Directive Data Protection

In this Data Protection Policy, we, as a registered occupational benefits foundation, explain how we collect and process personal data. This is not an exhaustive description; other data protection guidelines in affiliation agreements, service agreements, terms of use for web services, conditions of participation and similar documents may regulate further specific matters relevant to data protection. Personal data is understood to be all information that relates to a specific or identifiable person. If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this Data Protection Policy and only share their personal data with us if you are allowed to do so and if this personal data is correct.

This Data Protection Policy is based on the Swiss Data Protection Act (revDSG) and, where applicable, the EU General Data Protection Regulation (GDPR).

1. Person responsible / internal data protection officer / external data protection agency

Avanea AG in Wädenswil is responsible for our data processing.

If you have any questions about our data processing or data protection policy, you can send them to the following contact address:


 Avanea Ltd.

Internal Data Protection Officer 

Merkurstrasse 3 

8820 Wädenswil




2. Definition

This policy uses data protection terms that are based on the legal definitions. They mean the following: 

2.1 Personal data

Personal data is any information that relates to an identified or identifiable natural person; a natural person is considered identifiable if Avanea or recipients of the data can directly or indirectly identify the natural person on the basis of the information. As a rule, this includes general personal data such as surname, first name and contact details as well as customer numbers and other identifiers that Avanea collects and processes about the data subject (e.g. an employee, insured person, beneficiary or Avanea customer). It also includes financial data and health data relating to a data subject.

2.2 Personal data requiring special protection

Categories of particularly sensitive personal data: Data on religious, philosophical, political or trade union beliefs or activities; data on health, privacy or racial or ethnic origin; genetic data, biometric data uniquely identifying a natural person; data on administrative or criminal prosecutions or sanctions and data on social assistance measures.

2.3 Person concerned

Data subject” means the natural person about whom personal data are processed.

2.4 Edit

Processing means any handling of personal data, regardless of the means and procedures used, in particular the acquisition, storage, keeping, use, modification, disclosure, archiving, deletion or destruction of personal data.

3. Collection and processing of personal data

As the data controller, we primarily process the personal data that we receive in the context of our existing or yet to be concluded business relationships with our clients and potential clients, other business partners of these and other persons involved in this, in particular in connection with the preparation of offers, the conclusion and processing of affiliation contracts with employers and thus also with the administration of pension solutions for their employees.

To the extent permitted, we also take certain data from publicly accessible sources (e.g. debt collection register, land registers, commercial register, press, internet) or receive such data from authorities, doctors, clinics, insurance institutes and other third parties (data such as diagnoses, medical histories, etc.). 

In addition to the data about you that you give us directly, this refers to the categories of personal data that we receive about you from third parties, in particular 

  • Information from your previous employee benefits institution, from public registers, information that we learn in connection with official and legal proceedings
  • Information relating to your professional functions and activities (for example, so that we can use you to enter into and conduct business with your employer).
  • Information about you in correspondence and meetings with third parties, credit reports (where we deal with you personally)
  • Information about you given to us by people close to you (family, advisors, legal representatives, doctors, etc.) so that we can conclude or process contracts with you or involving you (e.g. have health checks carried out, references, your address for deliveries, powers of attorney, information on compliance with legal requirements, information from banks, insurance companies, sales and other contractual partners of ours on the use or provision of services by you (e.g. payments made, purchases made)).
  • Information from the media and internet about your person (if this is appropriate in the specific case, e.g. in the context of an application, press review, marketing/sales, etc.).

4. Purposes of data processing and legal basis

We use the personal data we collect primarily to be able to ensure the administration of the pension solution for our insured persons, or to conclude and process contracts with our customers and business partners, such as in particular services from our suppliers and subcontractors, as well as to fulfil our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may also be affected in this capacity.

In addition, we also process personal data of you and other persons, to the extent permitted and deemed appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose, unless we are already entitled to do so on the basis of your consent or for the performance of the contract:

  • Offer and further develop our offers, services, websites or IT or digital solutions;
  • Communication with third parties and processing of their requests (e.g. applications);
  • Review and optimisation of needs assessment procedures for direct client engagement and collection of personal data from publicly available sources for client acquisition;
  • Advertising and marketing (including the organisation of events), insofar as you have not objected to the use of your data (if we send you advertising or a newsletter as an existing customer of ours, you can object to this at any time and we will then put you on a blocking list against further mailings);
  • Market and opinion research, media monitoring, insofar as you have not objected to the use of your data for this purpose;
  • Assertion of legal claims and defence in connection with legal disputes and official proceedings;
  • Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
  • Guarantees of our operations, in particular IT, our websites and other platforms;
  • Monitoring activities to maintain IT, building and facility security and protect our employees and other persons and assets entrusted to us (such as access controls, network and mail scanners, telephone but not voice recordings);
  • Transfer of insured person data to other pension funds in the context of affiliation transfers to these institutions as well as the processing of insured person data by pension fund experts;
  • Purchase and sale of securities, real estate and other transactions under company law and the related transfer of personal data as well as measures for business management and insofar as for compliance with legal and regulatory obligations as well as internal regulations.

Insofar as you have given us consent to process your personal data for specific purposes (e.g. when registering as an insured person, when you register to receive newsletters, when applying for a job or when undergoing a health check), we process your personal data within the scope of and based on this consent, insofar as we have no other legal basis and we require such a basis. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.

5. Cookies and other technologies related to the use of our website

The internet pages use cookies. Cookies do not contain viruses. Cookies serve to make our offer more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.

We mainly use so-called “session cookies”. They are automatically deleted after the end of your visit. Other cookies remain stored on your terminal device until you delete them. These other cookies enable us to recognise your browser on your next visit.

You can control and regulate the use of cookies yourself via your browser settings. You can set your browser in such a way that you only allow the use of cookies in individual cases and are informed about the setting of cookies. Furthermore, you can exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser. Note: If cookies are deactivated, the functionality of this website may be limited. Cookies that are required to carry out the electronic communication process are stored. The website operator has a legitimate interest in storing cookies for the technically error-free and optimised provision of its services.

SSL encryption

Diese Seite nutzt aus Sicherheitsgründen und zum Schutz der Übertragung vertraulicher Anfragen die Sie an uns als Seitenbetreiber senden, eine SSL Verschlüsselung. Eine verschlüsselte Verbindung erkennen Sie daran, dass die Adresszeile des Browsers von “http://” auf “https://” wechselt und an dem Schloss-Symbol in Ihrer Browserzeile.
Wenn die SSL- bzw. TLS-Verschlüsselung aktiviert ist, können die Daten, die Sie an uns übermitteln, nicht von Dritten mitgelesen werden.For security reasons and to protect the transmission of confidential enquiries that you send to us as the site operator, this site uses SSL encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.


If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

5.1 Cookie settings

By using our website, you accept the use of cookies as explained above. Individual restrictions on the use of cookies can be created via your browser. However, the functionality of this website may be limited if cookies are deactivated.

5.2 Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies, which are stored on your device and enable an analysis of the website by you.
The information generated by the cookie about your use of the website, such as browser type, operating system used, referrer URL (the previously visited page), IP address and time of server request are transmitted to a Google server in the USA and stored there. The IP address transmitted by your browser in this context will not be merged with other Google data. We have also added the code “anonymizeIP” to Google Analytics on this website. This ensures that all data is collected anonymously. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
In the case of Google Analytics, Google uses the data on our behalf to evaluate your use of the website, to compile reports on website activities and to provide us with other services related to website and internet use.
Google uses so-called standard contractual clauses for data transfers to a third country outside the EEA, Switzerland or the United Kingdom in order to ensure a level of data protection that corresponds to Swiss data protection law.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. Instructions on how to prevent the processing of your data by the web analysis service can be found here.
Further information: You can find Google’s privacy policy here, as well as the standard contractual clauses used by Google for data transfers to a third country.

6. Data transfer and data transmission abroad

In the course of our business activities and for the purposes set out in section 3, we also pass on data to third parties where permitted and where we consider it appropriate, either because they process it for us or because they want to use it for their own purposes. This involves the following categories of recipients:

  • Service providers of ours, including contract processors (such as IT providers, IT maintenance);
  • Dealers, suppliers, subcontractors and other business partners;
  • Customers;
  • Domestic and foreign authorities, official agencies or courts;
  • Sector organisations, associations, organisations and other bodies;
  • other parties in potential or actual legal proceedings;

all hereinafter referred to as the “Recipient”.
These recipients are partly domestic, but can be anywhere in the world. If we transfer data to a country without adequate legal data protection, we ensure an adequate level of protection as provided for by law by using appropriate contracts (e.g. by means of standard data protection clauses or rely on the legal exceptions of consent to the performance of the 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.

You can obtain a copy of the contractual guarantees mentioned at any time from the contact person mentioned under point 1, unless already stated above. However, we reserve the right to black out copies for reasons of data protection or confidentiality or to supply only excerpts.


7. Duration of the retention of personal data

We process and store your personal data as long as it is necessary for the fulfilment of our contractual and legal obligations or otherwise for the purposes pursued with the processing. This means, for example, for the duration of the entire business relationship (from the initiation and execution to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the time during which claims can be asserted against our foundation and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as a matter of principle and as far as possible. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less generally apply.

8. Data security

We take appropriate technical and organisational security measures to protect your personal data from unauthorised access and misuse, such as internal data protection policies, internal training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, and regular checks on these.

9. Obligation to provide personal data

Within the scope of our business relationship, those personal data must be provided which are necessary for the establishment and implementation of a business relationship and the fulfilment of the associated contractual obligations (there is usually no legal obligation to provide us with data). Without this data, we will generally not be able to conclude or process certain contracts.

10. Automated decisions

For the establishment and implementation of the business relationship, and also otherwise, we generally do not use fully automated decision-making. Should we use such procedures in individual cases, we will inform you separately about this, insofar as this is required by law, and inform you about the associated rights.

11. Rights of the data subject

Within the framework of the data protection law applicable to you and insofar as provided therein, you have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing as well as to the surrender of certain personal data for the purpose of transfer to another body (so-called data portability). 

Please note, however, that we reserve the right to assert the restrictions provided for by law on our part, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to invoke this) or need you to assert claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of revoking your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or costs. We will inform you in advance if this is not already contractually agreed. The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card where your identity is otherwise not clear or cannot be verified). To exercise your rights, you can contact us at the address given in section 1. 

12. Changes

We may amend this Privacy Policy at any time without prior notice. The current version published on our website will apply. If the Privacy Policy is part of an agreement with you, we will notify you of the change by email or other appropriate means in the event of an update.

13. Version

This Data Protection Policy shall enter into force on 1 September 2023 and may be amended at any time by the management of Avanea Ltd.