1. Scope and responsibility
This Privacy Policy provides information on how and why Liberty Foundation for 3a Retirement Savings and Liberty Foundation for Vested Pension Benefits (hereafter referred to as “we” or “Foundation”) process the personal data which you (hereafter referred to as “you” or “Client”) disclose to us in connection with the use of Coop Finance+ (via website or mobile app, collectively referred to hereafter as “Coop Finance+") or that we collect from you through the pension agreement concluded between us through Coop Finance+. “Personal data” means all data and information relating to an identified or identifiable natural person.
We process your personal data in compliance with the requirements of the Swiss Federal Data Protection Act (hereafter “FADP”) and the relevant federal pension rules and regulations.
For data processing with regard, for example, to registration with Coop Finance+ or in connection with the use of products and services offered by providers other than us via Coop Finance+, the privacy policies of the relevant providers apply. The privacy policies of these providers are available on the Coop Finance+ website or in the Coop Finance+ app.
The party responsible for processing your personal data in accordance with this Privacy Policy is the Foundation with which you correspond or do business, or which has referred you to this Privacy Policy in connection with an inquiry, contract or other correspondence.
The name and address of the Foundation responsible for processing the personal data are the following:
Liberty 3a Retirement Savings Foundation or Liberty Foundation for Vested Pension Benefits
c/o Liberty Pension Ltd.
Steinbislin 19
6423 Seewen SZ
For all questions and concerns regarding data protection, irrespective of the Foundation responsible for processing your personal data, please contact:
Liberty Pension Ltd.
Steinbislin 19
6423 Seewen SZ
Phone: +41 (0)58 733 03 03
email: info@liberty.ch
2. Data sources and data categories
The personal data which we process is primarily that which you have provided to us or which we have collected from you in connection with your use of Coop Finance+ (e.g. during registration, product configuration, risk profiling, selection of pension type, choice of investment strategy, conclusion of contracts, etc. or through the Coop Finance+ infrastructure, etc.). We may also process your personal data that we receive from other companies offering products or services in connection with Coop Finance+ (e.g. Coop Genossenschaft, Basel, and other companies in the Coop Group, Glarner Kantonalbank, Glarus, Vanguard Asset Management Ltd, London UK, insurance providers, etc.) or with whom we have other business relationships (e.g. cooperation partners, etc.). If you provide us with personal data relating to third parties (e.g., your family members), we hereby ask you to provide these persons with this Privacy Policy prior to, or at the latest within one month of, providing us wih the data.
The personal data processed under this Privacy Policy varies from case to case and includes notably:
- contact and contract data, in particular address, email address, telephone number, nationality, social security number (AHV), language of correspondence, language of documents, US persons status, contract status (e.g. termination);
- particulars of your risk profile, namely employment status, age, investment period, expenses, salary/income, assets, risk tolerance;
- particulars relating to your personal circumstances such as date of birth, marital status, date of marriage, number of children;
- identification data, in particular a copy of your passport/ID;
- product data, in particular information about the products and services you have selected within the framework of Coop Finance+;
- financial and pension data, in particular transfer amounts, retirement and pension assets, pension fund affiliation, account balance, lumpsum withdrawals;
- information about adult protection measures, e.g. guardianships;
- information for processing of pension cases, e.g. information on disability, health, retirement, death, encouragement of home ownership;
- tax residence and any other taxrelevant documents and information;
- mortgage processing information (e.g. tax returns, salary data, marital status);
- bank account details;
- records of telephone calls between you and the Foundation if applicable;
- marketing data concerning, such as needs, wants and preferences;
- technical data such as internal and external identifiers, business numbers, IP addresses, records of access or changes;
- information of any kind relating to correspondence, contacts, and interactions with us.
3. Processing purposes and legal basis
3.1. In general, as part of the services and products offered through via Coop Finance+
We process your personal data primarily to fulfill our legal and contractual obligations, but also for marketing and other purposes. Specifically, we may process your personal data for the following purposes:
- to communicate with you, in particular to provide you with information or to process your requests. If you contact us by email/contact form, you authorize us to reply to you via the same channel. Please note that unencrypted emails are transmitted via the open internet and may therefore be viewed, accessed and manipulated by third parties. We therefore ask you not to send us any confidential information by email. To the extent permitted by law, we decline any liability in connection with such unencrypted messages;
- to provide you with our services, namely for account opening procedures, execution, settlement and management of the business relationship with you and your chosen investment products (e.g. identification, application assessment, product configuration, risk profiling, selection of pension provision, determination of investment strategy, payments, invoicing, accounts, investments, pension coverage, succession and insurance, client service, communication);
- to monitor, evaluate and improve our services and products and your use of them (e.g. statistics, planning and product development, service and product usage metrics, capacity metrics, transaction analysis, developing ideas for new services, assessing, improving and reviewing existing services, investment products, processes, technologies and systems);
- to conduct marketing and market research, to provide you with comprehensive support and service, guidance and information about new products and services (e.g. via direct marketing, printed and online advertising, client events, sponsorship, competitions, client satisfaction surveys, future customer needs or behavior or assessing customer, market or product potential);
- to synchronize your contact and contract information with other providers within Coop Finance+ and to correct errors;
- to monitor and manage risks;
- for IT security measures (such as network and mail scanners, phone records);
- to assert legal claims and take legal action in case of disputes, and for official proceedings;
- to comply with our legal obligations at home and abroad;
- for any other purposes of which you shall be duly informed.
Depending on the products and services we provide to you or the purpose for which we process your personal data, data processing is based on one of the following grounds:
- processing is necessary for the fulfillment of a contract with you;
- you have given your consent to the processing of your personal data;
- your personal data may be processed based on a legal basis, notably the Federal Act on Occupational Retirement, Survivors' and Disability Pension Plans, the Federal Act on Vesting in Occupational Retirement, Survivors' and Disability Pension Plans and the relevant ordinances;
- processing is necessary for the fulfillment of a legal obligation;
- processing is necessary to protect the vital interests of the data subject or of another natural person; or
- we have an overriding legitimate interest in processing your data.
3.2. When visiting our website
When visiting our website, the server collects user information which is temporarily stored in the server's log files. The information collected includes, among other things, the IP address, date and time of access, time zone difference from the GMT time zone, name and URL of the file accessed, the website from which access was made, the browser and operating system used.
When using this general information, no assignment to a specific person takes place. The collection of this information is technically necessary to display our website and to ensure its stability and security. This information is also collected to improve the website and analyze its use.
3.3. Contact form
To contact us, you may use the form provided on our website. The personal data you provide to us is stored and processed for the purpose of responding to your request.
3.4. Newsletter
If you subscribe to our newsletter, we will use your email address and other contact data to send you the newsletter. By subscribing to our newsletter, you consent to the associated processing of your personal data. Mandatory data for sending the newsletter, you must provide your full name and email address, which will be stored after registration. Your consent to the sending of the newsletter forms the legal basis for processing your personal data in connection with the newsletter. You may revoke your consent at any time and unsubscribe from the newsletter. To unsubscribe, click on the link at the bottom of each newsletter or send a cancellation email to info@liberty.ch or a message to the contact address indicated in the imprint.
3.5. Cookies
Our website uses cookies and beacons. Cookies are text files that are stored in the browser or by the browser on the computer system of the user or a mobile device. Cookies contain a characteristic sequence of characters which enables the browser or mobile device to be uniquely identified when the website or app is called up again.
Cookies are used, on the one hand, to enable and simplify the use of our website. Some functions of our website cannot be offered without the use of cookies (required cookies). On the other hand, we also use cookies to analyze user behavior on our website, namely for range management, as well as for marketing purposes.
3.5.1. Required cookies
These cookies are required to enable core site functionality. Therefore, required cookies cannot be switched off in our systems. As a rule, they record important actions such as the number of requests made, the processing of your privacy settings or the completed forms. You may block these cookies in your browser, this will however impede the functioning of parts of our website.
3.5.2. Analytical and marketing cookies
Analytical cookies allow us to analyze user behavior and traffic sources so we can measure the performance of our website and improve user experience. They help us determine how popular which pages are and show us how users navigate our website. The information collected is aggregated and remains anonymous.
Marketing cookies enable us to deliver advertising that is relevant to your interests. These cookies may remember that you have visited our website and share this information with other companies and advertisers.
You can find a list of the specific analytical and branding cookies used on our website here:
- Google Analytics of Google Ireland Ltd., Ireland (hereafter «Google»). See the privacy policy of Google Analytics here: https://policies.google.com/privacy?hl=en;
- Google Remarketing. See the privacy policy of Google Remarketing here: https://policies.google.com/privacy?hl=en;
- Google Optimize. See the privacy policy of Google Optimize here: https://policies.google.com/privacy?hl=en;
- Google Tag Manager. See the privacy policy of Google Tag Manager here: https://policies.google.com/privacy?hl=en;
- Google Ads Conversion Tracking. See the privacy policy of Google Ads Conversion Tracking here: https://policies.google.com/privacy?hl=en;
- Google AdSense. See the privacy policy of Google AdSense here: https://policies.google.com/privacy?hl=en;
- PageSense of Zoho Corporation, India (hereafter «Zoho»). See the privacy policy of PageSense here: https://www.zoho.com/privacy.html;
- SalesIQ by Zoho. See the privacy policy of SalesIQ here: https://www.zoho.com/privacy.html;
- ZOHO Marketing Automation. See the privacy policy of ZOHO Marketing Automation here: https://www.zoho.com/privacy.html;
You may block the use of cookies by (i) activating the relevant settings in your browser; (ii) using cookieblocking software (e.g. Ghostery); or (iii) downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
4. Disclosure of personal data to recipients and abroad
4.1. Disclosure of personal data to recipients
In addition to data transfers to designated recipients under this Privacy Policy, we may disclose personal data, insofar as permitted to the following categories of recipients:
- Liberty Pensions Ltd as the management company of the Foundations;
- providers, suppliers and subcontractors to whom we have outsourced certain services or from which we procure certain products (e.g. IT and outsourcing providers);
- companies that operate the Coop Finance+ platform and mobile application;
- companies offering products or services within the scope of Coop Finance+ (e.g. Coop Genossenschaft, Basel, and other companies of the Coop Group, Glarner Kantonalbank, Glarus, Vanguard Asset Management Ltd., London UK, banks and asset managers, insurance providers, etc..);
- domestic and foreign authorities, agencies or courts, in particular as part of our legal obligations.
4.2. Disclosure of personal data abroad
We generally store and process your personal data in Switzerland as well as in the member states of the EU/EEA, EFTA, the United Kingdom (UK) and, in connection with the use of cookies, in the USA, and under certain circumstances in other countries worldwide.
If we transfer data to a country without adequate legal data protection, we ensure an adequate level of protection as provided by law through means of contracts (containing standard FDPIC-approved data protection clauses), or rely on legal exceptions of consent, the execution of contract, exercise or enforcement of legal claims, overriding public interests, published personal data, or because it is necessary to protect the privacy of the data subjects.
5. Terms of storage
We process and store your personal data only as long as necessary according to the relevant processing purpose or another legal basis (e.g. statutory retention periods). We retain personal data deriving from the contractual relationship with you at least for the duration of the contractual relationship and the limitation periods for the assertion of claims, or for the duration of the contractual retention obligations. As soon as your personal data is no longer required for the abovementioned purposes, it will be rendered passive, deleted or anonymized.
6. Your rights
In the context of the applicable data protection legislation and insofar as provided therein, you have the right to information, correction, deletion, the right to restrict or object to our data processing and the right to data portability (i.e. the right to receive your personal data in a form appropriate for transmission to another controller). Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (to the extent we may rely on such interest), or need the data for the purpose of enforcing claims.
If data processing is based on your consent, you may revoke such consent at any time after it is given with effect for the future. This does not affect the lawfulness of the processing carried out based on prior consent.
To exercise such rights, you are usually required to prove your identity (e.g. by means of a copy of your ID card if your identity is not otherwise clear or cannot be verified). To exercise your rights, contact us at the address indicated in Section 1 of this Privacy Policy.
Every data subject is also entitled to enforce their claims in court or to file a complaint with the competent data protection authority. For the Foundation, the competent data protection authority is the Federal Data Protection and Information Commissioner ("FDPIC") (https://www.edoeb.admin.ch/edoeb/en/home.html).
7. Data security
We take technical and organizational measures to safeguard your personal data from unauthorized access, misuse, loss and destruction. In this regard, we use firewalls, authorization concepts, conduct regular IT security audits and have implemented additional protective measures to ensure that personal data is protected as comprehensively as possible.
8. Amendments to Privacy Policy
We expressly reserve the right to amend this Privacy Policy at any time. If such an amendment is made, the amended Privacy Policy will be published immediately on our website. The valid version of the Privacy Policy at any time is the one published on our website.
September 2023
