Privacy Policy

At SUISSE BANK PLC we recognise the importance of personal information entrusted to us. It is one of our fundamental responsibilities as a bank to ensure that we protect the information entrusted to us by our clients and our website visitors. Please find below select security measures we established to protect your privacy.

Why does SUISSE BANK PLC collect personal information?

We collect, process, and use personal information on our websites in order to offer you even better products and services, best adapt our business processes to our clients’ needs, and steer you to the most suitable product information and online banking applications.

This Privacy Policy also explains how we process 'personal data' about people in the European Union (EU), as required under the General Data Protection Regulation (GDPR).

We will review this policy regularly, and we may update it from time to time.

The types of personal information we collect and hold

We collect personal information about our users in order provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect.

Not all information requested, collected, and processed by us is “Personal Information” as it does not identify you as a specific natural person. This will include majority of “User Generated Content” that you provide us with the intention of sharing with other users inside a transaction. Such “Non-Personal Information” is not covered by this privacy policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such, this privacy policy will list both types of information for the sake of transparency.

In some situation users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the user will have bypassed our systems, processes, and control and thus the information provided will not be governed by this privacy policy.

In some situations, users may provide us personal information over platforms that are outside our control; for example, through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.

How we collect personal information and how long is it retained

Information collected on our website will only be retained for as long as necessary to fulfil the purpose for which it was collected. If you wish to access or correct any information SUISSE BANK PLC holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). You have the right to access the personal information we hold about you; this service is free of charge.

SUISSE BANK PLC is constantly aiming at enhancing its website. For this reason, we collect information through the website in an anonymised form, i.e. domain name, tracking the pages you visit and how long. The respective information is used for statistical and marketing purposes only and is not disclosed to third parties.


-    Information that you specifically give us

While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.

We may request, collect, or process the following information:

  • Account Details - password
  • Contact Details - email address, phone number
  • Location Details - physical address, billing address, time zone
  • Identity Details - full name, proof of identity (e.g. drivers licence, passport), proof of address (e.g. utility bill)
  • Financial Information - credit card details, wire transfer details, payment processor details, tax numbers
  • User Generated Content - transaction descriptions, transaction attachments

-    Information that we collect from others

Users have the ability to start a transaction with non-users by providing contact details such as email address, physical address, and phone number. In these situations, the information will be collected and stored by us to contact the non-user and to prevent abuse of our systems.

Your payment provider may transmit information about the payment that we may collect or process.

In some situations, personal information of users may be collected from public sources.

We may collect or process the following information:

  • Contact Details - email address, phone number
  • Location Details - Physical Address, billing address, time zone
  • Financial Information - transaction details, wire transfer details
  • User Generated Content - transaction description

Our partners may create transactions on your behalf, in these situations the information that can be provided is the same as the information we may request, collect and process from individual users. Whilst our partners platforms will be governed by their own privacy policy, any personal information that is transferred to our platform will be treated and protected as though it was submitted by a user.

How information is retained and protected

Information input collected through this website will be transferred to the responsible SUISSE BANK PLC division. Banking secrecy as well as confidentiality are maintained. Data will not be transferred to third parties, unless necessary to answer your queries (i.e. leaflets dispatched by vendors). Your information is used to exclusively fulfil the purpose for which it is collected, relating to the website through which it is collected.

Websites through which we collect your information are usually encoded using the encryption module of your browser. These sites are certified by renowned institutions for international encryption technique, analogous to SUISSE BANK’s Online-Banking. Moreover, SUISSE BANK PLC put in place additional and comprehensive state-of-the-art security measures when both accounts and custody accounts are accessed via the Internet. Firewalls prevent unauthorized access. Diverse encryption and identification layers protect customer information from intrusion or disclosure to third parties during data transfer. Furthermore, SUISSE BANK PLC internally uses sophisticated encoding methods in order to prevent de-coding by unauthorised persons. Moreover, an electronic identifier is generated during data transfer to safeguard your information.

-    Information we collect as you use our service

We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.

When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.

We may collect or process the following information:

  • Metadata - IP address, computer and connection information, referring web page, standard web log information, language settings, time zone, etc.
  • Device Information - device identifier, device type, device plugins, hardware capabilities, etc.
  • Actions - pages viewed, buttons clicked, time spent viewing, search keywords, etc.

-    Links to other sites

On our website, you will encounter links to third party websites. These links may be from us, or they may appear as content generated by other users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.

Cookies

In view of the importance of data privacy, and our obligations of transparency, we provide information below about cookies, how we use them on our website and what options you have if, despite the benefits they bring, you prefer to disable them. We will assume you agree to accept the cookies that we use on our website if you do not disable or opt out of them as described below.

-    What are cookies?

Cookies are small text files. They are commonly downloaded to your computer or mobile device by websites that you visit. They enable the website to tag your device and recognize it as you move around the site (and potentially when you return at a later date) so that, for example you do not have to re-enter your password each time you move between pages of the website.

-    Terminology

When trying to understand cookies, and how to control them, it can help to know some terminology:

  • Cookies installed on your device by the organization running the website you are visiting are known as “first party” cookies.
  • Cookies installed on your device via the website you are visiting by another organization are termed “third party” cookies. An example is a cookie set by a specialist website analytics company that provides the website owner with data on the numbers of people visiting its website.
  • So-called “persistent cookies” remain on your device even after you close your internet browser. They are activated each time you visit the website that created that particular cookie. For example, where a "persistent cookie" is used on a website to remember your login details, you will not need to enter those details each time you visit that website.
  • Session cookies, by contrast, are temporary and are typically used to enable the website to operate, e.g. by permitting a user to move from page to page without having to log in again. Once you close your browser, all session cookies are deleted.

-    What cookies do we use?

To enhance user experience, this website uses ‘persistent’ and ‘session’ cookies for the purposes described below. These cookies are generally ‘first party’ cookies, but may also be ‘third party’ cookies.

  • Website functionality

Cookies that are essential for our website to function technically or which provide a service or option that you have requested. For example, a cookie that “remembers” your authentication details so you can remain logged into secure internet banking facilities, or a cookie that remembers the country or language you have selected.

  • Website performance analysis

Cookies that help us improve our website by providing us with aggregate statistics on how many users visit it, which parts of the site are viewed the most, and the city or regional location of those users. These may be installed by a third-party analytics provider under a contract with us. These cookies do not identify you personally. Nevertheless, if you prefer to opt out of such analytics cookies, you may do so here: “Opt Out” and a cookie will be stored under this name. No information is collected as long as the cookie is stored in your browser. Please keep in mind that – as soon as the cookie is erased – the Opt Out for SUISSE BANK’s website is disabled and must be renewed.

Currently, Opt Out is not active: tracking information is being collected on this computer.

  • Interest-based targeting

In order to be able to provide you with the most relevant information about our products and services, we use cookies to be aware of which content you have viewed on our website.

We may also use this information for the purposes of our advertising campaigns on third party websites. In that case, we may also receive information about the websites of our marketing partners on which you saw our advertisements. Similarly, third parties may display their advertisements on our website and they may become aware that you have visited our website. If you prefer to opt out of this, and receive advertisements that may be less relevant to your interests, you may do so here: “Opt Out” and a cookie will be stored under this name. No information is collected as long as the cookie is stored in your browser. Please keep in mind that – as soon as the cookie is erased – the Opt Out for SUISSE BANK’s website is disabled and must be renewed.

Currently, Opt Out is not active: tracking information is being collected on this computer.

-    How to control cookies

As explained above, cookies help you to get the most out of our website. If you decide to disable cookies, you may find that certain aspects of our website do not work as expected.

Aside from any specific opt-outs we have provided above, if you do not wish to receive cookies you can set your web browser to disable cookies. Note that most browsers offer different levels of privacy, such as allowing first party cookies but blocking third party cookies, or notifying you each time a website wants to install a cookie. Be aware that disabling cookies in this way will prevent new cookies from being set, but will not stop previously set cookies from operating on your device unless you delete all cookies in your browser settings. The instructions for managing cookies in your browser can usually be found via the browser’s Help function or in a smartphone manual.

Data privacy notes on social plugins

Our website uses social plugins (“plugins”) from social networking sites such as Twitter, Facebook etc.
If you access a SUISSE BANK PLC website using such a plugin, your browser will contact the server of the underlying social networking site, load the visual presentation of the plugin, and present it to you. While this is happening, the social networking site receives information concerning your visit to our website, as well as further data such as your IP address.
In order to ensure an appropriate level of data privacy in connection with our internet presence, we have deactivated the respective plugins with a button and placed a short data privacy note that can be consulted before a plugin is activated.
We have no influence on the amount of data that social networking sites collect via an active plugin.

When you access this link, you are leaving the SUISSE BANK website. The information provided on any websites accessed through this link has been produced by independent providers and SUISSE BANK PLC does not endorse or accept any responsibility for information provided on any such sites. Any opinions or recommendations expressed on such other websites are solely those of the independent providers and are not the opinions or recommendations of SUISSE BANK PLC. The existence of a link from this SUISSE BANK page to any other such websites does not constitute a recommendation or other approval by SUISSE BANK PLC of such websites or any provider thereof.

For more information, please consult the relevant data privacy notice:
Facebook 
Twitter
Google+

How we use personal information

The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:

  • to provide the service or product you have requested;
  • to provide technical or other support to you;
  • to answer enquiries about our services, or to respond to a complaint;
  • to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);
  • to allow for debugging, testing and otherwise operate our platforms;
  • to conduct data analysis, research and otherwise build and improve our platforms;
  • to comply with legal and regulatory obligations;
  • if otherwise permitted or required by law; or
  • for other purposes with your consent, unless you withdraw your consent for these purposes.

The lawful processing grounds on which we will use personal information about our users are (but are not limited to):

  • when a user has given consent;
  • when necessary for the performance of a contract to which the user is party;
  • processing is necessary for compliance with our legal obligations;
  • processing is necessary in order to protect the vital interests of our users or of another natural person;
  • processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.

When we disclose personal information

-    To other parties in your transactions

We may disclose your personal information to third parties that participate in a transaction with you, including but not limited to:

  • counterparties,
  • brokers; and,
  • affiliates involved in origination of the transaction.

-    Other disclosures and transfers

We may also disclose your personal information to third parties for the following purposes:

  • if necessary to provide the service or product you have requested;
  • We receive court orders, subpoenas or other requests for information by law enforcement,
  • if otherwise permitted or required by law; or
  • for other purposes with your consent.

As we are a global company, with offices around the world, your personal information may be processed by staff in any of our offices. SUISSE BANK PLC currently has offices in the Union of the Comoros and in the United Arab Emirates.

Accessing or correcting your personal information

You have the right to request access to the personal information SUISSE BANK PLC holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.

You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support.

Exercising your other rights

You have a number of other rights in relation to the personal data SUISSE BANK PLC holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, provide protection for the legitimate users, and meet our legal obligations - these data uses are protected against the below rights.

You have the right to:

  • opt-out of direct marketing, and profiling for marketing
  • erasure
  • temporary restriction of processing.

Direct marketing and profiling: Users can unsubscribe by following the link included at the bottom of each email.

Erasure: Most personal information cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protection for users on the platform. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data.

Temporary restriction to processing: Under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer.

Unless stated above, users may exercise any of the above rights by contacting our Privacy Officer.

To contact our Privacy Officer

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end. Please contact us at data.privacy@suissebank.com.