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Legal Disclaimer

The following legal information and privacy policy address business partners of SOBACO Holding AG and its subsidiaries [1] (hereinafter referred to as sobaco-incore) as well as visitors to the website www.sobaco-incore.com.

 

Important legal information on the website of sobaco-incore

Use of the website of sobaco-incore
The entire content of the website of s protected by copyright (all rights reserved). Individual pages and/or parts of the sobaco-incore website may only be downloaded and/or printed out if the copyright marks and other designations protected by law are retained. Whenever you download, print or reproduce any data from the sobaco-incore website, all rights of ownership are retained by sobaco-incore and the relevant third-part owners. Reproduction, transmission (by electronic or other means), modification, linking or use of any or all of the sobaco-incore website for public or commercial purposes is prohibited.

Not an offer
The information published on the sobaco-incore website does not constitute a call or offer or recommendation to buy or sell investment instruments or to undertake any transactions or conclude any legal transaction.

No guarantees, no liability
sobaco-incore has taken every effort to obtain the information on this website from known reliable sources. Information sourced from third parties is checked by sobaco-incore, however sobaco-incore and third parties provide no statement as to the accuracy, reliability and completeness of the information and views provided on the website. The information and views distributed on the sobaco-incore website are provided by sobaco-incore and third parties purely for private use and information purposes and are subject to modification at any time without prior notice. The data on the sobaco-incore website does not constitute formal decision-making information for any legal, tax or other queries not should any such investment or other decisions be made on this basis. No guarantee whether express or implied is given for the accuracy, currency and completeness of the information and data made available on the sobaco-incore website. sobaco-incore and third parties shall bear no liability for any losses or damages of any type, whether direct, indirect or consequential, suffered as a result of or in connection with the access to the use, performance or queries of the sobaco-incore website or its links to other websites, even if sobaco-incore or third parties have been informed of the possibility of such damages.

Local statutory restrictions
The sobaco-incore website is not intended for use by persons who are subject to laws that forbid the publication or access of the sobaco-incore website (on the basis of the nationality of the affected person, their place of residence or other reasons). Persons who are subject to such restrictions are not permitted to use the sobaco-incore website. In particular this relates to persons in the United Kingdom, Japan, the USA and other countries in which the offer of such products and services is subject to limits.

 

Privacy policy of sobaco-incore

General

In the scope of its operational activities, sobaco-incore complies with the legal requirements of the Swiss Data Protection Act (DPA) and the European General Data Protection Regulation (GDPR).

This privacy policy explains how sobaco-incore processes personal information about business partners and visitors to this website. The term «process» covers all handling of personal data, irrespective of the tools and procedures used, in particular the storage, disclosure, procurement, deletion, saving, modification, destruction and use of personal data. «Personal data» refers to all information relating to an identified or identifiable person. In addition, the privacy policy describes how sobaco-incore guarantees the security of the personal data it processes.

The visitor agrees that sobaco-incore processes personal data in accordance with the policy. Statutory or contractual confidentiality obligations imposed on sobaco-incore with regard to the visitor’s personal data are not affected by this policy.

Processing and protection of personal data

Personal data is processed in particular for the following purposes:

  • to agree contracts with business partners;
  • for technical administration and research;
  • for further development of the websites;
  • for user administration and marketing;
  • to provide information to users about sobaco-incore’s services and products, insofar as the user has given consent for this purpose.

The visitor authorizes sobaco-incore to pass on personal data to employees, subcontractors or third parties within or outside the visitor’s country of residence in order to provide services and for the aforementioned purposes. Employees, subcontractors and third parties that are granted access to personal data are obliged by sobaco-incore to comply with all applicable data protection regulations. Persons to whom sobaco-incore grants access to personal data in the scope of this policy will receive appropriate training in data security and data protection.

Data collected

sobaco-incore processes personal data (e.g. name, gender, address, e-mail address, telephone or fax number) about the visitor whenever the visitor visits websites of sobaco-incore or otherwise explicitly provides sobaco-incore with this data. This includes registration for specific services or web content that can only be accessed using a personal login, as well as subscriptions to print media or online newsletters. This also applies if the user participates in events (in person or online) run by sobaco-incore. In some cases, personal data is processed when sobaco-incore records telephone calls from users, whether for training or quality assurance purposes, or to meet its statutory obligations. The sobaco-incore web server automatically records details of the user’s visit (like the IP address, browser type and version, operating system used, previous website, pages accessed, date and length of visit).

Data security

The websites are protected by appropriate technical and organizational measures against loss, destruction and manipulation as well as against access, modification and distribution by unauthorized persons.

sobaco-incore protects personal information using appropriate physical, digital and procedural safeguards, including firewalls, personal passwords, encryption and authentication technologies. When sobaco-incore collects personal data through one of its websites, the data is transferred in an encrypted form using the currently most common and secure Secure Socket Layer (SSL) technology.

sobaco-incore stores the data collected when users access the websites as well as the data collected by cookies or entered in contact forms on registration pages exclusively on its own servers in Switzerland, which are protected by appropriate security measures.

sobaco-incore reserves the right to transfer personal data to government and supervisory authorities as well as, within the scope of this declaration, to analysis service providers. sobaco-incore fully complies with the applicable regulations, legislation and any court or official requirements.

Information about personal data being processed

Individuals whose personal data are processed within the scope of this policy have the following rights:

  • to obtain information about whether and which personal data is held by sobaco-incore (categories of data, recipients or categories of recipients, retention period of the personal data or criteria used to determine the retention period);
  • to obtain a copy of the personal data;
  • to request the deletion of personal data;
  • to demand restrictions on the processing of personal data;
  • to obtain personal data in a structured, common and machine-readable format;
  • to object to the processing, in particular for the purpose of direct marketing.

The above-mentioned rights may be denied or restricted if the interests, rights or freedoms of third parties prevail or if processing serves sobaco-incore’s enforcement, exercise or defense of its legal claims.

Queries related to processing of personal data must be addressed to the sobaco-incore data protection officer:

InCore Bank Ltd.
Compliance
Wiesenstrasse 17
CH-8952 Schlieren/Zurich

E-mail: compliance@incorebank.ch

Right to withdraw consent and right to complain

All data subjects whose personal data is processed may withdraw their consent to processing at any time. The instruction withdrawing consent is to be made in writing or by e-mail to the data protection officer of sobaco-incore.

Data subjects whose personal data is processed have the right to complain to a competent supervisory authority for data protection. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Links

sobaco-incore’s websites may contain hyperlinks to other websites that sobaco-incore does not operate or monitor. Third party websites are not subject to this policy. sobaco-incore is not responsible for their content or for their use of personal data.

Google Analytics

This website uses the Google Analytics component (with anonymization function). Google Analytics is a web analytics service. Web analytics means the collection, collation and evaluation of information about the behavior of visitors to web pages. The information captured by the web analytics service includes the web page from which a data subject arrived at the current web page (the referrer), the subpages of the website that have been accessed and the frequency and length of visits to subpages. Web analytics is primarily used to optimize a web page and carry out a cost-benefit analysis of web advertising.

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

The additional function «_gat._anonymizeIp» is used for the Google Analytics web analysis. This additional function abbreviates and anonymizes the IP address of the data subject’s internet connection when our web pages are accessed from a Member State of the European Union or from another country in the European Economic Area.

The purpose of using the Google Analytics component is to analyze visitor flows to our website. Google uses the data and information obtained in order to evaluate the use of our website, produce web reports for us showing the activities on our website, and to provide other services in connection with the use of our website.

Google Analytics places a cookie on the data subject’s computer. By setting this cookie, Google is able to analyze the use of this website. Each time one of the individual pages of this website that is operated by the processor and on which a Google Analytics component has been installed is accessed, the web browser on the data subject’s computer 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 of the data subject, that may be used by Google to track the origin of visitors and clicks and subsequently to enable computation of commissions.

The cookie is used to store personal information such as the access time, the location from which an access originated and the frequency of visits to our website by the data subject. Each time the data subject accesses the website, these personal data including the IP address of the Internet connection used by the data subject are transferred to Google in the United States of America. These personal data are stored in the United States of America by Google. Google may share this personal information collected by means of the technical process with third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by configuring the appropriate web browser settings and thus permanently object to the setting of cookies. Such a configuration of the web browser settings would also prevent Google from setting a cookie on the data subject’s computer. In addition, a cookie already set by Google Analytics can be deleted via the web browser or other software programs at any time.

Furthermore, it is possible for the data subject to object to and prevent the collection of data generated by Google Analytics about the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to web pages may be transmitted to Google Analytics. Installing the browser add-on is considered by Google to be withdrawal of consent. If the data subject’s computer system is deleted, formatted or reinstalled at a later time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or by a person within his/her sphere of control, it may be reinstalled or reactivated.

More information about Google’s current privacy policy can be found at www.google.de/intl/de/policies/privacy/ and www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link www.google.com/intl/de_en/analytics/.

Social media buttons

The sobaco-incore websites integrate functions (in the form of plug-ins) of third-party providers or social media platforms (LinkedIn, Xing, Google+, etc.). These plug-ins allow the user to share content on the aforementioned social networks. The buttons are deactivated by default when the website is accessed. This means that no personal data is transmitted to the respective third-party providers without the user’s intervention. When the user activates the buttons, the plug-ins automatically transmit data including personal data to the corresponding third-party provider. If the user is logged into the network of the respective third-party provider at the same time, the third-party provider can match the visit to the user’s social media account. sobaco-incore has no influence over this. The purpose and scope of this data collection and the further processing and use of personal data are subject to the privacy policies of the corresponding social networks. These also provide users with information on rights and settings in relation to protection of their privacy.

Hotjar

sobaco-incore uses Hotjar as part of its services. Hotjar uses cookies. Hotjar processes stored anonymous information (e.g. click behavior, IP addresses, geographical location, browser type, length of visit, pages accessed) on behalf of sobaco-incore in order to prepare reports on the use of the website. sobaco-incore can also carry out targeted marketing activities on the basis of this information. Hotjar processes the data in Ireland. More information can be found at https://help.hotjar.com/hc/en-us/sections/115003180467-Privacy-Security-and-Operations.

Modifications

sobaco-incore may unilaterally make changes to this policy at any time. The current version will be published online.

Last updated

Last updated on: February 8, 2019

 

[1] SOBACO Solutions Ltd., SOBACO Betax Ltd., InCore Bank Ltd.