1. Objective and responsible body

This data protection declaration clarifies the type, scope and purpose of the processing (including the collection, processing and use as well as obtaining consent) of personal data within our online offer and the websites, functions and contents connected with it (hereinafter jointly referred to as "online offer" or "website"). This privacy policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) on which the online offer is executed.

The provider of the online offer and the body responsible for data protection is finpension AG, Hirschmattstrasse 36, 6003 Lucerne (hereinafter referred to as "provider", "we" or "us"). For contact details, please refer to the contact information on our website.

The term "user" includes all customers and visitors of our online offer. The terms used, such as "user", are to be understood in a gender-neutral way.

2. Basic information on data processing

We process personal data of users only in compliance with the relevant data protection regulations in accordance with the dictates of data economy and data avoidance. This means that user data will only be processed if a legal permission has been granted, in particular if the data is required for the provision of our contractual services and online services, or if it is required by law or if permission has been granted.

We take organisational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of the data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.

If, within the scope of this data protection declaration, content, tools or other means are used by other providers (hereinafter jointly referred to as "third party providers") and their registered office is abroad, it is to be assumed that a data transfer to the countries where the third party providers are based is taking place. The transfer of data to third countries is either based on a legal permission, a consent of the users or special contractual clauses which guarantee the legally required security of the data.

3. Processing of personal data

The personal data, apart from the uses expressly mentioned in this privacy policy, will be processed only for purposes based on legal permissions or consents of the users.

We only transfer the users' data to third parties if this is necessary to fulfil our contractual obligations to the users. When contacting us (via contact form or e-mail), the user's details are stored for the purpose of processing the enquiry and in the event that follow-up questions arise.

4. Collection of access data

We collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the website previously visited), IP address and the requesting provider.

We use the protocol data without allocation to the person of the user or other profile creation in accordance with the legal regulations only for statistical evaluations for the purpose of the operation, security and optimisation of our online offer. However, we reserve the right to check the log data subsequently if there is a justified suspicion of illegal use based on concrete evidence.

5. Cookies & reach measurement

Cookies are information that is transferred from our web server or web servers of third parties to the web browsers of users and stored there for later retrieval. Users are informed about the use of cookies in the context of pseudonymous range measurement within the scope of this data protection declaration.

It is also possible to view this online offer without the use of cookies. If the users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

It is possible to manage many online advertisement cookies from companies via the US site http://www.aboutads.info/choices or the EU site http://www.youronlinechoices.com/uk/your-ad-choices/.

6. Google Analytics

We use Google Analytics, a web analysis service of Google Inc. ("Google"). Google uses cookies. The information generated by the cookie about the use of the website by the user is usually transferred to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the use of the Internet. The processed data can be used to create pseudonymous user profiles of the users.

The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online service from Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on Google's use of data for advertising purposes, setting and objection options can be found on Google's websites: https://www.google.com/intl/de/policies/privacy/partners ("Data use by Google when you use websites or apps of our partners"), http://www.google.com/policies/technologies/ads ("Data use for advertising purposes"), http://www.google.de/settings/ads ("Manage information that Google uses to show you advertisements") and http://www.google.com/ads/preferences ("Determine which advertisements Google shows you").

7. Google-Re/Marketing-Services

We use the marketing and remarketing services ("Google Marketing Services") of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").

Google's marketing services allow us to display ads for and on our website in a more targeted manner so that users are only shown ads that potentially match their interests. For example, if users are shown ads for products that they are interested in on other websites, this is referred to as "remarketing". For these purposes, when users call up our and other websites on which Google marketing services are active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (instead of cookies, comparable technologies can also be used). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other states which are party to the Agreement on the European Economic Area and only in exceptional cases is it transmitted in full to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google offers. The above-mentioned information may also be combined with such information from other sources. If the user subsequently visits other websites, the ads tailored to his interests can be displayed.

User data is processed pseudonymously within the framework of Google's marketing services. This means, for example, that Google does not store and process the name or e-mail address of the user, but processes the relevant data in a cookie-based manner within pseudonymous user profiles. This means that from Google's point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected by "DoubleClick" about users is transmitted to Google and stored on Google's servers in the USA.

The Google marketing services used by us includes the online advertising program "Google AdWords". In the case of Google AdWords, each AdWords customer receives a different "conversion cookie". Cookies can therefore not be tracked via the websites of AdWords customers. The information collected through the cookie is used to compile conversion statistics for AdWords customers who have opted in to conversion tracking. AdWords customers are informed of the total number of users who have clicked on their ad and been redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

We include third-party ads based on Google's "DoubleClick" marketing service. DoubleClick uses cookies to enable Google and its partner sites to serve ads based on users' visits to this site or other sites on the Internet.

We also include third-party ads based on Google's "AdSense" marketing service. AdSense uses cookies to enable Google and its partner websites to serve ads based on users' visits to this website and other websites on the Internet.

8. Google Tag Manager

Another Google marketing service we use is the "Google Tag Manager", which can be used to integrate further Google analysis and marketing services into our website (e.g. "AdWords", "DoubleClick" or "Google Analytics").

Further information on the use of data for marketing purposes by Google can be found on the overview page: https://www.google.com/policies/technologies/ads, Google's data protection declaration can be accessed at https://www.google.com/policies/privacy.

If you wish to object to the collection of data by Google marketing services, you can use the setting and opt-out options provided by Google: http://www.google.com/ads/preferences.

9. Cloudflare

We use the service "Cloudflare". The provider is Cloudflare Inc, 101 Townsend St, San Francisco, CA 94107, USA (hereinafter "Cloudflare").

Cloudflare offers a globally distributed content delivery network with DNS. This technically routes the transfer of information between your browser and our website via Cloudflare's network. This enables Cloudflare to analyse traffic between your browser and our website and act as a filter between our servers and potentially malicious traffic from the internet. In doing so, Cloudflare may also use cookies or other technologies to recognise internet users, but these are used solely for the purpose described here.

Cloudflare is a certified participant of the "EU-US Privacy Shield Framework". Cloudflare has committed to handling all personal data received from European Union (EU) member states in accordance with the "Privacy Shield Framework".

The use of Cloudflare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 para. 1 lit. f DSGVO).

You can find more information about security and data protection at Cloudflare here: https://www.cloudflare.com/privacypolicy/.

10. Datadog

The functions of the Datadog service are integrated on our platform. Datadog is a monitoring system of the American company Datadog, Inc., 620 8th Ave, 45th Floor, New York, NY 10018 USA. The system notifies our development team about possible errors in the application. Log data is transmitted to Datadog, Inc. for this purpose.

For more information about security and privacy at Datadog, Inc. please visit: www.datadoghq.com/legal/privacy/.

11. Social Plugins

Our online service uses social plugins ("plugins") of social networks. The plugins can be recognised by the logos of the social network providers.

When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the servers of this social network. The content of the plugin is transmitted directly to the user's device by the social network provider and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that social network providers collect with the help of plugins and therefore inform the users according to our state of knowledge.

By integrating the plugins, providers of social networks receive the information that a user has called up the corresponding page of the online offer. If the user is logged on to the social network provider, the latter can assign the visit to his account. The purpose and scope of the data collection and the further processing and use of the data by social network providers, as well as the relevant rights and setting options for protecting the privacy of the users, can be found directly in the data protection information from the social network providers.

Further settings and objections to the use of data for advertising purposes are possible within the profile settings of social networks or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

12. Newsletter

With the following information, we would like to inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.

We collect personal data that you have voluntarily submitted to us, for example when you communicate with us via e-mail or other communication channels or when you ask us to send you notifications, newsletters (client alerts) or other (marketing) information. In certain cases, we supplement your personal data with information that we have found through other sources, such as publicly available data search engines, sector-specific newsletters, social media platforms and via your employer's website, in order to determine/confirm your current role.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with up-to-date information on finpension and about pension or other financial topics. We base this on our legitimate interest in staying in contact and communicating with you as a business partner or client to keep you informed about finpension activities and other news. We assume that our legitimate interests are in accordance with the regulation and your rights.

Dispatch of the newsletter: Newsletters are sent by means of Mailchimp (hereinafter referred to as "dispatch service provider"). The data protection regulations of the dispatch service provider can be viewed here: https://mailchimp.com/legal/privacy/.

The e-mail addresses of our newsletter recipients, as well as their other data described in the context of this notice, are stored on the servers of the dispatch service provider. The dispatch service provider uses this information to send and evaluate the newsletter on our behalf. Furthermore, the dispatch service provider may use this data according to its own information to optimise or improve its own services, e.g. for technical optimisation of dispatch and presentation of the newsletters or for economic purposes to determine the countries from which the recipients come. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.

Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address.

Cancellation/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. Your consent to the dispatch of the newsletter by the dispatch service provider and the statistical analyses will then expire at the same time. Unfortunately, it is not possible to cancel the dispatch separately by the dispatch service provider or the statistical analysis. You will find a link to cancel the newsletter at the end of each newsletter.

13. Integration of third-party services and content

It is possible that within our online offer contents or services of third party providers, such as city maps or fonts from other websites are integrated. The integration of content from third party providers always requires that the third party providers are aware of the IP address of the user, as without the IP address they would not be able to send the content to the user's browser. The IP address is therefore necessary for the display of these contents. Furthermore, the providers of the third-party content may set their own cookies and process the users' data for their own purposes. In doing so, user profiles of the users can be created from the processed data. We will use this content as sparingly and as far as possible to avoid data loss and will select reliable third-party providers with regard to data security.

14. User rights and deletion of data

Users have the right to request information free of charge about the personal data we have stored about them.

In addition, users have the right to correct inaccurate data, withdraw consent, block and delete their personal data and, in the event of suspected unlawful processing, to lodge a complaint with the competent supervisory authority.

The data stored with us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain them stand in the way of deletion.

15. Changes to the privacy policy

We reserve the right to amend the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. Insofar as the consent of the users is required or components of the data protection declaration contain regulations of the contractual relationship with the users, the changes will only be made with the consent of the users.

Users are asked to inform themselves regularly about the content of the data protection declaration.