This data protection declaration is intended to provide you with transparent information about the processing of personal data in our customer portal.
1. Introduction
You can view and save your insurance and contractual relationships with Swiss Life as well as your other asset management mandates in Swiss Life customer portal. The data processed for this is displayed in a domain only accessible to the applicable user (user account). Swiss Life takes the necessary technical and organisational measures to ensure compliance with data protection and data security. Use of Swiss Life customer portal is at the entire discretion of the user and can be terminated by him or her at any time.
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/en/privacy.
2. Controller and data protection officer
In accordance with data protection law, the following company is responsible for the data processing described here:
Swiss Life Ltd
General-Guisan-Quai 40
P.O. Box
8022 Zurich
For data protection concerns, you can contact us 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. Categories of personal data processed
The following categories of personal data in particular are depicted in the customer portal for the purposes set out in no. 4:
- Master data (e.g. name, address, contact information, gender, date of birth and age, marital status, languages, tax domicile);
- Contract data (e.g. policy term, type of insurance and cover, insured risks, benefits);
- Financial data (e.g. assets, custody account data, income and expenditures, investment profile information, payments and receivables, payment method data);
- Support data (the support data comprises information about the user’s hardware and software as well as further details of the support case, such as contact and authentication information, information about the status of Swiss Life customer portal at the time the error occurred and/or during diagnosis and files for error tracking;
- Behavioural data (as part of accessing Swiss Life customer portal, the data are entered in cookies and a log file. This makes it possible to determine which user accessed the customer portal at what time);
- 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 custodian bank, 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 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.
4. Processing purpose
We process your personal data (no. 3) in the customer portal for the following purposes:
- Presentation of your insurance contracts, benefits and contractual relationships. If you administer your asset management mandate in the customer portal, your custody account data will be regularly updated by the custodian bank in the customer portal;
- Support in case of system errors, problems in the user guidance after a call to the hotline, a query by e-mail or via the online form. Once the user has been identified, support is provided by telephone or remote access. Only the contents of the customer portal can be viewed remotely;
- Improvement of the customer portal and analysis of performance, error or misuse;
- Fulfilment of statutory and other legal requirements (e.g. industry standards and internal stipulations, e.g. on the prevention of money laundering and terrorism financing, 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). We process in particular master data, contract and financial data, communication data and, in some cases, behavioural data for these purposes;
- 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). To that end, we link data that we process about you and determine preference data. You may object to the processing for marketing purposes at any time by notifying us. Further information on your rights can be found in no. 8.
"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. to combat money laundering and terrorism financing, to combat abuse, for customer care and for marketing purposes.
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/en/home/about-us.html);
- Authorities, courts and offices;
- internal and external service providers (e.g. IT service providers, address and shipping service providers, marketing, distribution, communication or printing services, credit reporting agencies, 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 https://www.edoeb.admin.ch/edoeb/en/home/datenschutz/arbeit_wirtschaft/datenuebermittlung_ausland.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 (no. 3). 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.
The user can place an account deletion order via the portal. Personal data held in connection with Swiss Life contracts and contracts with other insurance companies under management by Swiss Life, in particular contract data, are stored by Swiss Life in accordance with legal or other provisions. Details on the processing of your contract data can be found via the following link: https://www.swisslife.ch/en/privacypolicy. The data stored for the user in the administration and partner systems of Swiss Life is not affected by this.
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;
- that we 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 (no. 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 no. 2. You can contact the Swiss supervisory authority at https://www.edoeb.admin.ch/edoeb/en/home/adresse.html.
8. Restriction of the range of products and services
Swiss Life Switzerland acts exclusively for clients 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 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 protection declaration
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.
10. Further provisions
The terms of use of Swiss Life customer portal apply additionally.
Last update: August 2023