Data protection

Data privacy statement for users of Bank Frick’s online services

25 May 2018

The German version of our data privacy statement is authoritative.

I. Name and address of the data controller

The controller – as defined in Art. 4 No. 7 General Data Protection Regulation (“GDPR”) and other national data protection laws of the member states as well as other data protection regulations – is

Bank Frick & Co. AG
Landstrasse 14
9496 Balzers
Liechtenstein

+423 388 21 21
bank@bankfrick.li
www.bankfrick.li

 

II. Name and address of the data protection officer

You can contact Bank Frick's internal data protection officer by e-mail under the following address:

dataprotection@bankfrick.li

 

III. General information on data processing

1. Description and scope of the processing of personal data

We only collect and use personal data of our users insofar as it is necessary to provide a functional website as well as our contents and services. The collection and use of our users' personal data is only carried out with the user's consent. An exception applies in those cases where prior consent cannot be obtained as a matter of fact and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a GDPR serves as the legal basis for the processing of personal data.

In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

If processing is necessary to protect legitimate interests of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

3. Data erasure and storage time

The personal data of a data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned provisions expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

 

IV. Provision of the website and creation of log files

1. Description and scope of data processing

Every time you visit our website, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected:

  • Information about the browser type and version used
  • The user's operating system
  • The user's Internet service provider
  • The IP address of the user
  • Date and time of access
  • Websites from which the user's system accesses our website

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this the IP address of the user must remain stored for the duration of the session.

The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

The aforementioned purposes also form our legitimate interest in processing data pursuant to Art. 6 para. 1 lit. f GDPR

4. Duration of storage

The collected data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. If the data is stored in log files, this will be the case after 3 months at the latest. Further storage is possible. In this case, the IP addresses of the users will be deleted or alienated, so that an assignment of the calling client will no longer be possible.

5. Possibility of opposition and erasure

The collection of data for the provision of the website and the storage of data in log files is necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

 

V. Cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. If a user visits a website, a cookie may be stored on the user's operating system. This cookie contains a specific character string that enables a unique identification of the browser, when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

  • Language settings

We also use cookies on our website which enable an analysis of the user's surfing behaviour. In this way, the following data can be transmitted:

  • Entered search terms
  • Frequency of page views
  • Use of website functions

When you visit our website, an information banner informs you about the use of cookies for analytical purposes and refers you to this data protection statement. In this context, there is also a note on how the storage of cookies can be prevented in the browser settings.

Further information on the analysis cookies can be found in this data protection declaration under the following points:

  • VI. Google Analytics

2. Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

3. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For this it is necessary that the browser is recognized even after a page change.

We need cookies for the following applications:

  • Acceptance of language settings
  • Remembering search terms

The user data collected by technically necessary cookies are not used to create user profiles.

The analysis cookies are used to improve the quality of our website and its content. Through the analysis cookies we learn how the website is used and can thus continuously optimize our offer.

The aforementioned purposes also form our legitimate interest in processing data pursuant to Art. 6 para. 1 lit. f GDPR.

4. Possibilities of opposition and erasure

Cookies are stored on the user's computer and transmitted to our site. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

 

VI. Google Analytics

1. Description and scope of data processing

We use the component Google Analytics (with anonymisation function) for this website. Google Analytics is a web analysis service. A web analysis service collects, among other things, data on the website from which a person has accessed a website, which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used to optimize a website and for cost-benefit analysis of Internet advertising.

The Google Analytics component is operated by Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

We use the addition "_gat._anonymizeIp" for web analysis via Google Analytics. By means of this addition, Google shortens and anonymises the IP address of the Internet connection of the data subject, when accessing our website from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

By setting the cookie, Google is enabled to analyse the use of our website. Each time you access one of the individual pages of this website, the Internet browser on your terminal device is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently enable commission statements.

Cookies are used to store personal information, such as access time, the location from which access originated and the frequency of visits to our website. Each time you visit our website, this personal data, including the IP address of the Internet connection you use, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose personal data collected through the technical process to third parties.

2. Legal basis of data processing

The legal basis for data processing is our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR.

3. Purpose of data processing

The purpose of the Google Analytics component is to analyse the flow of visitors to our website. Google uses the data and information collected to evaluate the use of our website, among other things, to compile online reports for us that show the activities on our website and to provide other services in connection with the use of our website.

The aforementioned purposes also form our legitimate interest in processing data pursuant to Art. 6 para. 1 lit. f GDPR.

4. Possibility of opposition and erasure

You can prevent the setting of cookies at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on your end device. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, you have the opportunity to object to and prevent the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. In order to do this, you must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout This browser add-on informs Google Analytics via JavaScript that no data and information on visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered a contradiction by Google. If your information technology system is deleted, formatted or reinstalled at a later time, the browser add-on must be reinstalled to disable Google Analytics. If you uninstall or deactivate the browser add-on, you have the option of reinstalling or reactivating the browser add-on.

Further information and Google's current privacy policy can be found at https://policies.google.com/privacy?hl=en&gl=de and https://www.google.com/analytics/terms/us.html. Google Analytics will be explained in more detail under this link https://www.google.com/intl/en_uk/analytics/#?modal_active=none.

 

VII. Media distribution list

1. Description and scope of data processing

You can subscribe to a free media distribution list on our website. When you register for the media distribution list, the data from the input mask is transmitted to us. These are:

  • E-mail address
  • First and Surname
  • Medium
  • Phone

In addition, the following data is collected upon registration:

  • date and time of registration

During the registration process, your consent is obtained for the processing of the data and reference is made to this data protection declaration.

We use the so-called double opt-in procedure for registering for our media distribution list. As soon as users register on our site, they will receive an e-mail asking for confirmation of their registration. In this way we want to prevent registrations with foreign e-mail addresses.

The data will be used exclusively for sending the media distributor.

2. Use of the mail service provider MailChimp

Our media distribution lists are sent out using "MailChimp" - a newsletter service provider. This is a newsletter mailing platform of The Rocket Science Group LLC, 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA.

All data collected by us to send the media distribution list is stored on the servers of MailChimp. The data is used by MailChimp for sending and evaluating the newsletter. Furthermore, MailChimp can use the data to optimize its own service (e.g. display of newsletters, to determine from which countries the recipients come, etc.). However, MailChimp does not use the data to write to the recipients themselves or to forward the data to third parties.

MailChimp is certified under the EU-US data protection agreement "EU-US-Privacy Shield". With this certification, MailChimp commits itself to comply with EU data protection regulations. Furthermore, we have concluded a data processing agreement with MailChimp. This is a contract which obliges MailChimp to protect the user's data, to process the user's data only according to our data protection regulations and not to pass on the user's data to third parties.

3. Statistical survey and analyses

Each media distributor contains a so-called "web-beacon". This is a pixel-sized file that MailChimp retrieves when opening the distribution list. This provides MailChimp with technical information such as

  • IP address,
  • Information about the browser and the system, and
  • Time of the retrieval.

This data is used to technically improve the service.

In addition, the "web beacons" determine whether the media distribution lists have been opened, when they were opened, and which links were clicked on. It is possible to assign the data to individual users, but neither we nor MailChimp want to observe the individual users. Only the reading habits of the users should be recognized in order to adapt the contents to the users. Different contents should be sent according to the interests of our users.

4. Legal basis for data processing

The legal basis for the processing of the data after registration for media distribution by the user is Art. 6 para. 1 lit. a GDPR.

The use of MailChimp and the performance of statistical surveys and analyses are based on our legitimate interests pursuant to Art. 6 Para. 1 lit. f GDPR. Our legitimate interest is to be seen in the secure and user-friendly use of the media distributor. This serves both our economic interest and the expectations of the users.

5. Purpose of data processing

The collection of the data serves to deliver our media releases.

6. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user's e-mail address will therefore be stored for as long as the media distributor's subscription is active.

7. Possibility of opposition and erasure

The subscription of the media distributor can be cancelled by the user concerned at any time. For this purpose, there is a corresponding link in every newsletter. This also makes it possible to revoke the consent to the storage of personal data collected during the registration process.

 

VIII. Contact form and e-mail contact

1. Description and scope of data processing

We offer a contact form on our website which can be used for contacting us electronically. If a user makes use of this possibility of contacting us, the data entered in the input mask will be transmitted to us and stored. This data is:

  • Salutation
  • First and Surname
  • E-Mail
  • Telephone number

At the time the message is being sent, the following data will also be stored:

  • IP address of the user
  • Date and time of the request

Alternatively, you can contact us via the e-mail address provided. In this case, the user's personal data transmitted by e-mail will be stored.

In this context, the data will not be passed on to third parties. The data will only be used for the processing of the conversation.

2. Legal basis for data processing

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. a GDPR, as it is based on the consent of the interested user. If the e-mail contact aims at the conclusion of a contract, then additional legal basis for the processing is Art. 6 exp. 1 lit. b GDPR.

3. Purpose of data processing

Processing personal data from the input mask serves us only to handle your request.

4. Duration of storage

We store the personal data of the requesting user as long as it is necessary to process the request.

5. Possibility of opposition and erasure

The user can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

All personal data stored in the course of contacting us will be deleted in this case.

 

IX. Google Maps

1. Scope of data processing

We have integrated Google Maps on our website. In this process Google perceives and stores the IP address of the users, which is the only way how the contents of Google Maps can be transferred to the browser of the user.

The Google Maps component is operated by Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Google LLC is certified under the EU-US Privacy Shield. Google's privacy policy can be found at https://policies.google.com/privacy?hl=en.

2. Legal basis for data processing

The legal basis for the use of the Google Maps component is Art. 6 para. 1 lit. f GDPR.

3. Purpose of data processing

We use Google Maps to ensure an attractive perception of our website. Google Maps is also used to make it easier to find the locations indicated on our website.

The aforementioned purposes also form our legitimate interest in processing data pursuant to Art. 6 para. 1 lit. f GDPR.

4. Possibility of opposition and erasure

The user has the possibility to deactivate Google Maps by means of an opt-out: https://adssettings.google.com/authenticated.

X. Applications for employment

1. Description and scope of data processing

Users have the possibility to upload application files in digital form on our website. We store and check the data contained in the dossiers in order to decide whether an adjustment should be made.

The scope of data processing at our company depends on the scope of the data sent by the applicant, but always includes name and contact details.

The data will not be passed on to third parties.

2. Legal basis for data processing

The legal basis for the processing of data transmitted in an application is Art. 6 para. 1 lit. a GDPR, as it is based on the consent of the interested user.

3. Purpose of data processing

We use the information provided solely to decide whether or not to hire you.

4. Duration of storage

We store the applicant data at the latest one year after receipt of the application documents, so that applicants can also be considered as application candidates for future vacancies.

5. Possibility of opposition and erasure

Applicants can object to their consent to the storage of their personal data sent with the application at any time.

All personal data will be irretrievably deleted in this case.

 

XI. Rights of the data subjects

If your personal data is processed you are a ‘data subject’ in terms of the GDPR and you have the following rights against the person responsible:

1. Right to information

You can ask the person in charge to confirm whether personal data concerning you will be processed by us.

If such processing has taken place, you can request the following information from the person responsible:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data being processed;

(3) the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;

(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;

(5) the existence of a right to rectification or deletion of personal data concerning you, a right to limitation of processing by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) any available information on the origin of the data if the personal data are not collected from the data subject;

(8) the existence of automated decision-making including profiling in accordance with Art. 22 para. 1 and 4 GDPR and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.

2. The right to correction

You have a right of rectification and/or completion against the data controller if the personal data processed concerning you are incorrect or incomplete. The person responsible shall make the correction without delay.

3. Right to limitation of processing

Under the following conditions, you may request that the processing of personal data concerning you be restricted:

(1) if you dispute the accuracy of the personal data concerning you for a period that enables the data controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;

(3) the data controller no longer needs the personal data for the purposes of the processing, but you do need them to assert, exercise or defend legal claims, or

(4) if you have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the person responsible outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed - apart from being stored - with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.

If the processing restriction has been restricted according to the above conditions, you will be informed by the person responsible before the restriction is lifted.

4. Right to cancellation

a) Deletion duty

You may request the data controller to delete the personal data relating to you without delay and the controller is obliged to delete this data without delay if one of the following reasons applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.

(3) You file an objection against the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 GDPR.

(4) The personal data concerning you have been processed unlawfully.

(5) The deletion of personal data relating to you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.

(6) The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.

b) Information to third parties

If the data controller has made the personal data concerning you public and is obliged to delete it pursuant to Art. 17 para. 1 GDPR, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform data processors who process the personal data that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.

c) Exemptions

The right to cancellation does not exist insofar as the processing is necessary

(1) to exercise freedom of expression and information;

(2) for the performance of a legal obligation required for processing under the law of the Union or of the Member States to which the controller is subject or for the performance of a task in the public interest or in the exercise of official authority conferred on the controller;

(3) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the law referred to under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or

(5) to assert, exercise or defend legal claims.

5. Right to information

If you have exercised your right to have the data controller correct, delete or limit the processing, he/she is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.

The person responsible shall have the right to be informed of such recipients.

6. Right to data transferability

You have the right to receive the personal data concerning you that you have provided to the person responsible in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another person in charge without obstruction by the person in charge to whom the personal data was provided, provided that

(1) processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and

(2) processing is carried out by means of automated methods.

In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one data controller to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to transferability shall not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority conferred on the controller.

7. Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you under Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.

The data controller no longer processes the personal data concerning you, unless he can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility to exercise your right of objection in connection with the use of Information Society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

8. Right to revoke the data protection declaration of consent

You have the right to revoke your data protection declaration of consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until revocation.

9. Automated decision in individual cases including profiling

You have the right not to be subject to a decision based exclusively on automated processing - including profiling - that has legal effect against you or significantly impairs you in a similar manner. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the person responsible,

(2) the legislation of the Union or of the Member States to which the person responsible is subject is admissible and that legislation contains appropriate measures to safeguard your rights, freedoms and legitimate interests; or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

In the cases referred to in (1) and (3), the person responsible shall take reasonable measures to safeguard your rights, freedoms and legitimate interests, including at least the right to obtain the intervention of a person by the person responsible, to state his own position and to challenge the decision.

10. Right of appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or suspect of infringement, if you believe that the processing of personal data concerning you is contrary to the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.