Privacy policy

Finwise SA (hereinafter “Finwise”) is a company whose head office is located at 28 rue de Carouge, 1205 Geneva – Geneva, Switzerland.

Finwise is committed to respecting your privacy and complying with the provisions of the Swiss Data Protection Act (DPA) and the EU General Data Protection Regulation (GDPR).

This privacy policy describes how Finwise collects, uses, transfers and stores Personal Data (defined below in point 1.1) when using our services (the “Services”) and/or our website (the “Website”) and/or our platform (the “Platform”) and informs you of your rights (hereinafter the “Privacy Policy”). If you have a question or request, please send us an email to the following address: contact@finwise.ch.

This Privacy Policy is in addition to any customer confidentiality obligations we may have to you. Please see our terms applicable to your engagement for more detailed information regarding privacy.

By using our Services and Website, you expressly consent to Finwise collecting and processing your Personal Data (as defined below) in accordance with the provisions of this Privacy Policy.

1. Information we collect

1.1 Personal data

The data collected by Finwise includes all information necessary for Finwise to fulfill all its contractual and legal obligations (“Personal Data”).

Personally identifiable information, including: first name, last name, date of birth, gender, address, email, telephone numbers, nationality, country of citizenship, residence, identity documents. Personal Data includes any document you give us, for example a copy of your passport;

Information on relevant family members and business relationships;

Education, professional qualifications, employment and professional information, references;

Salary and tax data;

Health data;

Bank details;

Information collected by our Website, as described below (see point 1.3).

1.2 Sources

Personal Data is collected at different times and from different sources:

When you or your organization/company contact us to review or request our services;

Information collected by our team as part of contractual obligations;

By e-mail, fax or telephone;

Our Website.

1.3 Cookies, visit tracking and similar techniques

1.3.1 To optimize your experience on the Website, cookies or similar tracking techniques may be used. These are small files saved in the Internet browser and which retain certain information and data in order to exchange them with the Finwise system. They are in no way used to store your Personal Data.

You can refuse the use of cookies in your Internet browser settings. We draw your attention to the fact that by deactivating cookies, you may not have access to all the functionalities of the Website.

1.3.2 The Website uses Google Analytics, a service provided by Google Inc. based in the United States of America. Google Analytics is a tool that analyzes the use of the Website. This tool may use cookies to collect anonymous information and generate reports in Website usage statistics without the User being personally identifiable by Google. The information generated by these cookies (including the user's IP address) may be sent to and stored on Google servers in the United States of America. Google complies with the data protection requirements of the Swiss-US Privacy Shield framework and is registered with the Privacy Shield program of the US Department of Commerce. If the User does not want Google Analytics to record their visit data, they can install an extension on their browser by deactivating Google Analytics.

1.3.3 We also inform you that the Website also uses third-party services such as the aforementioned Google Analytics tool or Mix Panel, Hotjar and others.

By using the Website, you consent to the processing by Google, Google Analytics, Mix Panel, Hotjar and others of the data collected about you in accordance with the aforementioned privacy policy and Google's privacy policy. You acknowledge that Finwise disclaims any liability for this process.

1.3.4 The Website may use social plug-ins for various social networking sites (hereinafter referred to as “Social Network”) such as facebook.com (operated by Facebook, Inc.), twitter.com (operated by Twitter, Inc.) and plus.google.com (operated by Google, Inc.) (hereinafter referred to as “plug-ins”). When the User visits a website that contains plug-ins, the User's browser connects directly to the servers of the Social Network concerned. The content of the plug-in is transmitted directly to the User's browser from each Social Network and is integrated into the Website. By integrating the Plug-in, the Social Network receives the information that the User has visited the Website.

If you are connected to a Social Network, it may associate your visit with the relevant Social Network account. If you interact with the plug-in, the corresponding information from your browser is sent directly to the respective Social Network and stored there.

For further information regarding the purpose and scope of data collection, the processing and use of data by the respective Social Network as well as your rights and ways to protect your privacy, please consult the privacy policy of each Social Network.

2. Why we collect and process your Personal Data

Personal Data collected and processed by Finwise may be used to:

(i) Contact you;

(ii) Identify you;

(iii) Fulfill our contractual obligations towards you or your organisation/company and, in this context, provide relevant information to third parties or authorities;

(iv) Execute administrative or operational processes within Finwise;

(v) Process and respond to requests, questions or complaints received from you or another person within your organization/company;

(vi) Manage and administer your or your organization/company's business relationship with Finwise, including payment processing and invoicing;

(vii) Comply with any legal obligation requiring Finwise to process Personal Data, for example keeping records for legal purposes (tax, corporate law);

(viii) Provide, monitor and improve Finwise Services;

(ix) Send newsletters and promotional materials;

(x) Monitor use of the Website;

(xi) Respond to any requests or fulfill any obligations to public authorities, law enforcement agencies, regulatory bodies and judicial bodies;

(xii) Establish, exercise or defend Finwise's legal rights or in legal proceedings;

(xiii) For any other legitimate business interest or overriding interest of Finwise;

3. Information sharing, access and transfers

3.1 Access via Finwise

Finwise management and employees may access your Personal Data in order to comply with Finwise's contractual and legal obligations.

3.2 Access by third parties, by authorities and public bodies

In order to fulfill its contractual obligations, Finwise must communicate Personal Data to third parties, authorities and public bodies (in particular in tax and insurance matters) in Switzerland, including sensitive data such as your health information if necessary. You hereby consent to such transfers.

3.3 Access by service providers, business partners and other persons

You hereby expressly authorize Finwise to use service providers and delegate certain tasks (such as IT services and infrastructure, server hosting, maintenance and other services) to third parties. In addition, you expressly authorize Finwise to transfer Personal Data to third parties in the event of a merger, sale, liquidation or assignment of all or part of Finwise's assets. This implies that Personal Data may be communicated to such companies outside Switzerland.

In this context, we hereby inform you that certain jurisdictions do not have legislation ensuring an adequate degree of protection within the meaning of the Swiss Federal Data Protection Act. If the User's Personal Data must be shared with such companies and if the other conditions of the LPD and/or the GDPR are not met, Finwise will request your consent.

Under no circumstances will Finwise sell your Personal Data to third parties.

3.4 Compliance with laws in force and requests from authorities; best interests of Finwise

Finwise may transfer Personal Data to third parties such as Swiss or foreign public authorities, law enforcement agencies, regulatory bodies or judicial bodies when such transfer is reasonably necessary to comply with the provisions of the law or a mandatory legal request or to protect an overriding interest of Finwise.

4. Storage and security

Your Personal Data is entered into our electronic systems and paper files processed and stored physically and in electronic form on servers located in Switzerland.

We take all reasonable and necessary steps to ensure that your Personal Data is processed and stored securely in accordance with this Privacy Policy. Finwise implements appropriate administrative, technical and physical measures reasonably necessary to protect the confidentiality, integrity and availability of your Personal Data.

5. Retention of Personal Data

We keep your Personal Data for as long as necessary for the purposes mentioned above, in order to provide our Services and to fulfill our contractual and legal obligations (for example our information and accounting obligations).

If Personal Data is no longer necessary to fulfill our contractual obligations, it will be returned or deleted unless it is necessary to comply with a legal obligation, in particular retention obligations under tax and commercial law. This includes in particular the Swiss Code of Obligations, the Swiss Anti-Money Laundering Law, the Swiss VAT Law and Swiss tax legislation.

Personal Data collected through cookies and other tracking data, analysis data, etc. are stored for 24 hours.

6. Your rights

You have a right of access under article 8 of the LPD (article 15 of the GDPR), a right of rectification when the information we have about you is inaccurate under article 5 of the LPD (article 16 of the GDPR), a right to request the deletion of your Personal Data under article 5 of the LPD (article 17 of the GDPR) or the restriction of the use of your personal information under Articles 12, 13 and 15 of the LPD (Article 18 of the GDPR), a right to object to the processing of your Personal Data under Article 4 of the LPD (article 21 of the GDPR) and, finally, a right to data portability under Article 20 of the GDPR. You can also file a complaint with the competent data protection authority in the event of a problem (article 77 of the GDPR).

If you have a question or request, please send us an email to the following address: contact@finwise.ch.

You can withdraw your consent at any time. Please note, this withdrawal of consent only applies to subsequent collections/processing of your Personal Data and has no impact on collections/processing carried out in the past. Please note that Finwise retains the right to process your Personal Data in the event of a legal obligation or in the best interests of Finwise, including in order to exercise its own legal rights. Withdrawal of your consent may terminate your business relationship with Finwise.

7. Miscellaneous

Please inform us as soon as possible of any changes to your Personal Data (including your correspondence contact details). Failure to provide accurate information or to update information as it changes may impede our ability to provide our services.

You are responsible for the accuracy and completeness of the data communicated to Finwise, and you are responsible for providing updates if your Personal Data changes.

Finwise cannot be held responsible for any situation caused by its possession of inaccurate, incomplete, false or otherwise deficient personal data communicated to us by you or a third party.

This Privacy Policy may be modified at any time. Finwise will notify you of any changes.

October 26, 2023