Privacy Notification in Connection with our Online Advertising Program via Google

1. Introduction

This Privacy Notification applies to our online advertising program performed by Google Ireland Limited ("Google"), which presents advertisements on the Google search engine, available at www.google.com (the “Engine”) or on third party websites (jointly the “Google Ads Program”). In this Privacy Notification the terms “we” “us” or “our” refer to EFG International AG (Bleicherweg 8, P.O. Box 6012 CH - 8022 Zürich, Tel. +41 44 226 1850) (“EFGI”).

The Google Ads Program is operated in cooperation with Google. While the present notification contains details regarding personal information processing on the Engine or generally conducted in cooperation with Google, these elements are mentioned only to the extent that they tie into personal information processing conducted by EFGI. The scope of the present notification is indeed limited to such personal information processing that is carried out by us (or on our behalf) and whose purposes are defined by us. With regards to information processing and purposes carried out and defined by Google alone and not by us, Google’s Privacy Policy, can be consulted here: https://policies.google.com/privacy.

We do not seek to collect personal information from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal information to us.

2. Types of personal information collected and processed

The types of personal information we collect and process depends, among other factors, on how you are using the Engine. In particular:

2.1 If you enter certain search terms in the Engine which are related to our operations, you may see our advertisements above or below search results, appearing with an "Ad" or "Ads" label on the search results page, as part of our search network campaign (the “Search Network Campaign”). Google processes your personal information to provide us with anonymized statistics which enable us to gain knowledge about the results of our Search Network Campaign. For this purpose, Google processes personal information that you already share with them, which may include online identifiers, cookie identifiers, internet protocol addresses, device identifiers, precise location information and Google client identifiers. Google does not share personal information with us when providing us with the above referenced statistics. Also, we are unable to draw conclusions regarding individuals from the information provided in these statistics.

2.2 If you are browsing your favorite websites, sharing a YouTube video with a contact, consulting your Gmail account or using mobile devices and apps, we may show you our advertisement, as part of our display network campaign (the “Display Network Campaign”). In this case, both we and Google participate in determining the purpose and means of aspects of the associated processing of personal information, which may result in the display of our advertisement to a set of individuals, who make up the target audience. Google processes personal information, which may include the personal information under 2.1 above, and classifies its users alongside categories. We select among these categories the ones that appear to define our target audience. Accordingly, we only specify the parameters of our intended audience and do not – through that process – have access to the personal information of the relevant Google users.

3. Sources of personal information

We collect your personal information directly from you and/ or from Google.

4. How we use personal information

Apart from the use of your personal information referenced under section 2 above, the situations in which we may process your personal information are listed below:

• To comply with any applicable laws and regulations;
• To comply with the request or requirement of any court of any relevant jurisdiction or any relevant authority; and
• For use in connection with any legal proceedings or regulatory action (including prospective legal proceedings/ regulatory action) and for obtaining legal advice or for establishing, exercising or defending legal rights.

5. Recipients of your personal information

We may disclose personal information in the situations described below:

• To Google, if necessary;
• To third parties who provide services to us (e.g. IT companies, telecommunication providers, advertising agencies);
• To any court of any relevant jurisdiction or any relevant authority;
• To public authorities, regulators or governmental bodies or other third parties, when required by law or regulation; or
• Otherwise, if you consent to such disclosure.

6. Overseas transfers

We may transfer the personal information we collect about you to countries other than the country of our incorporation or the country in which the information was originally collected. Other destination countries may not have the same laws on personal information as the country in which you initially provided the information.

When we transfer your personal information to other countries, we will protect that information as described in this Privacy Notification and in accordance with applicable law. If necessary, we require the recipients referred to in section 5 above to comply with appropriate safeguards designed to protect personal information.

7. How to contact us

If you have a query regarding the processing of your personal information or if you would like to exercise your rights under the applicable legislation on personal information, please contact your Client Relationship Officer if you are a client and/ or our Data Protection team at [email protected] .

8. Changes to this Privacy Notification

We may revise this Privacy Notification from time to time. The most current version of this Notification will govern our processing of your personal information and it is accessible on our website (www.efginternational.com). By continuing to access the Engine you agree to be bound by the Privacy Notification currently in place at the time of each visit.

9. EEA Addendum

If you are in the European Economic Area ("EEA"), the following additional EEA-specific provisions may apply to the processing of your personal information.

A. Controller – EU Representative

The controller of your personal information is EFGI(i.e., EFG International AG. Address: Bleicherweg 8, P.O. Box 6012 CH - 8022 Zürich, Tel. +41 44 226 1850). The EU Representative for EFGI is EFG Bank (Luxembourg) S.A. (https://lu.efgbank.com/). For the purpose of our online advertising program via Google, Google may act as a separate controller, as a joint controller with us or as our data processor, as the case might be. Relevant information can be found in the Engine (e.g. https://policies.google.com/privacy and https://privacy.google.com/businesses/processorterms).

B. Legal basis for using your personal information

We will only use your personal information when the law allows us to. Most commonly and depending on the situation in which we will use your personal information, we will use your personal information in the following circumstances:

• Where we need to comply with a legal obligation;
• Where it is necessary to the pursuit of our legitimate interests: i.e., our legitimate interest in advertising our services to our target audience and receiving aggregated feedback (rather than specific personal information) about the results of our targeting campaign.
• Where necessary for the establishment, exercise and defense of legal claims.
• Where you have given your consent.

C. European Privacy Rights

Your rights in connection with personal information

Under certain circumstances and subject to applicable law, you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to you or to another party (also known as “data portability”) where your personal information is processed by automated means and:
  • where we process your personal information on the basis of your consent; or
  • where such processing is necessary for entering into or performing our obligations under a contract with you.
• Where we process your personal information on the basis of your consent, you may withdraw that consent at any time. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• In certain circumstances, request not to be subject to automated decision-making, including profiling.

Certain of these rights are not absolute under the applicable legislation (as sometimes there may be overriding interests that require the processing to continue, for example); nonetheless we will consider your request and respond to you.

Moreover, if you report to us your intention to assert any rights in relation to Google or in relation to us and Google, we will forward your request to Google to the extent that company is concerned. We will also forward your request to Google, in case you report to us your intention to assert any rights in relation to us and we need Google’s support in order to reply to this request.

Finally, you have the right to lodge a complaint with the supervisory authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your personal information has arisen.

D. Retention of personal information

With respect to our Google Ads Program please note that we have no influence on the deletion of your personal information by Google. You can opt out of Google's use of cookies or device identifiers by visiting Google's Ads settings at the Engine.

E. How to contact us

If you would like to exercise any of your rights in connection with your personal information or receive a copy of the safeguards designed to protect personal information in the case of transfer of your personal information outside the EEA, please contact your Client Relationship Officer and/ or our Data Protection team at [email protected] .

10. Swiss Addendum

The additional provisions below apply to the processing of personal information which is subject to the Swiss Federal Data Protection Act.

A. Controller

The controller of your personal information is EFGI (i.e. EFG International AG. Address: Bleicherweg 8, P.O. Box 6012 CH - 8022 Zürich, Tel. +41 44 226 1850).

For the purpose of our online advertising program via Google, Google may act as a separate controller, as a joint controller with us or as our data processor, as the case might be. Relevant information can be found in the Engine (e.g. https://policies.google.com/privacy and https://privacy.google.com/businesses/processorterms).

B. Overseas transfers

Your personal information may be transferred (including made accessible from) by EFGI to the following countries:

• Countries within the EEA;

• Other countries recognized by Switzerland as providing adequate privacy protection (for a list of these countries, please see https://www.fedlex.admin.ch/eli/cc/2022/568/fr#annex_1);

• Countries where other EFG group entities / branches are established (for a complete list, see https://www.efginternational.com/ch/about/locations.html); certain service providers of EFGI might also be established in these countries; and

• Countries whose national authorities oversee the activities of EFGI.

Some of the countries referred to under (iii) and (iv) do not benefit from data protection regulations that have been recognized as being "adequate" (i.e., comparable standard) from a Swiss data protection perspective. When we transfer your personal information to such countries, we will implement appropriate safeguards in accordance with applicable law (e.g., implementation of standard contractual clauses).

In addition, please note that your personal information may be communicated to other countries in the context of (i) the execution of a contract between you and EFGI or a contract executed by EFGI with a third party in your interest or (ii) the establishment, exercise or defense of legal claims before a court or competent foreign authority.