The purpose of this privacy policy is to inform you transparently about how Swiss Life Ltd and its general agencies process your personal data within the scope of their acquisition, consulting and customer support remit as well as with regard to pension and financial analysis, financial, pension, inheritance and estate planning and the pension and insurance check (hereinafter "consulting and support").

1. Introduction

Swiss Life Ltd and its general agencies (hereinafter "Swiss Life" or "we") take the protection of your privacy and personal data extremely seriously. The relevant principles of data protection legislation and other regulatory requirements accordingly apply in everyday practice at Swiss Life.

This includes ensuring that Swiss Life adequately and consistently protects your personal data and safeguards the confidentiality, integrity, availability, traceability and proportionality requirements when processing your data.

We would like to provide you with an overview of the processes involving your personal data in connection with acquisition activities and the advice and support provided by Swiss Life and its general agencies.

This description is not exhaustive. Further information on data protection in relation to individual products, business activities and the processing of your data in connection with the provision of advice and support can be found at https://www.swisslife.ch/en/privacy.

2. Controller and data protection officer

For the purposes of data protection law, Swiss Life Ltd, General-Guisan-Quai 40, P.O. Box, 8022 Zurich is responsible for processing personal data in connection with the application, selection and recruitment process.

If you have any questions or concerns regarding data protection law, please contact the Swiss Life data protection officer at the following address:

Swiss Life Ltd
Data Protection Officer
General-Guisan-Quai 40
P.O. Box, 8022 Zurich

E-mail: datenschutz@swisslife.ch

3. Category of processed personal data

In connection with acquisition, advice and support as well as pension and financial analysis, financial, pension, inheritance and estate planning (hereinafter advice and support) in particular the following categories of personal data are processed for the purposes set out in cl. 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, occupation, health data);
  • Payment data (e.g. payment method data, details of beneficial ownership, date and amount of incoming payments, outstanding and paid invoices, reminders);
  • Financial data (e.g. income, assets, mortgage, debts);
  • Contract data (e.g. data from offers and applications including any questions on your state of health and doctor’s reports, information on the conclusion, fulfilment, enforcement and termination of contracts and other information in connection with contracts);
  • Highly sensitive data (e.g. health questionnaire);
  • 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 owner, controller, politically exposed persons, comparison with sanction lists);
  • Behavioural and preference data (information about specific actions, e.g. payments, use of electronic communications, interaction with social media profiles, contacts with distribution partners etc.; information about your needs and interests which we obtain from the analysis of this and other 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 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. statistical information) and other publicly available sources (e.g. the media or Internet).

If you act on behalf of third parties or provide us with data regarding third parties, you confirm that you have informed these third parties about our processing of their personal data and have expressly drawn their attention to the data protection information for the processing of personal data. If these persons object to our data processing, this may have an impact on the contract concluded with you.

4. Processing purpose

Swiss Life processes your personal data (cl. 3) in connection with acquisition, advice and support as well as pension and financial analysis, financial, pension, inheritance and estate planning (hereinafter referred to as advice and support) 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 reputation 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 the authorities, support in the prevention, detection and investigation of criminal offences and other breaches). In particular, we process master data, contract and payment data, communication data and, in some cases, behavioural data for these purposes;
  • Initiation, conclusion, management and execution of life and pensions and financial solutions (in particular acquisition, advice and support as well as pension and financial analysis, financial, pension, inheritance and estate planning or for the pension and insurance check, processing and review of applications including the required risk assessments, assessment and calculation of claims, processing and management of offers, contracts and client requests including collection and disbursement activities). For this purpose, we mainly process master data, contract data, financial data and communication data.
  • Prevention, risk management, legal protection (e.g. risk assessments, prevention of misuse, internal and external investigations, legal proceedings, corporate management and corporate 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, the media, social media, the Internet and other public sources.
  • Marketing (e.g. transmission of information and advertising from us and from or for 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). In particular, we use master data, communication data, behavioural data and preference data for this purpose. You may object to processing for marketing purposes at any time by notifying us or revoke any consent you have given to this. Further information on your rights can be found in cl. 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 (particularly master data, contract and communication 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 preference 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. for customer care and marketing purposes, to combat abuse, money laundering and the financing of terrorism).

5. Data recipients

We may disclose data pursuant to no. 3 in particular to the following categories of recipient to the extent required for the purposes required under 4 :

  • Our Group companies (for details see www.swisslife.com);
  • Intermediaries, address providers and brokers;
  • Previous insurers, co-insurers and reinsurers, as well as employee benefits and vested benefits institutions;
  • Authorities, courts and offices;
  • Parties subject to professional confidentiality such as doctors, medical staff, experts and their auxiliaries;
  • Other third parties such as banks or cooperation partners and their auxiliaries;
  • 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 by countries that do not all 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 https://www.edoeb.admin.ch/edoeb/en/home.html 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).

6. Duration of processing

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 (cl. 4). If these purposes have been achieved or no longer apply and there is no longer any obligation to retain it, we will delete or anonymise your data as part of our usual procedures.

7. Your rights

You have certain rights as defined by the relevant legal conditions and framework which may, however, be subject to certain prerequisites and restrictions:

  • To request information from us as to whether and which data we process about you;
  • To have data corrected by us if it is inaccurate;
  • To object to our processing and to request the deletion of data if we are not obliged or entitled to process it further;
  • 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 exert your rights in respect of us, please contact us, for example by e-mail to datenschutz@swisslife.ch (other contact information listed in cl. 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 cl. 2. You can contact the Swiss supervisory authority at https://www.edoeb.admin.ch/edoeb/en/home.html.

8. Restriction of the range of products and services

Swiss Life Switzerland acts exclusively for customers whose head office or domicile is in Switzerland. No marketing or sales activities take place abroad, and our services are intended only for people who live and whose habitual residence is in Switzerland.

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

9. Updating our data privacy policy

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. 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: August 2023