Privacy Notice
This Privacy Notice contains information on what data is collected when visiting our websites www.pilotage.ch or www.pilotage.group and applies to visitors to our websites, existing and potential customers, shareholders, investors, distributors, contractors, service providers, suppliers and other third parties (collectively "Business Partners") and provides an overview of the collection and processing of personal data by Pilotage Private Wealth Ltd, Zurich (“Pilotage”). In accordance with Art. 19 and 20 of the Federal Act on Data Protection (FADP) of 25 September 2020 and, where applicable, the EU General Data Protection Regulation 2016/679 ("EU GDPR"), this Privacy Notice informs you and other potential data subjects about the processing of personal data (in particular also about the collection of personal data) by Pilotage. Personal data’ is any information that relates to an identified or identifiable natural person.
1. Responsible bodies and contact information
Pilotage Private Wealth AG, Tödistrasse 48, CH-8002 Zürich, Switzerland
Phone: +41 43 508 17 17
E-mail address: enquiries@pilotage.ch
2. Consent
By accessing our website www.pilotage.ch you give the consent to the usage of your personal data as outlined in this Privacy Notice. We may make changes to this privacy notice at any time.
3. What data is being collected?
When using our site usage data is collected automatically. Usage data may include information such as your Device Internet Protocol address (e.g. IP address), Browser type, Browser version, the pages of our website that you visit, the time and date of your visit and the time spent on those pages, unique device identifiers and other diagnostic data. To the extent permitted for the provision of our services, we also process personal data that we collect from publicly accessible sources (e.g. public registers, publicly accessible debtor directories, public social media platforms, land registers, commercial and association registers, from the press or the Internet) or that is legitimately transmitted to us by other companies or by other third parties (e.g. credit agencies, sanctions lists, providers of risk management or intelligence solutions).
4. What is the collected data being used for?
The purposes of data processing depend primarily on what specific product or service you requested from Pilotage. Within the scope of our business relationship, you as our customer must provide such personal data as is necessary for the establishment and performance of a business relationship and the fulfilment of the associated contractual obligations or which we are legally obliged to collect. Without this data, we would not be able to enter into or perform a contract, or we might no longer be able to perform an existing contract and would have to terminate it. In particular Pilotage uses the personal data
to perform contractual obligations and execution of orders;
in order to protect the legitimate interests of Pilotage or of third parties;
on the basis of consent;
due to a legal requirement (e.g. anti-money laundering regulations) or in the public interest; and
to ensure that our website is properly functioning Further, from the information we collect we analyse how our website is being use and how we can improve it.
If you contact us via our website we may use your email address to send you marketing materials, market updates and white papers. If you do not wish to receive these communications please let us know and we will remove you from our mailing list.
5. Recipients of the personal data
As a financial institution supervised by FINMA, we are obliged to maintain the professional secrecy. We may only disclose your personal data to other companies providing services to us or to third parties that need it to fulfil the purposes set out in section 4 or for risk management services, and if there is a corresponding legal basis for doing so. Service providers and agents employed by us may also receive data for these purposes if they maintain business confidentiality. These are companies in the categories of IT services, logistics, printing services, telecommunications, video identification, consulting, auditing, banks, stock exchanges, clearing houses, collection services, payment card processing, risk controlling, expense reports as well as sales and marketing. With regard to the disclosure of data to recipients outside the authorised companies, we are obliged to maintain confidentiality about all customer-related facts and evaluations of which we become aware. We may only pass on information about you if you consented to this, if this is required by law, or if we are authorised to provide information. Under these conditions, recipients of personal data may be, for example:
public bodies and institutions (e.g. FINMA, financial authorities, law enforcement agencies) in the event of a legal or official obligation;
other financial services institutions or comparable institutions to which we transfer personal data in order to carry out the business relationship with you. (e.g. payment processors);
other companies within the PPW Group to manage risk due to legal or regulatory obligations.
Further data recipients may be those entities for which we have been granted consent to transfer data or for which we have been released from business secrecy pursuant to an agreement or consent.
6. Transfer of personal data abroad
For customers domiciled in a member state of the EU or in the EEA: Data transfer to third countries (states outside the European Economic Area - EEA; e.g. Switzerland) takes place in accordance with Art. 44 ff. DSGVO for the execution of your orders to PPW (registered office in CH-8001 Zürich), if the data transfer is necessary or provided for by law, in the context of order processing, if the transfer is otherwise permissible under the applicable data protection laws and regulations or if you have given us your consent.
In the context of order processing, your personal data will only be transferred to third countries if the relevant country (or the international data protection agreement applicable to such country) is deemed by the competent authorities and institutions to have an adequate level of data protection or, in the absence of such an adequacy decision, if the recipient ensures adequate protection based on appropriate safeguards in accordance with applicable data protection laws and regulations (e.g. the standard contractual clauses of the European Commission, adapted where appropriate to local law, or legal exceptions apply in accordance with data protection laws and regulations). e.g. the European Commission's standard contractual clauses, adapted to local law where applicable) or legal exceptions under data protection laws and regulations apply (e.g. explicit consent).
7. Retention period
We process and store your personal data as long as it is necessary for the fulfilment of our contractual and legal obligations. Our business relationship is a continuing obligation that is intended to last for years. We have procedures in place to review the different categories of data we hold at different times. This ensures that we do not store them for an excessively long period of time. If the data is no longer required for the purposes of processing, or if we are otherwise legally obliged to delete the personal data, it is regularly deleted, unless its - temporary - further processing is required for the following purposes: Compliance with legal retention obligations: The Swiss Code of Obligations (OR), the Business Records Ordinance (GeBüV) and the Anti-Money Laundering Act (GwG) are worth mentioning. The retention and documentation periods specified there are usually ten years.
8. Your rights
You have a right to ask Pilotage 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. However, we will consider your request and respond to you with the outcome.
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 Pilotage for a copy of some or all of the personal data we collect and process about you.
9. Automated decision making in individual cases, including profiling
As a rule, we do not make any decisions on the establishment and implementation of a business relationship that are based exclusively on fully automated processing. In certain circumstances Pilotage may process your personal data through automated decision-making, including profiling. Where this takes place, you will be informed of such automated decision-making that uses your personal data, be given information on the logic involved, and be informed of the possible consequences of such processing.
In some cases we may automatically process your personal data to assess certain personal aspects relating to you ("profiling") We may use profiling, for example, in the following cases:
to comply with our ongoing regulatory compliance requirements (e.g. anti-money laundering, anti-fraud, anti-terrorism and tax legislation), e.g. by reviewing how and from which geographical locations you use our applications or other PPW services;
use of evaluation and assessment tools, these enable need-to-know-based communication and advertising including market and opinion research;
as listed elsewhere for a particular product or service.
In certain circumstances, you can request not to be subject to automated decision-making, including profiling.
10. Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. In order to make the visit to our website attractive and to enable the use of certain functions, so-called cookies are used on our PPW website. These are small text files that are stored on the user’s terminal device. Some of the cookies used are deleted after the end of the browser session, i.e. after closing the browser (so-called session cookies). Other cookies remain on the end device and enable the browser to recognize the user on the next visit (persistent cookies). If cookies are set, they collect and process certain user information to an individual extent, such as browser and location data and IP address values. Persistent cookies are automatically deleted after a specified period of time, which may differ depending on the cookie.
Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our website. If cookies stored on the device are to be restricted or blocked, this can be done via your private browser settings. Information on this can be found in the help function of the browser. If cookies are disabled, at most not all functions of our website will be available.
11. Google analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic
The information generated by the cookies about your use of this website will be transmitted to a Google server in the USA and stored there. Google will make use of this information to evaluate your visit to the website, to compile reports about activities on our site and to provide further services associated with website and internet use. Google may also pass on this information to third parties, in so far as this is required by statute or in case the data is to be processed by a third party on Google’s behalf. On no account will Google combine your IP address with other data in its possession.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript from sharing information with Google Analytics about activity
Further information about Google Analytics may be found here: http://www.google.com/intl/de/analytics/learn/privacy.html
12. 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.
13. Amendments to this Privacy Notice
This privacy notice was last updated on 1 January 2024. You can find the current version on our website. PPW reserves the right to change this Privacy Policy at any time. It will provide notice of any such change in an appropriate manner.