SIX Interbank Clearing Privacy Statement

It applies to all natural persons with whom we come into contact (referred to as “you” in this docu­ment). This includes employees, company officers and directors, financial stakeholders and all personnel of our customers, service providers, supervisory authorities, and other business partners.

Data protection is a top priority for SIX Interbank Clearing Ltd; this applies in particular to the processing of personal data.

Our services are offered only to institutions authorized by FINMA, the Swiss National Bank (SNB) or
a comparable foreign authority. Participation requires a contract with SIX Interbank Clearing Ltd.

Personal data may be included in the transactions that we process on behalf of participants.

In order to fulfill our business purposes, we require contact information about the employees of our participants.

SIX Interbank Clearing Ltd is responsible for the processing of personal data.

SIX Interbank Clearing
Hardturmstrasse 201
8005 Zurich
Switzerland

We Process Personal Data:

• For the purpose of concluding a contract with participants
• To fulfill a contractual obligation
• To comply with legal requirements
• To pursue legitimate business interests, e.g., for compliance with the security provisions for our premises and IT infrastructure

We Process Personal Data for the Following Reasons:

• To provide services and products to the participants including any communications required to deliver them
• To receive requests and to improve our service and product quality
• To receive, investigate and respond to customer complaints
• To inform participants, suppliers and service providers
• To inform supervisory authorities (especially the SNB and FINMA)
• To manage relationships with participants, suppliers and service providers
• To carry out analyses with the intention of strengthening our relationships and improving our service and product offerings
• For testing and support purposes
• To operate and maintain our information technology platform
• To establish, exercise and/or defend legal claims and rights
• To protect, exercise and enforce our rights, property and security, or to assist participants, suppliers, service providers and other third parties to do so
• To undertake corporate marketing
• For other purposes as disclosed at each opportunity

In most cases, the personal data processed by SIX Interbank Ltd is limited to basic information on individuals. In general, this includes name, job title, business function, work address, telephone number and email address.

Other categories depend on the respective services, e.g., the provision of banking relationship data and account numbers in the transaction data.

We Collect Data From:

• Our participants, when they
  – Provide us with contact details for relationship management, sales, or other purposes
  – Send us data in either electronic or printed forms via e-mail or physical mail
  – Provide us with information for client on-boarding
  – Provide us with data for a contract or a service agreement (including invoicing)
  – Provide us with data to address operational problems, for customer satisfaction and other market-related surveys, for service improvements, and similar legitimate reasons
  – Instruct us to process transactions for settlement
• Our service providers when such data is required to
  – Establish and maintain a contact
  – Enter into and maintain contracts, service level agreements and other types of service descriptions
  – Facilitate billing and payment
  – Monitor and control service delivery to ensure and enhance quality
  
• From other sources, such as
  – Background information from third party providers
  – Information from regulatory authorities
  – Information from publicly available sources

Personal data may be disclosed to and/or transferred to

• Our partners within and outside SIX Group Ltd if the data is included in business transactions to be processed by the partners or in the context of issue and problem resolution, contract management, service and invoicing requests, requests of your compliance office, and general participant support
• The Swiss National Bank (SNB)
• FINMA, law enforcement agency or tax authorities
• Our auditors and legal advisors involved
• Our technology suppliers that provide support for incident handling
• Other persons where disclosure is required by law

Personal data can be transferred to other legal entities within SIX Group Ltd as well as the to relevant supervisory authorities, law enforcement and tax authorities, courts, service providers involved and other partners within and outside Switzerland and the European Economic Area (EEA). This includes countries whose data protection standards deviate from those of the EEA standard. When we transfer your personal data to service providers, other SIX Group Ltd entities or partners in these countries, we will ensure that they protect your personal data in accordance with EEA-approved standard data transfer agreements or other appropriate safeguards. Data transfers currently take place from and to Liechtenstein.

As a general rule, we keep personal data as long as we have a client relationship. After a contractual relationship ends, we are required to maintain that data for a period of 10 years. In cases where the relevant client or counterparty informs us that employment of a certain person has ceased, the retention period starts from that point in time.

You can ask us to: (i) to provide information on whether we may save personal data and what form this personal data may take (which categories of data, recipients or categories of recipients, retention periods for Personal Data or criteria governing retention periods) ; (ii) erase your personal data; or (iii) restrict our processing of your personal data. You may also opt out of the processing of your personal data for direct marketing purposes or object to our other processing of your personal data. These rights will be limited in some situations; for example, where we are required by law to process your personal data.

To exercise these rights or if you have questions about how we process your personal data, please contact us using the contact details on the last page. You may also raise objections to the relevant data protection authorities where you live or work or where the alleged infringement of data protection law occurred.

This Privacy Statement was last updated on 1 December 2021. Future updates may be required in response to changing legal, technical or business developments.

To exercise your rights with regards to data protection please use this link.

You can also direct your queries to: SIX Group Services Ltd, Data Protection Officer, Hardturmstrasse 201, 8005 Zurich, Switzerland, e-mail: dataprotection@six-group.com