1. Introduction
This Privacy Notification applies to our presence on the social network LinkedIn (the “Platform”) of LinkedIn Ireland Unlimited Company ("LinkedIn"), through: (i) our relevant company page available at https://ch.linkedin.com/company/efg-bank (the “LinkedIn Company Page”); or (ii) sponsored content displayed in the news feed of the Platform and leads captured in the Platform (jointly the “Marketing Activities”). 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”).
Our social media presence in the Platform is operated in cooperation with LinkedIn. While the present notification contains elements of information regarding personal information processing on the LinkedIn Platform, these elements are only incidental and 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 LinkedIn alone and not by us, LinkedIn’s Privacy Policy, can be consulted here: https://www.linkedin.com/legal/privacy-policy.
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 Platform in particular:
2.1. If you visit or follow our LinkedIn Company Page, LinkedIn processes your personal information to provide us with anonymized statistics and insights which enable us to gain knowledge about all social interaction in our LinkedIn Company Page. For this purpose, LinkedIn processes personal information that you already share with them by adding it to your profile including your position, country, field of work, seniority, company size and employment status, your IP address or your interactions with the Platform (e.g. like, share) and the date/ time of these interactions. LinkedIn does not share personal information with us by providing us with the insights. Also, we are unable to make conclusions about individuals from the information in the insights.
2.2. We will also receive your personal information if you reach out to us through a message via the Platform. Personal information in this context includes e.g. name, position, country, field of work, seniority, company size and employment status, date and time of your inquiry/ request and content of your inquiry/ request. In this case we will process your personal information in order to reply to your message.
2.3. With respect to the Marketing Activities, in the form of sponsored content displayed in the news feed of the Platform both we and LinkedIn participate in determining the purpose and means of the associated processing of personal information, which may result in the display of our advertisement to a set of individuals/ LinkedIn users, who make up the target audience. LinkedIn 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 LinkedIn users.
2.4. Finally, with respect to the Marketing Activities, in the form of leads captured in the Platform, the relevant Platform’s feature pulls Platform’s profile information (like your contact details) into a form you submit to us for the purposes for which your personal information is collected, as specified in the relevant form.
3. Sources of personal information
We collect your personal information directly from you and/ or from LinkedIn.
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 LinkedIn, if necessary;
- To third parties who provide services to us (e.g. IT companies, telecommunication providers, advertising agencies);
- To our affiliates (https://www.efginternational.com/Contacts.html), only to the extent necessary to process your inquiry/ request, if you contact us via message, through the Platform;
- 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 will always be at the LinkedIn Company Page. By continuing to access the Platform and/ or the LinkedIn Company Page 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 social media presence in the Platform, LinkedIn 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 Platform (e.g. https://www.linkedin.com/legal/privacy-policy, https://legal.linkedin.com/pages-joint-controller-addendum and https://www.linkedin.com/legal/l/dpa).
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 you have given your consent (e.g. in the form of the clear affirmative action of sending us a message or submitting a leads form via the Platform);
- 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 evaluating our audience’s interactions with our LinkedIn Company Page in order to improve its content and in turn better inform you while minimizing any impact on your personal information and 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.
C. Do you have an obligation to provide personal information?
In the context of sending us a message or submitting a leads form via the Platform, you are only required to provide the personal information without which your inquiry/ request cannot be processed by us.
D. 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. If you do not give your consent or withdraw your consent this may affect our ability to provide you with services. 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 LinkedIn or in relation to us and LinkedIn, we will forward your request to LinkedIn to the extent that company is concerned. We will also forward your request to LinkedIn, in case you report to us your intention to assert any rights in relation to us and we need LinkedIn’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.
E. Retention of personal information
With respect to: (i) our LinkedIn Company Page insights provided by LinkedIn to us in the form of anonymized statistics; and (ii) the Marketing Activities, in the form of sponsored content displayed in the news feed of the Platform, please note that we have no influence on the deletion of your personal information by LinkedIn. As long as you follow or interact with our LinkedIn Company Page, your personal information will be stored on the Platform in a way visible to us, as described above. By deactivating your respective interaction or deleting your profile, you can ensure that the personal information is no longer accessible to us. Any further storage would be outside our control. For further information, please refer to the relevant privacy notifications delivered by LinkedIn through the Platform.
With respect to any personal information processed: (a) when you reach out to us through a message sent via the Platform or (b) for the purposes of the Marketing Activities, in the form of leads captured through the Platform, we will retain personal information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, reporting or internal policy requirements and/ or until you withdraw your consent. To determine the appropriate retention period for personal information, we consider the applicable legal requirements, as well as the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the time periods, during which such personal information may need to be retained as evidence in an actual or potential judicial context.
F. 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 or obtain further information on the retention periods of personal information, 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 social media presence in the Platform, LinkedIn 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 on the Platform (e.g. https://www.linkedin.com/legal/privacy-policy, https://legal.linkedin.com/pages-joint-controller-addendum and https://www.linkedin.com/legal/l/dpa).
B. Overseas transfers
Your personal information may be transferred (including made accessible from) by us 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.
