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.
FlowBank processes your data in accordance with the Swiss Federal Act on Data Protection. In particular, 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.

2. ABOUT YOUR DATA CONTROLLER
This privacy notice applies to the processing activities of FlowBank.
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 9, 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 and in relation to the use of FlowBank's website (www.flowbank.com).
If you have any question or request regarding the processing of your data, you may contact us by sending an e-mail to privacy@flowbank.com.

3. INFORMATION COLLECTED BY US
3.1 Information you give us
We collect information you enter when using our website, when you apply to open an account with us, and when we provide you with our services. 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 collect data related to your location when you log in to our website. We also collect information when you voluntarily complete client surveys, provide feedback, apply for special offers and promotions, enter into competitions, register to our events (such as seminars and webinars), or otherwise communicate with us.

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, including behavioral and preference data. This helps us to provide you with a good experience while you use our website. You may refer to Section 6 below regarding our use of cookies.  

4. HOW FLOWBANK USES YOUR PERSONAL DATA
FlowBank may use personal information for the following purposes:

4.1 Identity Verification, Account establishment and ManagementAs part of providing services, or information about our services, to you, we will need to verify your identity to accept you as a customer. This may include third parties carrying out identity checks on our behalf. We will need to continue processing your data in order to effectively manage your account with us and to comply with our legal and regulatory obligations.
We process data for these purposes on the basis of our legal obligations and/or to enter or perform a contract with you.

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. 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. 
We process data for these purposes to perform a contract with you, on the basis of our legitimate interest in improving our services and/or based on your consent, when you have given us such consent.

4.3 Compliance, Risk management, Settlement of Enquiries and Disputes

We will need to process your data to comply with our record keeping obligateons and other legal obligation, with directives and recommendations of authorities, court orders, our internal directives, as well as for risk management  purposes. We may also need to process your data when reporting to regulatory bodies or for internal and external audit purposes.
Where we consider there to be a risk that we may need to defend or bring legal claims, we may process your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims.
We process data for these purposes on the basis of our legal obligations and/or based on our legitimate interest in defending or enforcing claims and in managing risks.

4.4 Retention period

In principle, we will retain your data the entire duration of your contractual relationship with us, and, and for a period of 10 years after the termination of our business relationship with you or after the end of the transaction, as required by law. We may retain your data for longer in specific circumstance, for instance if legally or contractually required to do so or if your data is required to defend or bring a legal claim. In that case, the retention period of your information will be limited to what is legally required or necessary for the relevant purpose.

 4.5 Data sharing with third parties

Within the limits set by the law and 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 (such as providers to whom we may outsource certain functions, tracking and analytics providers, and third party social networks) business partners (such as introducing brokers, assets managers, counterparties, correspondent banks, infrastructures), and Swiss and foreign authorities (including courts, arbitral tribunals and self-regulatory bodies. We may also need to share your information with our auditors, legal advisors and consultants, or in the context of mergers and acquisitions.
Recipients may be located outside of Switzerland and outside of the European Economic Area (including in countries that do not offer an adequate level of protection of Personal Data), in particular in countries where the FlowBank Group has a business presence and where Financial Instruments traded by the Client are listed or regulated, but potentially anywhere in the world. Our service providers may be based in Europe, Asia and North America. 

4.6 Profiling
We process some of your data with the goal of automatically assessing certain aspects of your personality (profiling). We may do so in particular to comply with our legal and regulatory obligations (e.g. to combat money laundering and terrorism financing), to protect you and ourselves against fraudulent activities and other security risks; and to tailor our offer and marketing to you, and to improve our products and services (e.g. by conducting statistical analyses and for operational planning).

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, complete 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 www.flowbank.com
website. 

5.3 Right to withdraw consent

In the event that our processing of your data is based on your consent, you may withdraw your consent at any time.

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.

5.5.  Possible consequences of and limits to the exercise of your rights 

The exercise of certain of your rights (e.g. your objection to the processing of your data or withdrawal of any previously given consent) may prevent us from granting you access to our website and/or offering you our products and/or services. There may also be limits to the exercise of your rights, for instance when applicable laws or regulations require us to process your data, or when our legitimate grounds for the processing override your interests and rights.

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 via the cookie banner on our website 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.
Some cookies are stored on your device temporarily, whereas others will be stored for a longer duration. Tailored content cookies will not be stored on your device for more than 6 months after which you will be requested to renew your consent to the use of these cookies.

6.3 Disabling cookies
When you visit our website, we will ask for your permission to use cookies. If you have consented to the use of cookies, you can withdraw your consent at any time by amending your cookie preferences on our website. 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
You must take appropriate precautions when accessing our website and using our services, including without limitation using a secure connection and keeping your log in information confidential.
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 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. Please also note that there are inherent risk to the transmission of personal information over the Internet and the electronic storage of data. We cannot guarantee absolute security of your information. 

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. If you are a user of our services, we will notify you of changes to this Privacy and Cookies Policy.

9. 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.

10. DATA TRANSMISSION IN THE FRAMEWORK OF FACEBOOK CUSTOM AUDIENCE AND GOOGLE MATCH
In order to create custom audiences (consisting of FlowBank customers and internet users or only internet users while excluding FlowBank customers) and lookalike audiences (consisting of internet users similar to FlowBank users) and deliver personalized content to such audiences, FlowBank uses Facebook Custom Audiences (a service provided by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin, Ireland) and Google Customer Match (a service provided by Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, Ireland). For this reason, FlowBank transmits your hashed (pseudonymized) email address to Facebook and Google. The so-called “hashing” is a form of pseudonymisation which encrypts an email address in a way that individuals can no longer be identified by this hashed email address, without the use of additional information. Facebook and Google then match this email address against potential Facebook and Google email addresses. Hashed email addresses are deleted within 6-8 hours by Facebook and within 48 hours by Google, after the matching process is completed.
In the course of this process, Facebook and Google may be able to infer your identity and the existence of a banking relationship with us. Facebook and Google are not bound by Swiss banking secrecy and will process these data outside of Switzerland, where it will no longer be protected by Swiss law. Facebook and Google do not share these data with third parties or other advertisers or grant access to these data, provided however that they may share data with their respective affiliates, which may be located outside of Switzerland and outside of the European Economic Area. The legal basis for the processing of this data is your consent.
By clicking "I agree" on the specific disclaimer on www.flowbank.com, you consent to the processing of your personal data in the manner described above (including to the transfer of your personal data to countries which may not offer an adequate level of protection of Personal Data, such as the United States of America) and you waive banking secrecy as far as such data processing is concerned.
You can revoke your consent to this data processing at any time in the FlowBank Web App and App. You can find further information on Facebook here* and Google here** and here***.

*Facebook: https://www.facebook.com/legal/terms/customaudience [facebook.com]

** Google: https://safety.google/privacy/ads-and-data/ [safety.google]

***Google: https://support.google.com/google-ads/answer/6334160 [support.google.com]


11. GOVERNING LAW, JURISDICTION
This Privacy & Cookies Notice shall exclusively be governed by and construed in accordance with Swiss law. The exclusive place of jurisdiction for any dispute arising from or in relation to this Policy or any part thereof shall be at the seat of the Bank in Geneva, Switzerland. However, we reserve the right to bring proceedings against you before the competent courts having jurisdiction at your place of residence or domicile or before any other competent court, in which case Swiss law shall remain exclusively applicable.

12. 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 9, 1211 Geneva 26, Switzerland. If you wish to contact our customer support, please refer to the Contact page on our website.