Data protection

Data privacy statement for users of Bank Frick’s online services
Status April 2022

The German version of our data privacy statement is authoritative.

I. Name and address of the controller

The controller, as defined in the EU General Data Protection Regulation (GDPR), and other national data protection laws of the member states and other data protection regulations, is

Bank Frick & Co. AG
Landstrasse 14
9496 Balzers
Liechtenstein

+423 388 21 21
bank [at] 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 sending an e-mail to the following address:

dataprotection [at] bankfrick.li

 

III. General information on data processing

1. Description and scope of the processing of personal data
We predominantly collect and use our users’ personal data to provide a functional website and our contents and services. In addition, 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 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, Article 6(1)(a) of the 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, Article 6(1)(b) of the 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, Article 6(1)(c) of the 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) of the 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 and fundamental rights and freedoms of the data subject do not outweigh the aforementioned interests, Article 6(1)(f) of the GDPR serves as the legal basis for processing.
 

3. Data erasure and storage time
The personal data of the data subject will be erased 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 erased 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 (cookies necessary for technical reasons)

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 are collected:

  • Information about the browser type and version used
  • The user’s operating system
  • The user’s Internet service provider
  • The user’s IP address
  • Date and time of access
  • Websites from which the user’s system accesses our website
  • The data selected in the cookie banner
  • User settings concerning the choice of language

2. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Article 6(1)(f) of the GDPR.
 

3. Purpose of data processing
The temporary storage of the aforementioned personal data is necessary to provide a functional website. 

The aforementioned purposes also form our legitimate interest in processing data pursuant to Article 6(1)(f) of the GDPR.
 

4. Duration of storage
The data will be deleted as soon as the user leaves our website. 
The only exception are cookies concerning language settings and preferences in the cookie banner. These data will be stored for one year. 
 

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. However, the data concerning language settings and preferences in the cookie banner can be deleted immediately at any time upon request.
 

V. 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 data subject 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 optimise 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 for data processing
The legal basis for data processing is our legitimate interest in processing data pursuant to Article 6(1)(a) of the GDPR. We will only process your data with regard to Google Analytics if you have given your express consent in the cookie banner.
 

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.
 

4. Possibility of objection 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 erased 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 an objection by Google. If your information technology system is erased, 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 at this link https://www.google.com/intl/en_uk/analytics/#?modal_active=none.
 

5. Duration of storage
If you have given your consent to us processing your data and do not object to us processing your data or withdraw your consent before we use your data, we will store your data for the use of Google Analytics for a maximum of two years. 
 

VI. Newsletter

1. Description and scope of data processing
You can subscribe to a free newsletter on our website. When you register for the newsletter, the data from the input mask is transmitted to us. These are:

  • E-mail address
  • Given name and Family name

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 privacy statement.

We use the so-called double opt-in procedure for registering for our newsletter. 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 newsletter.

2. Use of the mail service provider MailChimp
Our newsletters 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 are stored on the servers of MailChimp. The data is used by MailChimp for sending and evaluating the newsletters. Furthermore, MailChimp can use the data to optimise 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 commits itself to comply with EU data protection regulations. We have concluded a data processing agreement with MailChimp which also includes the EU standard contractual clauses. This is a contract which obliges MailChimp to protect users’ data, to process users’ data only according to our data protection regulations and not to pass on users’ data to third parties.
 

3. Statistical survey and analyses
Each newsletter 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

  • the IP address;
  • information about the browser and the system; and
  • the time of the retrieval.

This data is used to technically improve the service.

In addition, the web beacons are used to determine whether the newsletter has been opened, when it was 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 recognised 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 the user has subscribed to the newsletter is Article 6(1)(a) of the GDPR. By subscribing to our newsletter, you simultaneously consent to us processing your data.
 

5. Purpose of data processing
The collection of the data serves to deliver our newsletter.

6. Duration of storage
The data will be erased 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 objection 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 withdraw the consent to the storage of personal data collected during the registration process.
 

VII. 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. These data are:

  • Form of address
  • Given name and Family name
  • E-mail
  • Telephone number

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

  • The 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 Article 6(1)(a) of the GDPR, as it is based on the consent of the interested user. If the e-mail contact aims at the conclusion of a contract, additional legal basis for the processing is Article 6(1)(b) of the GDPR.
 

3. Purpose of data processing
Processing personal data from the input mask serves us only to handle your request. In the event that you contact us by e-mail, this will also form the necessary legitimate interest in processing data.
 

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 objection and erasure
The user can object to the storage of their 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 erased in this case.
 

VIII. Webinars and other online events

1. Description and scope of data processing
We offer the possibility of participating in so-called webinars (online seminars) and other online events on our website. When a user makes use of this possibility, the data entered in the input mask will be transmitted to us and stored. These data are:

  • Form of address
  • Given name and Family name
  • E-mail

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

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

2. Legal basis for data processing
The legal basis for the processing of data is Article 6(1)(a) of the GDPR, since the data are processed, as it is based on the consent of the interested user. 
 

3. Purpose of data processing
Processing personal data from the input mask serves us only to host the webinar or online event.
 

4. Duration of storage
We store the personal data of event participants for up to one month after the webinar has been held.
 

5. Possibility of objection and erasure
The user can object to the storage of their personal data at any time. However, in such a case, they will be unable to participate in the event.
 

IX. Google Maps

1. Scope of data processingWe have integrated Google Maps on our website. In this process, Google perceives the IP address of the user and stores the IP address of the user on servers in the USA, which is the only way 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 Article 6(1)(a) of the GDPR. We will only activate Google Maps after you have given your express consent.
 

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.
 

4. Possibility of objection 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 Article 6(1)(a) of the 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 for a maximum of one year after receipt of the application documents, so that applicants can also be considered as application candidates for future vacancies.
 

5. Possibility of objection and erasure
Applicants can object to the storage  of their personal data sent with the application at any time.
All personal data will be irretrievably erased 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 vis-à-vis the controller:

1. Right to be informed
You can ask the controller 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 controller:

  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 erasure of personal data concerning you, a right to restriction 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 Article 22(1) and (4) of the 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 Article 46 of the GDPR in connection with the transmission.

2. The right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are incorrect or incomplete. The vis-à-vis shall make the rectification without delay.
 

3. Right to restriction 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 controller to verify the accuracy of the personal data
  2. The processing is unlawful and you refuse to erase the personal data and instead request that the use of the personal data be restricted
  3. The 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
  4. If you have filed an objection to the processing pursuant to Article 21(1) of the GDPR and it has not yet been determined whether the legitimate reasons of the controller 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 controller before the restriction is lifted.
 

4. Right to erasure

a) Erasure duty

You may request the controller to erase the personal data relating to you without delay and the controller is obliged to erase 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 withdraw your consent, on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing
  3. You file an objection against the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Article 21(2) of the GDPR
  4. The personal data concerning you have been processed unlawfully
  5. The erasure 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 controller is subject
  6. The personal data concerning you were collected in relation to information society services offered pursuant to Article 8(1) of the GDPR

b) Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, the controller 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 erasure of all links to this personal data or of copies or replications of this personal data.

c) Exemptions

The right to erasure 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 Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
  4. for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the 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 be informed
If you have exercised your right to have the controller rectify, erase or restrict the processing, the controller shall inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.

You have the right vis-à-vis the controller to be informed of such recipients.
 

6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another controller without obstruction by the controller to which the personal data was provided, provided that

  1. the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) GDPR; and
  2. the 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 controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to portability does 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 to object
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 controller will no longer process the personal data concerning you, unless the controller 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 to object 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 controller;
  2. is admissible based on the legislation of the Union or of the member states to which the controller is subject and that legislation contains appropriate measures to safeguard your rights, freedoms and legitimate interests; or
  3. is made with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the 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 controller 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 controller, to state their 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 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 of the GDPR.