to exercise any rights against us, please contact us in writing (section 2). In order to rule out misuse, we need to identify you.

If you do not agree with our handling of your rights or data protection, please let us know as specified under section 2. You can contact the Swiss supervisory authority at https://www.edoeb.admin.ch.

Swiss Life Switzerland acts exclusively for customers whose head office or domicile is in Switzerland. No
marketing or sales activities take place abroad.

Should you be interested in our products as a person domiciled outside Switzerland, we recommend that you contact a representative of the Swiss Life Group near you or one of our Group companies via their website (https://www.swisslife.com).

Swiss Life reserves the right to modify this data protection declaration without prior notice to take account of current statutory provisions and changed business procedures. We will actively inform persons whose contact details are registered with us about major changes as and when they occur, provided this is  possible without disproportionate effort. As a general rule, the data protection declaration in its current version at the start of processing applies for data processing. This data protection declaration does not form part of the contract. 

Last update: September 2023