PRIVACY POLICY & COOKIE POLICY
I.PRIVACY POLICY
The privacy practice of collecting and processing of personal data provided by the Clients to PI Digital AG, legal
entity duly incorporated in Swiss Confederation with registered number CHE-155.913.212 is described hereby. The
provisions of this Privacy Policy are subject to Regulation (EU) 2016/679 of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and
on the free movement of such data (“Regulation”) and the Federal Data Protection Act of 19 June 1992 (Swiss
Confederation).
INTRODUCTION
We understand the importance of your privacy protection and personal data and commit a lot of efforts to develop
and maintain high standards of inner security measures and technologies to provide you with secure processing and
storage of the data we collect from you; and keep your data safe against unauthorized or unlawful processing and
against accidental loss, destruction or damage.
1. PERSONAL DATA WE COLLECT AND OBJECTIVE
1.1. When applying as a customer of PI Digital AG we collect and further process the following categories of data:
(a) Information requested during your application as a customer, for example your name, date of birth,
citizenship, etc.
(b) Financial information, including your income, source of income / funds, taxation residence information, etc.
(c) Your identity and residency verification documents, for example passport and/or ID card, utility bill, etc.
(d) Contact information, i.e. your phone number, e-mail address, etc.
1.2. We are obliged by applicable laws to maintain records of personal data for ten years after the termination of
a client relationship, this term may be extended upon request by the local competent authority.
1.3. We collect and process the abovementioned data to fulfil our contractual obligations and legitimate interest
before you, namely:
(a) provide services, including individual portfolio management and related maintenance of the services you
registered for and manage the account you hold with third parties;
(b) provide you with the information about activities within your account;
(c) inform about any changes and updates to the services you are provided with;
(d) assess and mitigate risks related to anti-money laundering and terrorism financing regulations as well as
transaction related risks;
(e) comply with applicable legislation;
(f) maintain actions in relation to legal claims;
(g) provide additional or supportive services, as well as perform Client surveys and statistical analysis;
(h) convey marketing activities;
(i) improve the performance and functionality of our services.
The above list may be extended depending on the development of the services.
2. PROCESSING OF YOUR PERSONAL DATA
2.1. Your personal data may be received and processed:
(a) by PI Digital AG within our inner systems of processing, which complies with technical and organizational
measures in a manner that meets applicable requirements of Regulation and security standards; and/or
(b) by 3rd party service providers and processors who access and use the data only to the extent required to
perform the obligations subcontracted to them by PI Digital AG (hereinafter – ‘subprocessors’).
2.2. Those subprocessors perform tasks on our behalf and are contractually obligated not to disclose or use
collected information for any other purposes, than storage, help in facilitation of technical aspects of our
services or perform functions related to the administration of services (collection and analysis) or other
indicated
under contractual closes.
2.3. Client specifically agrees that PI Digital AG may to its own discretion engage subprocessors, that comply
with
technical and organizational measures in a manner that meet applicable requirements of Regulation and security
standards implied under this Privacy Policy.
2.4. If such subprocessors are outside of Swiss Confederation or the European Union or European Economic Area, the
processing of personal data is done or will be done in accordance with the applicable laws.
2.5. Subprocessors remain fully liable for all obligations subcontracted to, and all acts and omissions of, PI
Digital AG is not responsible if the information is disclosed as a result of a breach or security lapse at any
such
subprocessors, or for such subprocessors' non-compliance with the foregoing requirements.
3. INCIDENTS NOTIFICATION
3.1. If PI Digital AG becomes aware of any breach of our security leading to the accidental or unlawful
destruction,
loss, alteration or unauthorized disclosure of, or access to (excluding unsuccessful attempts or activities)
personal data of Clients on systems managed or otherwise controlled by us we will notify you promptly and without
undue delay and in compliance to the procedure prescribed under respective Regulation.
3.2. The notification will be sent to your e-mail address at the discretion of PI Digital AG or by other direct
communication channel available to PI Digital AG and allowed by Client (for example, by phone). It is sole
responsibility of the Client to provide us with the e-mail address and ensure that this e-mail address is valid
and
active.
3.3. None of Data Incidents notification from PI Digital AG may not be and will not be construed as an
acknowledgment of any fault or liability with respect to data incident by us.
4. CLIENT’S SECURITY COMMITMENTS
4.1. Client agrees that without prejudice to our security measures and data incidents that it is Client’s
responsibility to make appropriate use of our services to ensure a level of security appropriate to the risk in
respect of your personal data and securing your authorization credentials, system and devices which you use to
access our services.
4.2. We are not obliged to protect your personal data that you choose to store or transfer outside PI Digital AG
and
our subprocessors’ systems.
5. CLIENT’S RIGHTS IN RESPECT TO HIS PERSONAL DATA
5.1. You may access and amend your personal data, request the details about purposes of processing of your
personal
data and prevent undesirable marketing activities by opting-out. If you wish to opt-out of marketing activities,
use
‘unsubscribe’ option available within our e-mails.
5.2. Client may also send a request to receive the information which has been processed, amended, deleted or
locked
and information about any parties to which we transmit your personal data.
5.3. In some cases we may charge a fee (based on our reasonable costs) if the requests are excessive considering
the
nature of the request itself or nature and functionality of our services.
6. COOKIE & SIMILAR TECHNOLOGIES
6.1. We also use cookies and similar technologies for collecting technical information, which contains your unique
identifiers. We automatically receive the web address of the site that you came from and the IP address of the
computer or device that you are using to access the PI Digital AG website. This information helps us to understand
your preferences, improve website navigation, allows to develop and improve our services, and better manage our
servers.
6.2. If you prefer to prohibit the usage of cookies, please use your browser settings. Most browsers give you an
ability to manage your cookies or provide you with an “incognito mode” or similar features, which allows you to
not
record your visits and downloads in your browsing and download histories. In this mode any cookies created during
this type of session are deleted after you close all “incognito” windows.
For more details please check our Cookie Policy.
7. CHANGES TO THESE PRIVACY POLICY
7.1. Please note that we may amend this Privacy Policy from time to time at our sole discretion. Therefore, please
check this Privacy Policy for updates. If any significant updates with regard to the data processing terms are
made
here, we will notify you additionally within reasonable time period via e-mail provided by you.
8. CONSENT
By using PI Digital AG website and/or applying to become a customer of PI Digital AG, you consent to the
collection,
processing and receipt of your personal data, as described in this Privacy Policy.
9. CONTACT DETAILS
If you require any additional information or have any further questions concerning this Privacy Policy, please
contact us at [email protected].
II. COOKIE POLICY
A. Cookie is a small text file placed on your computer by websites that you visit.
B. They are widely used in order to make websites work more efficiently, as well as to provide information about
functionality and behavior of the users on the site.
C. Cookie helps you to better interact with a website and helps a website to better interact with you.
D. Cookie does not contain your personal data.
1. We use cookies, tags (together - Cookie) to:
(a) understand how you use website and to provide you with a safe, effective and user-friendly website;
(b) remember your settings, such as preferred language, type of the device, news already shown to you, your
preference about Cookie allowance;
(c) keep opened sessions and conversation during your last visit to the website;
(d) identify the popularity of different sections of the website and improve them respectively;
(e) prevent and exclude unauthorized use of the website.
2. We normally do not associate your account with your Cookie, however in exceptional cases we may use this option
to prevent or avoid unauthorized use of the website and violation of applicable agreements between you and us. In
this case we will treat this information as personal and process as described in the Privacy Policy.
3. We use third party web analytics services that assist us in better understanding of our website use, those
services are complied with the prescribed adequacy of security measures. For example, we use Google Analytics
service powered by Google LLC (US). This service helps us to improve the effectiveness of our advertising efforts
and understand your preferences and interests. It collects information and reports website usage statistics
without personally identifying you – we use it for better delivery of our ads. Please check the details about
Google Analytics services here: https://policies.google.com/technologies/partner-sites. However, in some cases
Google can match information collected through Cookie with your Google account and use it under Google Privacy
Policy explained here: https://policies.google.com/privacy.
4. If you do not want to share your Cookie you may restrict it or block it.
4.1. If you prefer not to allow cookies, please use your browser settings, but most browsers give you an ability
to manage your cookies or provide you with “incognito mode” or similar options. For more information about how to
disable cookies completely or how to amend your cookie settings check http://www.allaboutcookies.org/. If your
browser settings do not give you an ability to block or restrict cookies, then you need to leave the website.
5. We also use similar technology and collect unique identifiers of our visitors of the website, the information
we collect by this means includes:
(a) Unique identification numbers, e.g. Internet protocol (IP) address and device ID;
(b) Your login information;
(c) As applicable to your type of device, browser type and version, and browser plug-in types and versions,
application release and version, device model, manufacturer (brand), operating system, operating system version,
OS library version, time of last seen, enable Wi-Fi, radio (EDGE, HSDPA, LTE, WCDMA, none), device screen (width,
high, dpi), NFC, telecom operator, Bluetooth enable, Bluetooth version;
(d) Time zone setting, city, region, country and language;
(e) Operating system and platform;
(f) Information about your visit, including the full Uniform Resource Locators (URL) click stream to, through and
from our website (including date and time); products you viewed or searched for; page response times, download
errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and
mouse-overs), and methods used to browse away from the page.
5.1. We use this information for the same purposes as a Cookie.