Last update: 06.18.2022

The Clés group and its subsidiaries (hereinafter «Cles.la» or «we») welcome you to our website, our mobile applications and other services provided electronically (hereinafter collectively «Electronic Services») and thank you for your interest in our products and services.

Cles.la attaches great importance to proper data protection. This page explains how we process your personal data in connection with your use of our Electronic Services (hereinafter «Privacy Policy»).

By continuing to use Cles.la Electronic Services, you confirm that you are over 18 years of age. Please note that we may change this Privacy Policy from time to time. The applicable version is always the most recent, as indicated above with the legend «Last Updated».

Purpose and scope of the Privacy Policy

It is important to us to protect your privacy and treat the information of all users of our Electronic Services in accordance with applicable laws. We understand that by using our Electronic Services, you may entrust us with personal information («data»), and we assure you that we take our duty to protect this data very seriously. Thus, this Privacy Policy explains the type of data we process when you use our Electronic Services, the purpose for which we process it, how we process it, to whom we may disclose it, and the security measures we take to protect it..

This Privacy Policy applies to all data we obtain when you use our Electronic Services. It does not apply to data we obtain through other channels or to third-party electronic services (hereinafter «Third-Party Electronic Services»), even if you access it through a link on our Electronic Services, and even if are necessary for the operation of our Electronic Services. We have no control over the content or privacy policy of Third Party Electronic Services, and we assume no liability in connection with them.

Processed data types

When you use our Electronic Services, our administrative systems may automatically record details of your use (such as your IP address, your browser, the http header user agent, information specific to your device, the content you accessed, including date and time). access time, usage and user interaction information, and the website that referred you to our Electronic Services). We also process personal data such as your name, postal address, email address, telephone number, date of birth, gender and other data that we receive if you register to use our Electronic Services or fill out a registration form. or a comment field to receive a newsletter, product demos, etc.

Purpose and legal grounds of data processing

We process data on the basis of the following legal grounds:

• to enter into a contract to which you are a party or to take, at your request, steps prior to entering into a contract
• to comply with a legal obligation to which we are subject
• to defend our legitimate interests
  

We process data for the following purposes:

• to comply with internal bank guidelines
• to check the identity of customers and their suitability for certain products and services
• to build a future information base on the services and products offered by Cles.la and improve their quality
• to facilitate technical administration, research and further development in connection with the Cles.la Electronic Services
• to ensure the security and operation of our computing environment
• to use them in marketing and advertising measures (for example, email newsletters and online advertising)
• to analyze and monitor usage, user behavior and navigation while using the Electronic Services
• to facilitate customer management

We process all your personal data in accordance with applicable data protection laws and for the required period.

Disclosure of data related to the use of Electronic Services

Cles.la only discloses data related to the use of Electronic Services to third parties to the extent permitted by law, if it is legally obliged to do so or if such disclosure is necessary to assert its rights, in particular to assert claims arising from a contractual relationship. Within the framework of these purposes and in order to optimize our products and services, we may transfer data within the Cles.la group between group companies in Switzerland or abroad. In addition, we may disclose data to third-party service providers if necessary to provide our products and services. Such service providers may not use the data for any purpose other than to process the order in question. All the persons and entities mentioned above that may receive data must observe the applicable national and international data protection laws, as well as the data protection regulations of Cles.la

When so prescribed by applicable law, Cles.la may, upon request or if required to provide information, disclose data to surveillance authorities, judicial authorities or other authorities.

Security measures of Cles.la

Cles.la will make every effort to take technical and organizational security measures to ensure that your personal data processed within the computer environment controlled by Cles.la are protected against unauthorized access, misuse, loss and/or destruction, taking into account account the current legal and regulatory requirements.

Cles.la adopts physical and electronic security measures adapted to each process, such as firewalls, personal passwords and encryption and authentication technologies. Our employees and the service providers we hire are bound by professional secrecy and must comply with all provisions relating to data protection..

In addition, access to personal data is limited exclusively to employees, contractors and third parties who need access to them to carry out the processing of the data and the provision of products and services (principle of legitimate need for access to data)..

Data transmission over an open network

Cles.la wants to take this opportunity to draw your attention to the fact that if you use our Electronic Services over an open network, this could allow a third party (e.g. an app store, a network provider or the manufacturer of your device) to access and process your data, regardless of where you are. Open networks are outside the control of Cles.la and therefore cannot be considered secure environments. No data transmission over such an open network can be guaranteed to be secure or error-free, as data could be intercepted, modified, corrupted, destroyed, monitored, lost, late, incomplete, or contain virus. In particular, data sent over an open network could leave the country - even if the sender and recipient are in the same country - and could be transmitted and processed in other countries where data protection requirements the data is less strict than in your country of residence.

If data is transmitted over an open network, we are not responsible for the protection of this data and assume no responsibility for the security of your data during transmission. Therefore, we suggest you avoid transmitting sensitive information over open networks.

Cookies

Cles.la Electronic Services use cookies for statistical purposes, as a tool for our web developers and to improve the user experience. Cookies are small files that are stored on your electronic device to keep track of your visits to the Electronic Services and your preferences as you move from one page to another, and sometimes to save your settings between visits. Cookies help the creators of Electronic Services to gather statistics about how often users visit certain parts of the site and help tailor the Electronic Services to make them more useful and user-friendly.

Please note that most browsers automatically accept cookies. You can set your browser not to save any cookies on your electronic device, to save only some cookies, or to always display a warning before receiving a new cookie. However, disabling cookies may affect your ability to use certain features of our Electronic Services.

Remark: in the case of some Electronic Services, cookies persist only during the user's session and are deleted when it ends.

Analysis tools

We use various third-party analytics tools, such as Google Analytics, to create reports on the Electronic Services. This involves the creation of pseudonymized data and the use of cookies to help analyze how users use our Electronic Services. The information about the use of the Services that is generated from these cookies, such as:

• the host name of the electronic device from which it is accessed (masked IP address)
• the type and version of the browser used
• The operating system
• the referring URL (the website that redirects visitors to the Cles.la Electronic Services when they click on a link)
• the date and time of the server request
• device specific information

could be transmitted to third-party servers located in countries outside the European Union and is used for analysis purposes.

For information on how to delete cookies, see the section above, «Cookies».

Links

Cles.la Electronic Services may contain links to third-party Electronic Services that we do not manage or monitor. Please note that such Third Party Electronic Services are not subject to this Privacy Policy and that Cles.la is not responsible for its content or its principles regarding the handling of personal data. Therefore, we recommend consulting and verifying the privacy policies or terms of use of each of the Third Party Electronic Services.

Rights of the interested party

In accordance with current data protection laws and regulations, you may have the following rights:

• Right to request information about the personal data we hold about you
• Right to request that information be rectified if it is incorrect
• Right to request that your data be deleted if the Bank does not have permission or legal obligation to keep it
• Right to demand that the processing of your data be restricted
• Right to object to us processing your data
• Right to have the data transmitted in a structured, commonly used and machine-readable format

You may also have the right of appeal (to the extent applicable) to the Data Protection Supervisory Authority.

Questions and contact

If you have questions regarding the processing of your personal data, please do not hesitate to contact us:

Clés
+1 (786) 422-955825
info@cles.la