UBS Y is an initiative of UBS Business Solutions AG, that shares ideas through their social media presence in the internet (website, Facebook, Twitter, Instagram), publications and events. This privacy notice is to be understood in that context. For information about how we process client personal data, please visit this webpage.
1. Data protection
For UBS Y activities (UBS Y, "We", "our" or "us") UBS Business Solutions AG takes your privacy seriously and adheres to high data protection standards as well as transparency of personal data collection and processing. This privacy notice contains general information on what personal data UBS Y collects, what we do with that information, and what rights you have. If you have any questions or comments, please contact us at the address set out in section 8. We want to inform you in this document about:
- why and how UBS Y collects, uses and stores your personal data;
- the lawful basis on which your personal data is processed; and
- what your rights and our obligations are in relation to such processing.
2. What types of personal data do we collect?
We, through UBS Y will, depending on our interaction with you , collect and process personal data about you including:
- personal details such as your name, date of birth, phone number, physical and electronic address,
- where applicable, family details such as the name of your spouse, partner, or children, only when you have provided this data to us (for example for an event);
- where applicable, professional information about you, such as your job title and work experience (for example in an event, for a speaker engagement, in an engagement activity);
- details of our interactions with you and the events you attended to;
- any records of phone calls between you and us for UBS Y related topics;
- when you access our Website, data transmitted by your browser and automatically recorded by our server, including date and time of the access, name of the accessed file as well as the transmitted data volume and the performance of the access, your web browser, browser language and requesting domain, and IP address (additional data will only be recorded via our Website if their disclosure is made voluntarily, e.g. in the course of a registration or request). When you visit a UBS website, that website will contain additional information about how we use your information while you are visiting that website.
3. On which legal basis and for which purposes do we process personal data?
Depending on the purpose of the processing activity (see section 3.2), the processing of your personal data will be one of the following:
- necessary for the legitimate interests of UBS, without unduly affecting your interests or fundamental rights and freedoms (see below);
- necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as for example a non-disclosure agreement in engagements with us;
- required to meet our legal or regulatory responsibilities, including when we conduct the checks make the disclosures to authorities regulators and government bodies as appropriate;
- when we use special categories of personal data, necessary for establishing, exercising or defending legal claims or where the processing relates to personal data manifestly in the public domain; and
- in limited circumstances, processed with your consent which we obtain from you from time to time (for instance where required by laws), or processed with your explicit consent in the case of special categories of personal data.
Examples of the ‘legitimate interests’ referred to above are:
- pursuing certain of the purposes in section 3.2 below;
- exercising our rights under Articles 26 and 27 of the Federal Constitution of the Swiss Confederation, including our freedom to conduct a business and right to property;
- when we make the disclosures referred to in section 4 below, providing products and services (for example when public speaking or in workshops with us) and assuring a consistently high service standard and to our audience or other people engaged with us.
In each case provided such interests are not overridden by your privacy interests. Where the personal data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this personal data there is a possibility we may be unable to or provide products or services to you (in which case we will inform you accordingly).
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for the following purposes:
- Managing our social media presence, which guarantees that we share parts of the content of our work, and engaging in social media activities accordingly;
- providing products and services to you and ensuring their proper execution;
- managing our relationship with you, including communicating with you in relation to the products and services you obtain from us and from our business partners, handling customer service-related queries and complaints;
- taking steps to improve our products and services and our use of technology, including testing and upgrading of systems and processes, and conducting market research to understand how to improve of our existing products and services or learn about other products and services we can provide;
- meeting our on-going regulatory and compliance obligations (e.g. laws of the financial sector, anti-money-laundering and tax laws), including, as applicable, recording and monitoring communications, disclosures to tax authorities, financial service regulators and other regulatory and governmental bodies, and investigating or preventing crime;
- undertaking statistical analysis;
- for the UBS Group’s prudent operational management (including, audit, systems and products training and similar administrative purposes); and
- any other purposes we notify to you from time to time.
4. Who has access to personal data and with whom are they shared?
When providing services to you, we may share personal data with other companies from the UBS Group involved in the transaction (depending on the type of product or service you receive from us).
In some instances, we also share personal data with our suppliers, including UBS Group companies and other business partners who provide services to us, such as IT and hosting providers, marketing providers, communication services and printing providers, debt collection, tracing, debt recovery, fraud prevention, and credit reference agencies, and others. When we do so we take steps to ensure they meet our data security standards, so that your personal data remains secure.
- If our business is sold to another organization or if it is re-organized, personal data will be shared so that you can continue to receive products and services. We will usually also share personal data with prospective purchasers when we consider selling or transferring part or all of a business. We take steps to ensure such potential purchasers keep the data secure.
- We may need to disclose personal data to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.
5. International transfers of personal data
The Recipients referred to in section 4 above may be located outside Switzerland. In those cases, except where the relevant country has been determined by the Federal Data Protection and Information Commissioner to provide an adequate level of protection, UBS requires such recipients to comply with appropriate measures designed to protect personal data contained within a binding legal agreement. If and to the extent required by applicable law (such as Swiss Banking Secrecy), we implement the necessary legal, operational and technical measure and/or enter into an agreement with you before such transfers.
6. How long do we store your data?
We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose, such as if you want us to contact you for further events, as long as you want to remain in the distribution list, or longer if there is a legal obligation to retain your personal data.
7. Your rights
You have a right to ask us to rectify inaccurate personal data we collect and process and the right to request restriction of your personal data pending such a request being considered. Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Please also note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You have a right to ask us to stop processing your personal data, or to request deletion of your personal data –these rights are not absolute (as sometimes there may be overriding interests that require the processing to continue, for example), but we will consider your request and respond to you with the outcome. When personal data are processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketing by writing to [email protected] or by contacting us at the address set out in section 8. Where we process your personal data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right under applicable data protection laws to request your personal data be transferred to you or to another controller. You have the right to ask UBS for a copy of some or all of the personal data we collect and process about you. You can exercise the rights set out above by contacting the DPO using the details in section 8 of this notice.
8. Exercising your rights and complaints
If you are not satisfied with any aspect of the processing of your personal data regarding your dealings with the UBS Y team, we would like to discuss it with you to understand how we can rectify the issue. You may exercise any of your rights in relation to your personal data by writing to us at one of the following addresses. To avoid delay in dealing with your request, please enclose with your signed letter a copy of your passport or identity card:
UBS Switzerland AG, Quality Feedback / Direktion, Postfach, 8098 Zürich, Switzerland
UBS Business Solutions AG, Office of Group DPO, PEZH NORD1 EUR1-211, Postfach, 8098 Zürich, Switzerland
If you are not satisfied with UBS response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen.
9. Security Note
We have in place appropriate technical and organizational measures to prevent unauthorized or unlawful access to the personal data you have provided to us. As complete data security cannot be guaranteed for communication via e-mails, instant messaging, and similar means of communication, we would recommend sending any particularly confidential information by an alternative secure means.
10. Changes to personal data
We are committed to keeping your personal data accurate and up to date. Therefore, if your personal data changes, please inform us at [email protected] of the change as soon as possible.
11. Status of this privacy notice
This privacy notice was updated in November 2019. It is a notice explaining what UBS Y does, rather than a document that binds UBS or any other party contractually. We reserve the right to amend it from time to time. If the notice has been updated, we will take steps to inform you of the update by appropriate means, depending on how we normally communicate with you, such as through your account statement.