This Data Protection Notice radicant apps (“Notice”) provides any User of radicant apps (“You”, collectively “Users”) with an overview of how radicant bank ag, Mühlebachstrasse 162-164, 8008 Zürich, Switzerland (“radicant”) in its capacity of data controller, collects, uses and processes information You provide (“Personal Data”) when accessing and using radicant apps, as well as of security measures and precautions implemented by radicant to protect Your Personal Data.
We treat Your Personal Data as confidential and manage it pursuant to the Swiss Federal Act on Data Protection (FADP), the EU General Data Protection Regulation (GDPR), the UK GDPR, all in their current version (Data Protection Provisions) and this Notice.
You acknowledge that You are legally bound by this Notice once You accept it after downloading a radicant app and submitting Your email address or telephone number.
To the extent Your consent is necessary under applicable law, You provide consent to the collection, use and potential disclosure of Your Personal Data to third-party recipients in accordance with the terms of this Notice.
What is Personal Data?
Personal Data is any information relating to an identified or identifiable natural person. This includes information that directly identifies You and information that allows to indirectly identify You by reference to additional information (e.g., email address, customer number, phone number).
In which cases is this Notice applicable?
This Notice applies to any information collected by radicant through Your use of radicant apps and technologies radicant uses to improve Your user experience, such as tracking technologies, feedback forms, etc. It does not apply to:
- the use of the radicant website www.radicant.com;
- the data processing by companies that radicant does not own or control;
- third-party websites to which You might be directed by clicking on a link displayed in the radicant apps.
Am I obliged to provide My Personal Data?
Processing Your Personal Data is necessary for radicant to conclude a contract with You and to fulfil statutory and/or regulatory obligations. radicant cannot accept You as a client nor provide You with the product or service requested if radicant is unable to process Your Personal Data.
Do I have to inform radicant of any changes in My Personal Data?
radicant is obliged to keep Your Personal Data always correct and up to date. If any changes concerning Your Personal Data occur, please inform radicant without delay.
What kind of data does radicant collect?
radicant processes Your Personal Data lawfully, in good faith and only if it is necessary for (i) entering and executing a contract with You, (ii) the functioning and improvement of radicant apps, and (iii) upholding radicant’s legal obligations. If radicant processes Your Personal Data in context with a product or service provided within the radicant apps, such data processing is based on Your consent, except in cases where obtaining Your consent in advance is not possible due to practical reasons, and the processing of the data is permitted by law.
Identification
radicant is required to verify Your identity when You are opening a radicant bank account and establishing a business relationship with us. Therefore, radicant conducts online identification according to FINMA circular 2016/7 “Video and online identification” in its current version. The online identification must be based on a valid official identification document You provide when starting the identification process.
radicant will check if Your biometric facial features match the photograph in the identification document and compare the information obtained from the identification document with data You provided within the radicant app. For detailed information about how the online identification is conducted please refer to the “Terms of Use Identity Verification; Data Privacy Policy and Certification Practice Statement electronic signature” on our website.
Your data will be processed and stored to the extent necessary for compliance purposes such as politically exposed persons (PEP), sanctions, and adverse media screening. An initial transfer from an account in Your name from a bank in Switzerland, Liechtenstein or an EU/EEA member country is required to complete the identification.
Fingerprint and face recognition
You can log in to the radicant apps using fingerprint and face recognition if Your device supports these features. radicant does not receive or store Your biometric data. For more information on how these features work, please contact the relevant device provider.
Client data
For opening a radicant bank account and using radicant products and services within the radicant apps, Your Personal Data (e.g., first and last name, country of residence, date of birth, nationality, e-mail address, mobile phone number, tax domicile, documents to establish Your identity, information relating to Your account and Your accounts with other banks) is collected, processed, and stored.
radicant may use Your Personal Data for marketing purposes and for contacting You at a later point to inform you about additional services and features.
Sensitive Data
Sensitive data includes data relating to e.g., race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life, criminal records, and genetic and biometric data.
For compliance purposes radicant checks Your administrative and criminal records as well as potential sanctions against You of to fulfil regulatory requirements.
radicant suggests not to provide sensitive data where not required. Should You wish to provide sensitive data for any reason, radicant accepts this as Your explicit consent to use that data in ways described in this Notice.
Banking and Financial Information
For displaying information and offering all available features within the radicant apps, radicant collects, processes and stores:
- Transaction Information: Data relating to transactions You carry out within the radicant apps and Your Debit Card (e.g., Your IBAN, booking date, status, type of transaction, date on which a transaction is performed, related amount, information on the beneficiary), data related to Your Debit Card (e.g., card number, expiry date, CVC), data concerning Your credit balance, merchant category, location of the ATM, etc.. Data about outgoing and incoming payments will be collected, processed, and stored for compliance purposes such as e.g., KYC, AML checks, PEP and sanctions screening which will be conducted throughout the entire banking relationship between You and radicant.
- Financial information: Data relating to Your financial situation (e.g., assets, investment products, risk and investment profile including investment objectives, financial statements, liabilities, revenues, earnings, etc.).
The type of data collected depends on the banking or investment product selected. Data is stored in an encrypted form or using other comparable security measures.
Mobile payments by Wallet
To make contactless payments by using mobile payment services from respective providers, Your account information is converted into an encrypted token, which is used to authorise payments within those services. Your Personal Data will be shared with the providers of mobile payment services as they supply the underlying technology. Wallet Providers collect, and process information related to transactions and data stored in Your Device independently from radicant, for independent purposes governed by the contractual terms and conditions and privacy policy of the Wallet Provider.
radicant TWINT app
radicant provides You with an option to use the TWINT payment system through the radicant TWINT app. When using the radicant TWINT app, Your Personal Data are processed for the purposes of providing the services. Your transaction data (e.g., information about the merchant, the time, type and amounts of transactions made) may be analysed for marketing and advertising purposes. Additionally, types of offers you view, activate, and redeem are evaluated, to display offers and added-value services tailored for You in the radicant TWINT app. Offers from third parties that are not affiliated with radicant will only be displayed to You if the required consent has been given within the TWINT app.
Client Services
radicant will collect, process, and store Your Personal Data (e.g., name, first name, contract number, product type, language, telephone number, reason for contacting radicant, financial information provided, etc.) when You contact our client services to assist You with Your inquiries. The exchange between You and radicant will be recorded and stored regardless of the means used for communication for regulatory purposes, quality assurance as well as to better support You with future request.
Feedback
radicant might from time to time collect Your feedback regarding the design, functionalities, and services of the radicant apps within the apps. If You send us Your feedback radicant will process and store Personal Data You provide to us to address Your feedback and improve the radicant apps, products, and services. You should not enter any sensitive data or data particularly worth protecting (e.g., changes of address, deposits of money, credit rating) in free text fields. Sensitive data or data particularly worth protecting, feedback, and other matters must only be dealt with by contacting our client services at welcome@radicant.com.
Technical Data
radicant collects, processes, uses, and stores data that is generated when You use the radicant apps such as IP address, operating system of the device used to access the radicant apps, time, and date of access. This technical information is required to deliver the functionalities and services of the radicant apps. radicant uses such data for its own purposes as well as to further optimize Your experience. This includes technical administration of the radicant apps and system security.
Does radicant use analytics services and tracking technologies?
radicant uses analytics services and tracking technologies from Google, Salesforce, and Heap to enable statistical analysis of usage behaviour among radicant app Users. The information about Your use of the radicant apps is being processed and stored in Switzerland and abroad. The data collected is anonymised and is used by radicant for optimizing Your experience. Google, Salesforce, and Heap may pass on this information to third parties if legally required or if third parties analyse the data for them.
What is the legal basis for data processing?
According to the purpose of data processing, radicant processes Your Personal Data on the following legal basis:
- Legal obligations: radicant may be required by law or official order to collect, provide information on, or to disclose or deliver Your Personal Data (e.g., fulfilling control and reporting obligations under applicable financial and tax regulations, identity checks, fraud, and financial crime detection).
- Compliance obligations: to fulfil ongoing compliance obligations Personal Data and data about outgoing and incoming payments will be collected, processed, and stored for e.g., AML checks, PEP, sanctions, and transaction monitoring.
- Contractual obligations: to enter or execute contracts with You relating to the product or services You have selected, or to fulfil radicant’s obligations under such contracts.
Safeguard legitimate interests: protecting our business and the integrity of the financial markets, monitoring, and managing risks, receiving, and handling complaints, improving our products and services and our use of technology, and conducting market research, providing advice and information on the range of services provided. - Consent: for other purposes, Your Personal Data can be processed based on Your consent, which can always be withdrawn.
Does radicant support Push Notifications?
You may receive push notifications within the radicant app when You are logged in or using the radicant apps, or when Your device is locked or in sleep mode.
radicant uses push notifications to provide information and alerts associated with the use of the radicant apps. Sending push notifications is out of radicant’s control but is linked to the operating system push notification service (OSPNS) supported by each mobile operating system. Push notifications can be stopped in Your device settings.
How does radicant secure My data?
We collect, store, and process Your Personal Data confidentially and, using appropriate technical and organizational precautions. They include use of firewalls, password protection, access controls, encryption, anonymisation, and authentication technologies. We secure Your Personal Data against loss or manipulation as well as unauthorised access, by restricting the access to the employees and other parties who need to know that information to provide You products and services (need-to-know-access).
When You use the radicant apps, Your Personal Data is transmitted via an open network accessible to anyone. Data that You electronically transmit to radicant or radicant electronically transmits to You (e.g., contact form or email) is encrypted. radicant uses TLS certificates for data exchanges. However, the following risks might occur:
- data may be intercepted and viewed by third parties;
- even if sender and recipient are in Switzerland, data may be transferred uncontrolled abroad, where data protection might not be comparable to Switzerland;
- electronic messages may contain viruses or other malware which may result in diverse types of damages;
- the identity of the sender (e.g., email) and the content of the message may be faked or otherwise manipulated by unauthorized persons. Emails of doubtful origin and unexpected attachments to an email should not be opened.
Even in an encrypted transmission, the sender and recipient remain unencrypted in each case. It can, therefore, not be ruled out that data sent in such a way may be intercepted and viewed by third parties or that the contact with radicant may be traced. Unless otherwise expressly stated, radicant does not accept orders or instructions of any kind that are issued via email or by other electronic message transmission systems.
Does radicant process My data outside of Switzerland?
If Personal Data is transferred to other countries, radicant contractually agrees with the receiving party that the applicable laws and regulations are complied with. Depending on the kind of product or service that is used, Personal Data might be disclosed to third parties domiciled in countries which, in general, may not have an appropriate or equivalent to Switzerland level of data protection. However, if Personal Data is transferred to such a country, radicant puts in place contractual provisions stipulating that Your Personal Data shall continue to receive appropriate and robust protection (e.g., by agreeing on standard contractual clauses for data transfers between EU/EAA and non-EU countries). Nevertheless, all data transmitted abroad is not protected by Swiss law as it is not applicable. To this extent, radicant does not accept responsibility for the security of Your Personal Data and rejects all liability for direct and indirect damages.
Are there cases of automated individual decisions, including profiling?
radicant and third parties commissioned by radicant may process and combine, in an automated manner, Your Personal Data and preferences expressed within tools and services offered in the radicant apps, including automatically categorising Your transactions and creating statistics for Your account movements over set periods of time and for set recipients.
radicant uses Your data to evaluate certain aspects concerning You, to analyse or predict aspects pertaining to Your economic situation, personal preferences, interests, behaviours, locations, and movements (profiling). Profiling is used to create client segments so that radicant can provide You with targeted advertising or offers that are tailored to Your interests, but also to perform marketing research and product development. The data used for profiling may be obtained from radicant’s own sources, from publicly accessible sources and from contractually affiliated data providers.
Your data may lead to automated decisions, e.g., the receipt and execution of Your orders in an automated fashion. When radicant will use automated decision making, radicant will notify You, providing transparent information about our decision to rely on automated processing and our legal basis for doing so. You have the right not to be subject to a decision which is based solely on automated processing, and which produces legal or other significant effects to You. You have the right to object to the use of Your Personal Data for automated decisions. radicant ensures that a suitable contact person is available to You if You wish to express a view on any automated individual decision or where such opportunity to express a view is required by law.
Are third parties involved in processing My data?
radicant may, for the provision of its services to You (e.g., payment transactions, IT-systems, cloud and other support functions), if it is required by law (e.g., Automatic Exchange of Information for tax purposes) or based on Your consent, transfer or disclose Your Personal Data to its affiliates or third-party suppliers and subcontractors, based in Switzerland, the EU/EEA or in non-EU countries. Furthermore, radicant may transfer Your Personal data to third-party providers for data backup, security, and storage services, in Switzerland the EU/EEA, or in non-EU countries.
The affiliates and third-party suppliers are obliged to only use Your Personal Data in connection with the services they perform for radicant. They shall be bound by contracts offering the same degree of protection for Your Personal Data as specified in this Notice and in further applicable rules and regulations.
Third-party providers are bound to maintain appropriate levels of security and confidentiality and to process Your Personal Data only as instructed by radicant.
They need to impose the same obligations to their own sub-processors, in accordance with applicable laws and regulations.
If, in exceptional cases, services are outsourced to a provider abroad outside the EU/EEA, radicant will disclose this in accordance with applicable rules and regulations, where required.
How long will My data be stored?
Your Personal Data will be stored for the duration of the business relationship with radicant and subsequently for further years if necessary for the purposes it is being processed for, and to comply with obligations to preserve records according to banking, commercial and tax law. You can, at any time, exercise the right to erase Your Personal Data by following the instruction set out in the section “What data protection rights do I have?” radicant will proceed accordingly, where permitted by law.
What data protection rights do I have?
You are entitled at any time to request information about Your Personal Data processed by radicant and to exercise the following rights:
- Right to be informed whether Your Personal Data is being processed by radicant;
- Right to access;
- Right to rectification;
- Right to erasure (‘right to be forgotten’);
- Right to restriction of processing;
- Right to object, if the data processing takes place for the purposes of the legitimate interests of radicant;
- Right to data portability – if applicable;
- Right to lodge a complaint with the supervisory authority.
You are entitled at any time to withdraw Your consent to radicant processing Your Personal Data. Your withdrawal has effect for the future only. The processing already performed will not be affected. You are aware that objecting to the processing of Your Personal Data leads to the termination of all business relationships with radicant.
Who do I contact for exercising My rights?
If You wish to exercise Your rights, please contact: legal@radicant.com.
radicant accepts requests for information on data processing in writing (email) together with an appropriate proof of identity (e.g., passport, identity card).
You can send any other data protection inquiries to the following address: legal@radicant.com.
What can I do if something goes wrong?
This Notice and all matters arising out of or relating to it shall be governed by and construed under the substantial laws of Switzerland, excluding its conflict of law provisions.
All disputes arising out of or in connection with this Notice shall be submitted to the competent courts of the City of Zürich, Switzerland.
How often will this Notice for radicant apps be updated?
Given the rapid technological development, radicant continuously develops and improves the radicant apps. Similarly, radicant periodically examines if adjustments or extensions with respect to data protection are required. You will be notified of any amendments by appropriate means.
You can find the current version of this Notice in force, as amended from time to time here.
August 2023