Privacy & Cookies Policy

1. INTRODUCTION

The protection of your privacy and your personal information is important to FlowBank SA (hereinafter “FlowBank”). Our policy is to respect the confidentiality of information and the privacy of individuals.

This privacy notice outlines how we manage the personal information provided to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or our app(s) or website(s). It also details your rights in respect of the processing of your information.

The data protection principles under the Swiss Federal Act on Data Protection set out FlowBank’s responsibilities to you. Personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date
  • Kept only as long as necessary for the purposes we have told you about
  • Kept securely

FlowBank keeps this notice under review and may change and amend it from time to time to take into consideration new technology, changes to our operations and practices, and new laws and regulations. Our most current privacy notice will govern any of your personal information we hold.

2. ABOUT YOUR DATA CONTROLLER

This privacy notice applies to the processing activities of FlowBank SA.

FlowBank is a company registered in Switzerland under registered number CHE-445.530.584, authorized and regulated by the Swiss Financial Market Supervisory Authority (FINMA).

The registered address for FlowBank is: Esplanade de Pont-Rouge 6, 1212 Grand-Lancy.

FlowBank provides a variety of banking investment and e-trading related services and is the data controller of your personal information in relation to those services.

3. INFORMATION COLLECTED BY US

3.1 Information you give us

We collect information you enter when using our website and when you apply to open an account with us. The information you give us may include your name, address, email address, phone number, date of birth, tax identification number, bank account and other financial details, copies of personal identification documents (such as your passport or driving licence) and photographs or other descriptions of your likeness. We also collect information when you voluntarily complete client surveys, provide feedback, apply for special offers and promotions, enter into competitions or register to our events (such as seminars and webinars).

3.2 Information received for other sources

When you visit our website, we may collect or receive your IP address, URL, browser information, plug-in types, operating system and platform as well as your login information. We work closely with third parties (e.g. business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), data aggregators, lead generation agencies, public sources, third party social networking sites and search information providers) and may receive information about you from them. Such information may include your clickstream through our website, the products you viewed and the page interactions, your personal contact information (if you are referred to us by an introducing broker or a friend), any personal data that is part of your profile on a third party social network (e.g. Facebook) and that you allow that third party social network to share with us (e.g. name, email address, gender, birthday, city, country, interests, profile picture, user ID, friend list). You can learn more about the data that we may obtain about you by visiting the website of the relevant third-party social network. We may also receive personal data about individuals when we acquire other companies.

3.3 Information collected using cookies

We, or our third-party providers, may also use cookies to collect information about you. This helps us to provide you with a good experience while you use our website.

4. HOW FLOWBANK USES YOUR PERSONAL DATA

FlowBank may use personal information for the following purposes:

4.1 Identity Verification, Account establishment and Management

As part of providing services, or information about our services, to you, we will need to verify your identity to accept you as a customer and we will need to use those details in order to effectively manage your account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out identity checks on our behalf. It is in our legitimate interest to do so and the use of your personal information in this way is necessary for us to know who you are as we also have a legal obligation to comply with certain Know Your Customer regulatory obligations.

As a Swiss bank, we are bound by the banking secrecy concerning information related to our clients. However, within the limits set by the law or the contract you have signed with us, we may be allowed to share your information with affiliated companies within FlowBank Group, third party service providers, business partners (such as introducing brokers, assets managers, banks and other financial institutions), judicial bodies or regulators. Information that we collect and maintain may be transferred to or controlled and processed inside or outside of the European Economic Area (“EEA”). In particular, our service providers might be based in Europe, Asia and North America. We only collect the minimum amount of data needed and use anonymised data in our profiling activities. We will retain your information for as long as needed to provide you with our services or as long as your account is active. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

4.2 Provisions, Improvement and Development of Products and Services

After account opening, we will need to use your personal information to perform our services and comply with our obligations to you. It is in our legitimate interests to ensure that we provide you with the best products and services so we may regularly review your needs to ensure that you get the best possible products and services from us. We may from time to time use personal information provided by you through your use of our services and/or through customer surveys as well as through the use of our website to help us improve our products and services. It is in our legitimate interests to do so.

4.3 Settlement of Enquiries and Disputes

Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. The retention period of your information will depend on the nature of the claim and the period during which we consider there is a risk that we will or should need to defend or bring a claim. In any case, we are required by law to keep your data for a period of 10 years after the termination of our business relationship with you or after the end of the transaction.

5. YOUR RIGHTS

5.1 Access, correction and erasure of your information

Upon your request, we will send you a copy of the information that we hold about you. This will be provided to you without undue delay in a structured, commonly used and machine-readable form. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. If we hold personal information about you and you want it to be removed from our database or inactivated, please contact us at privacy@flowbank.com.

5.2 Right to oppose the use of your personal data and to opt out of marketing communication

You have the right to ask us not to process your personal data. You can exercise your right to object by contacting us at privacy@flowbank.com. If you wish to opt out of marketing, our emails will also have an ‘unsubscribe’ option available in the footer of flowbank.com website. 

5.3 Links to other websites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

5.4 Complaint

You always have a right to file a complaint with a supervisory authority or directly to us by sending an e-mail to privacy@flowbank.com.

6. COOKIES

6.1 Definition

Cookies are small text files placed on your computer, smartphone or other device when you visit our website. They allow us to distinguish you from other users, which helps us give you an enhanced website experience. Cookies allow you to do many things such as log on to your account, apply for products and services online and use financial tools.

6.2 What cookies are we using?

We use three types of cookies on our website: essential cookies, performance cookies and tailored content cookies.

  • Essential cookies enable you to operate vital functions of our website and trading platform. If these are disabled, you may not be able to access the platform or other significant parts of the website.
  • Performance cookies allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily.
  • Tailored content cookies allow us to tailor the content of our website to suit you and link with other websites, such as social media websites. For instance, instead of displaying promotional messages about products you already have, they let us show you other services you might be interested in. We only use tailored content cookies subject to your prior opt-in to that effect and as set by our trusted business partners to provide you with FlowBank products and services and will only show you FlowBank branded advertisements on our website.

6.3 Disabling cookies

When you visit our website, we will ask for your permission to use cookies. If you wish to disable all cookies, you can do this through your browser settings. However, please be aware that cookies are often used to enable and improve certain functions on our website. If you choose to opt-out of certain cookies, it is likely to affect how our website works. For more information about how to disable cookies, including instructions on how to amend your cookie settings for a variety of browsers and how to delete existing cookies from your device, visit allaboutcookies.org.

7. DATA SECURITY

In order to keep your personal data secure, we have implemented a number of security measures, including: securing our operating environments that are only accessible to our employees, agents and contractors on a need-to know basis; encrypting each and every sensitive financial information processed to carry out transactions over our websites; verify your identity before you can access, use or make changes to your account so as to prevent any unauthorized access. Please note that these protections do not apply to personal data you choose to share in public areas such as on community websites.

8. CHANGES TO OUR PRIVACY AND COOKIES POLICY

We keep our Privacy and Cookies Policy under regular review and consequently, it may change at any time in the future. We will place any updates on our website

9. CONTACT

If you have any other questions about this policy please contact our privacy team at privacy@flowbank.com or write to us via postal mail at FlowBank Ltd, Esplanade de Pont-Rouge 6, P.O. Box 1303, 1211 Geneva 26, Switzerland. If you wish to contact our customer support, please refer to the Contact page on our website.