Swiss Life Ltd (hereinafter “Swiss Life” or “we”) takes the protection of personal data extremely seriously. Accordingly, the relevant principles of data protection legislation, insurance supervisory legislation and ordinance as well as other regulatory requirements apply in everyday practice at Swiss Life.
This includes ensuring that Swiss Life adequately and consistently protects personal data and safeguards the confidentiality, integrity, availability, traceability and proportionality requirements when processing your data.
Please find below an overview of the processing activities carried out on personal data by Swiss Life.
2. Controller and data protection officer
The following party is responsible for processing data as described:
Swiss Life Ltd
For queries concerning data protection law, you can contact our data protection advisor at the following address:
Swiss Life Ltd
Data Protection Advisor
3. Category of processed personal data
We may process the following categories of personal data for the purposes set out in section 4:
- Personal data and contact information: In particular, this includes first and last names, street, house number, place of residence, country of domicile, gender, date of birth, age, marital status, languages, nationality, residence permit, e-mail address, telephone number;
- The personal data provided in the application for accreditation and related supplementary documents;
- Data on the sub-intermediaries reported by the distribution partner, in particular the personal data of the management and the contact person;
- Data required to fulfil internal requirements as well as the legal obligations incumbent upon us and associated clarifications and reporting (e.g. in connection with insurance supervisory requirements), in particular information relating to the creditworthiness, good repute and reputation of the persons entrusted with the administration and management of the intermediary, persons with a direct or indirect stake in the intermediary of more than 10% and other functionaries of the intermediary;
- Data for the administration of cooperation agreements;
- Collection and disbursement data (e.g. for commissions and reclaims).
4. Processing purpose
We process personal data in the context of cooperation with (insurance) intermediaries for the following purposes:
4.1 Contract processing (including accreditation and contract preparation)
Swiss Life processes personal data for the following purposes:
- Making decisions on entering into business relationships (“accreditation”) and terminating them;
- Processing the cooperation agreement;
- Deciding whether to approve the use of sub-intermediaries;
- Commission calculations and reclaims;
- Checking the trustworthiness, creditworthiness and compliance with regulatory requirements, such as a good reputation as well as training and development requirements;
- Statistical evaluations;
- Use of the Swiss Life PartnerNet application.
4.2 Advertising and marketing activities
Swiss Life wishes to provide you with individual and customer-friendly information to meet your needs. We therefore also process your personal data
- to send you, your employees and sub-intermediaries information (including in the form of magazines and newsletters);
- to invite you to client events; and
- for efficient and effective intermediary support, maintaining contacts and other communication, including outside contract processing.
4.3 Legal obligations and combating abuse
The processing of personal data is necessary in order to comply with legal and regulatory requirements (e.g. retention obligations, Anti-Money Laundering Act, Insurance Supervision Law, FINMA requirements, Financial Services Act).
If there is a suspicion of fraud or misconduct, we will process your personal data in compliance with the principles of proportionality and data protection and pass it on to other insurance companies, detectives and law enforcement authorities for the purpose of detecting or preventing abuse.
4.4 Market research purposes and analyses
We may also contact you to voluntarily participate in market research activities. We collect, store and process personal data for the evaluation, improvement and new development of products, services and functions. In some cases, the insights gained are anonymised and then used (without any personal reference) for various analyses or reviews in the company.
If you do not want us to use your data for market research purposes, please let us know. Our contact details can be found in section 2 above.
4.5 Data use by Swiss Life service units
As part of our broker service, one of our service units may contact you. Swiss Life processes your personal data within our service units for the following purposes:
- Arranging appointments;
- Managing existing customer relationships.
4.6 Other processing purposes
- Protection of data, secrets and assets;
- Security of systems and buildings, including video recordings;
- Optimising and guaranteeing the functionality and security of the websites and other IT systems;
- Preventing and investigating criminal offences and misconduct;
- Asserting, exercising or defending legal claims.
5. Data recipients
Your personal data may be disclosed to the following categories of recipients insofar as this is necessary for the purposes set out in section 4:
- Swiss Life Group companies (for details see www.swisslife.com);
- Authorities, register offices, courts and offices;
- Internal and external service providers of Swiss Life (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.).
The aforementioned recipients may be located abroad. Personal data may therefore be processed anywhere in the world, including outside the EU or the European Economic Area (e.g. in the USA or on other continents). 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 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, or if the data subject has given their consent). If further measures are required as a result of a specific instance of data transmission, we will also take this into account appropriately. Please note that while contractual provisions may partially compensate for weaker or missing legal protection, they cannot fully exclude all risks (e.g. of government interventions abroad).
6. Duration of processing
Data is stored for as long as the processing purposes, statutory retention periods and legitimate interests of Swiss Life 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 data as part of the usual procedures at Swiss Life. As soon as personal data is no longer required for any of the aforementioned purposes and there are no other reasons precluding deletion, it is generally automatically deleted or anonymised.
7. Your rights
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 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 you wish to exercise any rights in respect of us, please contact us in writing or by e-mail (contact details listed in 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 inform the unit specified in section 2. The Swiss supervisory authority can be reached at https://www.edoeb.admin.ch/edoeb/en/home.html.
Should the provision or disclosure of information be manifestly unfounded or not possible, in particular due to a law, a judicial order, overriding interests of third parties or for other reasons, we are entitled to refuse, restrict or postpone such provision or disclosure of information.
Last update: September 2023