Data Protection Notice

This Data Protection Notice (Notice) provides any User (“You”, collectively the “Users”) with an overview of how radicant bank ag, Mühlebachstrasse 162-164, 8008 Zürich, Switzerland (“radicant” or “We”) in its capacity of controller, collects, uses and processes information You provide (Personal Data) when accessing the website www.radicant.com (Website), as well as the security measures and precautions implemented by radicant to protect Your Personal Data. We treat Your Personal Data as confidential and handle it pursuing the Swiss Federal Act on Data Protection (FADP), the  EU General Data Protection Regulation (GDPR) , the UK GDPR, all in their current version (Legal Data Protection Provisions) and this Notice.

By accessing the Website or registering for any Service, You agree to have read, understood and to be bound by this Notice.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 any third-party recipient in accordance with the terms of this Notice. In case You are not able to read and / or understand this Notice or if You do not agree to be bound by it, You need to leave the Website.

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).

What are the exemptions to the application of this Notice?
This Notice applies to any information collected by radicant through Your use of the Website and tracking technologies we use. It does not apply to:

1. the use of the radicant app. A dedicated Data Protection Notice for the radicant app is available when accessing the radicant app;

2. other websites to which you have been directed by clicking on a link: the Website may contain links to third-party websites that are not operated or monitored by radicant. Please be aware that such third-party websites are not bound by this Notice nor by our Cookie Policy and that We are not responsible to their principles regarding the handling of Personal Data. We, therefore, recommend consulting and checking the individual Data Protection and Cookie Policies of third-party websites. Despite careful control of content, We accept no liability for the content of external links to third-party websites from which We expressly distance ourselves as We do not adopt these contents as our own. For further information on this topic please refer to our Terms of Use.

3. the data processing of companies that radicant does not own or control. Additional provisions may apply to certain data processing and radicant’s social media presence. The relevant provisions will be available on the relevant websites and apps
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Am I obliged to provide My Personal Data?
In certain circumstances processing Your Personal Data is necessary for radicant to fulfil statutory or regulatory obligations or for the conclusion or performance of a contract. radicant cannot accept You as a client or cannot provide You with the Service requested if it is unable to process Your Personal Data. If this occurs, radicant will inform You accordingly.

Do I have to inform radicant of any change in My Personal Data?
We are obliged to keep Your Personal Data correct and up to date. If any changes concerning Your Personal Data occur, please inform radicant within the shortest possible time.
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What kind of data is collected and for what purposes is it used for?
radicant only processes Personal Data lawfully, in good faith and only if this is necessary for the functioning of the Website and for the Website’s content and Services. If radicant processes Your Personal Data regarding a Product or a Service, 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 legal provisions.


Technical Data
Our web servers register non-personalized user data when You visit our Website. The permanent and temporary logfiles provide information about Your IP address, the last page You visited, the type of browser that You are using, date, time and data files requested. If the Website was accessed via a search engine, We log the search term You found us with.  This technical information is required to properly deliver the content of the Websites that You requested. radicant uses such data for its own purposes as well as to further optimize the user experience. This includes amongst others technical administration of the Website, system security and optimizing Your search experience.

Master Data
Certain services on our Website require You to provide Your Personal Data. If You decide to provide us with Your Personal Data (e.g., name, username, telephone number, date of birth, address or email address, account and contract number) using a form, subscribing to our newsletter, signing up for a waiting list, or otherwise via the Website,  radicant handles this information in compliance with the applicable data protection regulations. radicant may use Personal Data for marketing purposes and for contacting You at a later point to inform You about radicant services and news. By using our digital presence, You consent to the collection, use, and disclosure of this data in accordance with the terms of this  Notice. We store Your Personal Data only for the time necessary for the specified purpose or if there is a legal basis or legal requirement to store it.

Tracking Data
When You access  the Website , radicant collects so-called tracking data (e.g., time and date of access, plugins), which provide information about user behaviour. For data security reasons radicant stores the following access data: IP address, unique ID, date and time of access, name and URL of the file retrieved, search term, browser and operating system used. The Website uses so-called cookies. For further information on cookies please consult the applicable Cookie Policy. So-called plugins and components of third parties with whom radicant maintains marketing relationships may also be used to analyze Your behaviour. The plugins bear the third party’s logo and may consist of, for example, “Like” buttons. When You interact with plugins, the corresponding information is transmitted directly from  Your browser to the third-party provider’s system and stored there. Third-party components may also use cookies.

Sensitive Data
radicant does not seek any special categories of Personal Data (also called Sensitive Data) unless legally required for recruiting purposes. For information on how We use, process and protect Your Personal Data for employment with radicant, please refer to the Notice You find here (LINK). Sensitive Data include several types of 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, or criminal records. radicant suggest not providing Sensitive Data . Should You wish to provide Sensitive Data for any reason, radicant accepts this as Your explicit consent to use that data the way described in this  Notice or as described at the point where You choose to disclose Sensitive Data.  Your explicit consent will be required in a separate confirmation at the point where You choose to disclose them.
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What is the legal basis for data processing?
According to the purpose of data processing, radicant processes Your Personal Data on the following legal bases:

- Legal obligations: radicant may be required by law or official order to provide information to disclose or deliver Your Personal Data (e.g., fulfilling control and reporting obligations under applicable financial regulations, identity checks, fraud and financial crime).

- Contractual obligation: to enter into or execute a contract with You for the services or products You have requested, or to fulfil radicant’s obligations under that contract.

- Safeguard legitimate interests: protecting our businesses and the integrity of the financial markets, monitoring and managing risks, receive and handle complaints, improve our products and services and our use of technology and to conduct market research, 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.


What other tools and services are available on the Website?

Community, Co-Creation & Newsletter
If You sign-up to become a radicant, we will need from You an e-mail address as well as information  to ensure that the registration is being executed by You as the owner of the email address.   For this purpose, We establish a protocol of the sign-up to the community, the sending of the confirmation mail and the receipt of the confirmation. As a community member, You will receive our newsletter regularly and You will be able to participate in co-creation, a platform within the Website to exchange ideas and thought among Community members. You are entitled to cancel Your subscription/membership at any time within Your Profile. A designated link for this purpose can be found in every newsletter and on the Community page respectively. By deleting Your subscription/membership You will be no longer be eligible for co-creation. This data is being stored and analysed by radicant to optimize Your experience on our Website, to track Your preferences and to continuously adjust the content to Your interests. Your Personal Data will be deleted after the cancellation of the community membership.

Contact Form, Feedback
If You send us an email or use our feedback, and contact form integrated in our Website We will store the Personal Data You provided to us only to process Your request and improve our Website and  Services.  You should not enter any Sensitive Data or particularly worth protecting data (e.g., changes of address, deposits of money, credit rating). Sensitive or particularly worth protecting data and issues must only be dealt with by contacting our customer support at support@radicant.com. If You use one of the email contact addresses or contact forms published by radicant on its Website to contact radicant, You expressly authorize radicant to respond by the same means to the sender address. Entry of data related to Your banking relationship is at Your own risk, as radicant is unable to guarantee the confidentiality of the information transferred via public networks or networks operated by third-party providers, even if the encryption is enabled.

Customer Support
radicant will collect, process Your Personal Data (e.g., name, first name, contract number, product type, language, telephone number) when You use our customer support provided via different means (e.g., email, phone calls, chatbot (Radi)) in order to support You with Your enquiries concerning our Products and Services. The exchange between You and radicant will be stored regardless of the means used for communication for quality assurance purposes as well as better support You with future requests.

Chatbot (Radi)
radicant offers the chat feature (Radi) to assist You.

As Radi is a tool for answering the most common questions, We do not recommend You enter any data concerning Your banking relationship with radicant, nor any Sensitive Data or particularly worth protecting data.  Session data such as Your IP address, the time and date of contacting radicant, and general chat and conversation data as well as information on chat contents are stored to improve the quality of the service provided as well as to better understand Your requests.
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Google
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Web Analysis Service
We are using Google Analytics on our Websites, a web analysis service provided by Google Ireland Limited («Google»), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses its own cookies, which allow the analysis of user data. The information about Your use of our Website (including Your IP address) is being transmitted to a Google server in the U.S., where it is being stored. radicant has activated the anonymization of IP addresses on all its websites. Google will use this information to analyse Your use of the Website, to compile reports about Website activities for radicant and to generate further services connected with the use of the Website and the use of the internet. radicant has a legitimate interest in the analysis of the data. Google may also pass on this information to third parties if legally required or if third parties analyse the data for Google. Under no circumstance will Google connect Your IP address with other data held by Google. Sessions and campaigns are being terminated automatically after a certain time. Generally, a session is terminated after 30 minutes without activity and a campaign after six months. The maximum time limit for a campaign is two years. You can find more information about the Terms of Use and Data Protection at google.com/analytics/terms and policies.google.com.

You can prevent the installation of cookies by adjusting the preferences in Your browser. Please be aware that You will not be able to fully use all functionalities of our Website in case you do not allow the use of cookies. You can also prevent the collection of data generated by cookies and regarding Your use of the Website (including Your IP address) as well as the analysis of the data by Google by downloading and installing a browser add-on. Opt-out cookies prevent the future collection of Your data when visiting the Website. To prevent the collection of data across a set of different devices, You will need to complete the opt-out on all the systems used.

Search Engine
Our Website uses Google’s Custom Search Engine (CSE) as their main search engine. The provider is Google Ireland Limited («Google»), Gordon House, Barrow Street, Dublin 4, Ireland. The embedded search facility enables full-text search for content on our publicly accessible pages. This search facility can be accessed via the search box embedded in the page header of the individual websites concerned. When You enter a search term into the search box and then hit return or click on the search symbol, You activate the search function and Your results will be shown on a results page, which downloads the Google search results using a Google plug-in. This way data is transferred to the search service. The plugin developed and provided by Google is embedded by the operator in the search results page. When the search results page is accessed, the plugin enables automated communication (data exchange) between the search results page displayed and Google. The use of the search function provided by Google encompasses a dynamic transfer of data via Google. Data is not shared with Google until You conduct a search and thereby access the search results page. By using the search function within the search results page, You will at the same time share Your data with Google, but if You use our Websites without using Google’s user-defined search function, no data will be shared with Google. By using the search function and thus accessing the search results page, You consent to the data sharing with Google. This includes for example the search terms You enter and the IP address of Your device. If You are at the same time logged in with Google, Google can allocate the information directly to Your user profile. More information about how Google uses users’ data can be found in their Data Protection Statement at https://tools.google.com/dlpage/gaoptout.


‍Video Services

Youtube
Our Website uses plug-ins of the YouTube platform, which is being operated by Google Ireland Limited («Google»), Gordon House, Barrow Street, Dublin 4, Ireland. We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to their Website before they watch a video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out because of the expanded data protection mode. For instance, regardless of whether You are watching a video, YouTube will always establish a connection with the Google DoubleClick network. As soon as You start to play a YouTube video on our Website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages You have visited. If You are logged into Your YouTube account while You visit our Website, You enable YouTube to directly allocate Your browsing patterns to Your personal profile. You have the option to prevent this by logging out of Your YouTube account. Furthermore, after You have started to play a video, YouTube will be able to place various cookies on Your device. With the assistance of these cookies, YouTube will be able to obtain information about You. Among other things, this information will be used to generate video statistics with the aim of improving the user-friendliness of the Website and to prevent attempts to commit fraud. These cookies will stay on Your device until You delete them. Under certain circumstances, additional data processing transactions may be triggered after You have started to play a YouTube video, which are beyond our control. For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy https://policies.google.com/.

‍Vimeo
Our Website uses plug-ins of the video portal Vimeo. The provider is Vimeo Inc., 555 West 18th Street, New York 10011, USA. If You visit one of the pages on our Website into which Vimeo plug-in has been integrated, a connection to Vimeo’s servers will be established. Therefore, the Vimeo server will receive information as to which of our pages You have visited. Moreover, Vimeo will receive Your IP address. This will also happen if You are not logged into Vimeo or do not have an account with Vimeo. If You are logged into Your Vimeo account, You enable Vimeo to directly allocate You browsing patterns to Your personal profile. You can prevent this by logging out of Your Vimeo account.For more information on how Vimeo handles user data, please consult the Vimeo-Privacy Policy.

Social Pugins
radicant provides You the option to use social media buttons on our Websites. Thereby, we employ a solution, by which the buttons on the Website are included as a graphic only with a link to the relevant social media website. If You don’t click on the buttons, no data is being transmitted to the social media websites. Information about the use of Personal Data in the social media networks is available in the relevant providers’ conditions.


How does radicant secure data transfer and electronic communication?

General processing
We collect, store and process Your Personal Data confidentially and, using appropriate technical and organizational precautions. They include use of firewalls, personal passwords, encryption and authentication technologies. We secure Your Personal Data against loss or manipulation as well as unauthorized access, by restricting the access to the employees or other parties who need to know that information to provide You Products or Services (need-to-know access). When You visit  our Website,  Your Personal Data is transmitted via an open network accessible to anyone. Data that You electronically transmits to radicant or has radicant electronically transmitted to it (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 located 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 various types of damages. For anti-virus purposes, the use of up-to-date browser versions and the installation of antivirus software that is updated on an ongoing basis is recommended;

- 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.
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Cross-border processing
If Personal Data is transferred to other countries, radicant ensures 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 takes appropriate measures so that Personal Data continues to receive appropriate and robust protection (e.g., by agreeing on standard contractual clauses for data transfers between EU/EAA and non-EU countries). Notwithstanding, all data transmitted abroad are 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 reject 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 our Website and use them to evaluate certain aspects concerning You, in particular to analyze or predict aspects pertaining Your economic situation, personal preferences, interests, behaviors, locations or movements (profiling).

Profiling is used to create client segments so radicant can provide You with targeted advertising or offers that are tailored to Your needs and interests, but also to perform marketing research and product development.

The data used for profiling may be obtained from the radicant’s own sources, from publicly accessible sources and from contractually affiliated data providers. Your profile may in the future lead to automated individual decisions, e.g., the receipt and execution of Your orders in e-Banking in an automated fashion. When we will use automated decision making, We will notify You, providing clear 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 on You, You have the right to contact radicant, so We do not further use Your Personal Data for this purpose. 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, printing and dispatch of documents, IT systems, cloud and other support functions), 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 of data backup, security, cloud, 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 Users 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 Personal Data only as instructed by radicant. They need to impose the same obligations on 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 and subsequently if necessary for the purposes its being processed for, to comply with obligations to preserve records according to 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?” of this Notice.

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 of access by the data subject;
- 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 pursued by radicant;
- Right to data portability - if applicable;
- Right to lodge a complaint with a supervisory authority .

You are entitled at any time to withdraw Your consent to radicant processing Your Personal Data. Your withdrawal has effect only for the future. The process already performed is not affected.

Who do I contact for exercising My rights?
If you wish to exercise Your rights, please contact:

radicant bank ag
Mühlebachstrasse 162-164
8008 Zürich

radicant accepts requests for information on data processing in writing (email) together with an appropriate proof of identity (e.g., passport, identity card) to the contact address legal@radicant.com

ou 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 in accordance with 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 Canton of Zürich, Switzerland.

How often will this Notice be updated?
Given the rapid technological development of the internet, radicant continuously develops and improves its Website. Similarly, We periodically examine if adjustments or extensions with respect to data protection are required. You can find the current version of this Notice in force, as amended from time to time, on our Website.

20.10.2022