Data Protection Declaration

Thank you for your interest in our company. Data protection is important to us and accordingly we explain in this privacy policy how we collect and process which personal data (in short: "personal data", i.e. data relating to a specific or identifiable person, such as name, address, nationality, e-mail address, interests and hobbies, user behaviour on websites). This privacy policy is based on the EU General Data Protection Regulation ("GDPR" for short).

Controller, data protection officer and representative

(1) The data protection officer is First Trust Services AG, Beethovenstrasse 19, 8002 Zurich, SWITZERLAND. 


(2) The contact details of the data protection officer are as follows 
Email: info@first-trust-services.ch

Telephone: +41 44 283 12 67

Collection of personal data and purposes of processing 

1) We limit the processing of personal data primarily to personal data that we receive from our customers, our cooperation partners or other persons involved in connection with our services and products or that we collect from users on our websites, apps or other applications.

(2) In particular, we collect the following personal data from you on a case-by-case basis and depending on the purpose (see below)

  • Salutation / title
  • First name, surname
  • your address
  • Email address
  • Telephone number(s)
  • Date of birth
  • Nationality
  • Hobbies / personal interests
  • Family circumstances
  • Tax identification number
  • Bank details

 

(3) In addition, we obtain and process further data from publicly accessible sources (e.g. land register, commercial register, media, Internet, Worldcheck) or receive such data from other group companies, from authorities and institutions, from your personal environment such as family, legal advisors) or from other third parties, if permitted and indicated. 

 

(4) We require this data in particular to fulfil the following purposes:

  • to identify you as a customer, co-operation partner or user of our websites
  • for correspondence with you
  • to fulfil our due diligence obligations
  • to comply with other statutory provisions
  • to conclude and process service contracts, e.g. formation order, mandate agreement, licence agreement
  • to conclude and process purchase and sales contracts, e.g. for the purchase of products from suppliers or sales to interested parties
  • for invoicing
  • to provide other services from our company or, if necessary, in cooperation with third parties
  • to provide you with the best possible and customised services and to further develop our range of services and products
  • for communication with third parties
  • to assess and respond to applications
  • to advertise and market our services and products (unless you have objected to the use of your data for this purpose)
  • for the assertion of legal claims or defence of our position in general
  • to ensure our operations in general (e.g. IT, websites, apps)
  • for video surveillance as a security element for access management (incl. visitor lists or other access controls)
  • to safeguard other security aspects

 

(5) We only process your personal data if we have a legal or contractual basis or if the data processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority. We only process data beyond this if we have your consent and there is no revocation. Or if a legitimate interest on our part prevails (e.g. continuation of the delivery of newsletters to existing customers, provided there is also no revocation). Consent can be revoked at any time.

3 Recipients of personal data and data transfer abroad

(1) We only pass on your personal data to recipients or third parties within the scope of the purposes described above, insofar as permitted and indicated. This may include in particular

  • Partner companies
  • Service companies such as banks, asset management companies, insurance companies, IT providers, printing companies
  • Customers of ours
  • Suppliers, dealers, transport companies, subcontractors or other cooperation partners
  • Authorities, state institutions, courts
  • Associations, public interest organisations

 

(2) Such data transfer is based either on a legal obligation (e.g. data transfer in the course of the automatic exchange of information), fulfilment of a contract (e.g. asset manager abroad), consent on your part, a public interest or on the basis of a legitimate interest on our part, provided that your interests or fundamental rights and freedoms with regard to the protection of personal data do not prevail. 

 

(3) The recipients may be in Germany or abroad. In particular, we would like to point out that we may exchange personal data within our group companies or transfer personal data to countries in which service companies from which we obtain services are based (e.g. Microsoft, Thomson Reuters).


In the case of recipients outside our company in the EU/EEA or in countries with recognised data protection adequacy (e.g. Switzerland), we ensure data protection by concluding - where necessary and appropriate - so-called commissioned data processing agreements.

 

If we transfer personal data to third countries without adequate legal data protection, we ensure an adequate level of protection in accordance with legal requirements, for example on the basis of EU standard contractual clauses or other instruments (e.g. Binding Corporate Rules, US Privacy Shield).

4 Use of our website(s)

In addition to the above, we would like to inform you about the use of cookies, analytics/tracking or other technologies on our websites as follows:


(1) When using the website for information purposes only (i.e. if you do not log in to use the website, register or otherwise provide us with information), we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website, which may include the following data in particular:

  • IP address
  • Date and time of the enquiry
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request originates
  • Browser used
  • Operating system and its interface
  • Language and version of the browser software

 

(2) Our website uses so-called cookies. These are small text files that are stored on your end device with the help of the browser. The cookies do not cause any damage. We only use them to make our website more user-friendly. Some cookies remain stored on your end device until you delete them. They enable us to recognise your browser on your next visit. If you do not want this, you can set up your browser so that it informs you about the setting of cookies and you only allow this in individual cases. However, we would like to point out that in this case you may not be able to use all the functions of our websites to their full extent.

 

(3) We use Google Analytics on our websites. Google Analytics is a web analytics service provided by Google Inc. in the USA and uses cookies. Web analysis means the collection, collation and evaluation of data about the behaviour of visitors to websites. Among other things, a web analysis service collects data on which website a data subject came to a website from, which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analysis is mainly used to optimise a website and to analyse the costs and benefits of internet advertising.

 

The purpose of Google Analytics is to analyse the flow of visitors to our website. Among other things, Google uses the data and information obtained to analyse the use of our website, to compile online reports for us which show the activities on our website and to provide other services in connection with the use of our website. Google may combine your behaviour with other websites you have visited. If you are a registered Google customer, Google will recognise you accordingly. Google's data protection provisions then apply to the further processing of personal data. Cookies are used to store personal information, such as the access time, the location from which access was made and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transferred to Google in the USA. Google may pass on this personal data collected via the technical process to third parties.

 

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used can also prevent Google from setting a cookie on your device (e.g. computer, notebook, tablet). In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programmes.

 

For further information, please contact Google directly, in particular via the following links 
www.google.de/intl/de/policies/privacy/
www.google.com/analytics/terms/de.html
www.google.com/intl/de_de/analytics/

 

(4) We use Google AdWords on our websites. Google AdWords is an internet advertising service that allows advertisers to place adverts both in Google's search engine results and in the Google advertising network. Google AdWords allows an advertiser to specify certain keywords in advance, by means of which an advert is only displayed in Google's search engine results if the user uses the search engine to retrieve a keyword-relevant search result. In the Google advertising network, the adverts are distributed to relevant websites using an automatic algorithm and taking into account the previously defined keywords.

 

The purpose of Google AdWords is to advertise our website by displaying interest-relevant adverts on the websites of third-party companies and in the search engine results of the Google search engine and by displaying third-party adverts on our website.

 

If a data subject reaches our website via a Google advert, a so-called conversion cookie is stored on the data subject's IT system by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages, such as the shopping basket from an online shop system, have been accessed on our website. The conversion cookie enables both us and Google to track whether a data subject who has reached our website via an AdWords ad has generated sales, i.e. completed or cancelled a purchase.

 

The data and information collected through the use of the conversion cookie is used by Google to compile visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimise our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could be used to identify the data subject.

 

The conversion cookie is used to store personal information, such as the websites visited by the data subject. Each time our website is visited, personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.

 

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used can also prevent Google from setting a cookie on your device (e.g. computer, notebook, tablet). In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programmes.

 

Furthermore, the data subject has the option of objecting to interest-based advertising by Google. To do this, the data subject must call up the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.

Storage period

We generally only store your personal data for as long as is necessary for the purposes for which it was collected in accordance with this privacy policy. However, we may be legally obliged to store certain data for a longer period of time. In this case, we will ensure that your personal data is treated in accordance with this privacy policy for the entire period.

Your rights

(1) You have the right to request information from us at any time and free of charge about the personal data we have stored about you, as well as its origin, recipients or categories of recipients to whom this personal data is passed on and the purpose of storage.

(2) You also have the right to request that we rectify, erase or restrict the processing of your personal data at any time. You also have the right to data portability.

(3) You also have the right to object to the processing of your personal data by us at any time.

(4) If you have given us your consent to use your personal data, you can revoke this at any time without giving reasons.

(5) If you wish to assert the above rights, please contact us at the address given in paragraph 1.
 

Data Security

We maintain up-to-date technical measures to ensure data security, in particular to protect your personal data from risks during data transmission and from third parties gaining knowledge of it. These measures are adapted in line with the current state of the art.

Changes

As part of the technical development of our range of services and the legal framework, we will also continuously adapt our privacy policy. To this end, changes to the privacy policy will be published on our website. Please therefore regularly read the current version of this privacy policy. Subject to the applicable legal provisions, all changes to the privacy policy will enter into force as soon as the updated privacy policy is published.