Version valid from August 1, 2020 (based on DSAT.ch)
With this data protection declaration, we, Honesto AG, a company registered in Liechtenstein with the address Poststrasse 2, 9494 Schaan (hereinafter “Honesto”, “we” or “us”) describe how we collect and process personal data. This data protection declaration is not a comprehensive description of our data processing. It is possible that other data protection declarations or general terms and conditions, conditions of participation or similar documents may apply in special circumstances.
COLLECTION AND PROCESSING OF PERSONAL DATA
We primarily process personal data that we receive from our customers and other business partners and other persons as part of our business relationships with them or that we collect from users when operating our websites, apps and other applications.< p>To the extent permitted, we obtain certain personally identifiable information from publicly available sources or we receive such information from Honesto affiliates, government agencies, or other third parties.
As part of our business relationship, you must provide us with all personally identifiable information Provide data that is necessary for the conclusion and implementation of a business relationship and for the fulfillment of our contractual obligations. Without this information, we are usually unable to enter into or perform a contract with you (or the company or person you represent). In addition, the website cannot be used unless certain information is disclosed to enable traffic (e.g. IP address).
DATA SECURITY AND DATA TRANSFER
We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse.
In the course of our business activities and in accordance with the above reasons for data processing, we may transfer data to third parties to the extent that such transfer is permitted and we deem it appropriate for them to process data for us or, where appropriate, for their own purposes. In particular, the following categories of recipients may be affected (collectively “Recipients”):
• our service providers (either internal or external, such as e.g. banks, insurance companies), including processors (such as e.g. IT providers);
• dealers, suppliers, subcontractors and other business partners;
• domestic and foreign authorities or courts;
• the media;
• the public, including users of our websites and social media;
• competitors, industry bodies, associations, organizations and other entities;
• acquirers or parties interested in acquiring any business, company or other part of Honesto;
• other parties in potential or pending legal proceedings;
• Honesto affiliates;
Certain recipients may be located within Liechtenstein, but they may also be located in any country worldwide. In particular, you must expect that your data will be transferred to Switzerland, any country in Europe and the USA, depending on where our service providers are located.
We transfer data to a country without adequate legal data protection, we ensure an adequate level of protection as required by law, through the use of appropriate contracts (in particular based on the European Commission’s Standard Contractual Clauses, which can be accessed here) or binding corporate rules, or we invoke the legal exceptions of consent, the fulfillment of a contract, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal data or because it is necessary to protect the integrity of the data subjects.
PURPOSE OF DATA PROCESSING AND LEGAL GROUNDS
We use the collected data primarily to conclude and process contracts with our customers and business partners, in particular in connection with the use of our “Best Price App” and the procurement of products and services from our suppliers and subcontractors, as well as to fulfill our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a customer or business partner.
In addition, in accordance with applicable law and where appropriate, we may process your personal information and the personal information of third parties for the for the following purposes, which are in our (or, where applicable, the legitimate interests of third parties)
• To provide and develop our products, services and websites, apps and other platforms on which we operate;
• Communicating with third parties and processing their enquiries;
• Reviewing and optimizing processes for determining needs for the purpose of directly addressing customers and obtaining personal data from publicly accessible sources for customer acquisition;
• Advertising and marketing (if If you belong to our customer base and receive our advertising, you can object at any time and we will put you on one Blacklist against further commercials);
• Market and opinion research, media monitoring;
• Assertion of legal claims and defense in legal disputes and official proceedings;
• Prevention and investigation of criminal offenses and other misconduct (e.g. Conducting internal investigations, data analysis for fraud prevention);
If you have given us your consent to process your personal data for specific purposes, we will process your personal data within the scope and on the basis of that consent, unless , we have another legal basis if we need one. A given consent can be revoked at any time, but this has no influence on the data processed before the revocation.
In accordance with applicable law and to the extent provided for by law, you have the right to access, correct and delete your personal data, the right to restrict processing or to object to our data processing and the right to request certain personal data transfer to another controller (data portability).
Please note, however, that we reserve the right to enforce legal restrictions on our part. Please also note that the exercise of these rights may conflict with your contractual obligations and this may lead to consequences such as early termination of the contract or incur costs. If this is the case, we will inform you in advance, unless this has already been contractually agreed.
In general, the exercise of these rights requires that you are able to prove your identity (e.g. by a copy of identification documents if your identity is not otherwise apparent or cannot be verified in any other way). To assert these rights, please contact us at the addresses given above.
In addition, every data subject has the right to assert their rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Liechtenstein is the Office for Data Protection (http://www.sds.llv.li).
By using our website and consenting to receive newsletters and other marketing emails, you consent to this that we use such techniques. If you object, you must configure your browser or email program accordingly.
In accordance with applicable law, we may use visible and invisible image files in our newsletters and other marketing emails. When such image files are retrieved from our servers, we can determine if and when you opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You can disable this in your email program, which will usually be the default setting.
We use Google Analytics or similar services on our website. Google Analytics was built in through Google Tag Manager. These are third-party services that may be located in any country worldwide (in the case of Google Analytics, Google LLC in the USA, www.google.com) and that allow us to analyze the use of our website (on an anonymous basis) to measure and evaluate.
Permanent cookies set by the service provider are used for this purpose. The service provider does not receive (and store) any personally identifiable information from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited that are also tracked by the relevant service provider, and may use this information for own purposes (e.g. to control advertising). If you have registered with the service provider, the service provider will also know your identity. In this case, the service provider will process your personal data in accordance with its data protection provisions. The service provider only provides us with data about the use of the respective website (but no personal data from you).
RETENTION PERIODS FOR YOUR PERSONAL DATA
We process and store your personal data for as long as is necessary to fulfill our contractual obligation and to fulfill legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the fulfillment of the contract until its termination) and beyond this period in accordance with the statutory storage and documentation obligations.
Personal data can be stored for as long as claims can be asserted against our company or as far as we are otherwise legally required to do so are obliged to do so or if legitimate business interests require further storage (e.g. for evidence and documentation purposes).
As soon as your personal data are no longer required for the above purposes, they will be deleted as far as possible or anonymized. For operational data (e.g. system logs), shorter retention periods of a maximum of twelve months usually apply.
PROFILING AND AUTOMATED DECISIONS IN INDIVIDUAL CASE
We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling enables us to provide you with more detailed information and advice about products that may be relevant to you. For this purpose, we may use evaluation tools that enable us to communicate with you and, if necessary, to advertise to you, including market and opinion research.
When establishing and conducting a business relationship, we usually use no fully automated individual decisions (e.g. according to Article 22 DSGVO).
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Dr. iur. Hans Kuhn LL.M.
«Honesto hat ein einzigartiges Produkt mit einem sehr innovativen technischen und operativen Aufbau mit hervorragenden Partnern wie der InCore Bank entwickelt. Das hat bisher noch niemand gemacht.»
«Der Aufbau der honesto App ist schlank, brillant und hat das Potenzial, die Branche zu verändern.»
«Die InCore Bank gehört zu den ersten etablierten Finanzdienstleistern weltweit, die das Potenzial von digitalen Assets wie Kryptowährungen und Investment-Token erkannt haben. Wir sind überzeugt, dass die Honesto-App einem grossen Bedürfnis entspricht und eine entsprechende Nachfrage im Markt besteht.»