Thank you for your interest in the Kamuno website. The protection of your privacy is very important to us. Below we inform you in detail about how we handle your data.

Kamuno AG (Kamuno) is a financial intermediary pursuant to Art. 2 para. 3 lit. a of the Anti-Money Laundering Act (AMLA) and is supervised by the self-regulatory organization VQF (Association for Quality Assurance of Financial Service Providers, General-Guisan-Strasse 6, 6300 Zug (www.vqf.ch).

In this privacy policy, we, Kamuno AG, inform you which data we collect about you, why we process it and to whom we pass it on so that we can guarantee transparent and legally compliant data processing. We will provide you with the information you need to assert your rights under the applicable Swiss Data Protection Act (DSG). If you have any further questions about the processing of your personal data, please do not hesitate to contact us.

Data protection officer

is the data controller within the meaning of the Data Protection Act:

Kamuno AG, Bahnhofplatz 1, 6460 Altdorf

E-mail: info@kamuno.ch

Phone: 041 874 36 36

General information

Personal data is information that relates to an identified or identifiable person. Kamuno defines processing as any handling of personal data, regardless of the means and procedures used, in particular the collection, storage, retention, use, modification, disclosure, archiving, erasure or destruction of personal data.

For certain data processing (e.g. credit checks, digital onboarding, qualified digital signature, e-mail), there are further provisions which are available in the General Terms and Conditions of Kamuno or on the corresponding websites or apps of the third-party providers.

Processing framework

3.1 Categories of personal data processed

Kamuno processes as little personal data as necessary. In connection with the products and services offered, Kamuno also collects, if necessary, data about third parties affected by the business relationship (e.g. controllers, beneficial owners, authorized signatories, shareholders, business partners, guarantors).

If you provide Kamuno with data about another person, you undertake to provide that person with this declaration before you provide Kamuno with any information about that person. You also represent and warrant that you have complied with all requirements under applicable data protection laws to enable the processing of personal data by Kamuno and that you have obtained the data subject’s prior consent to its processing, where applicable.

Depending on the case, Kamuno may process the following data of visitors, interested parties, customers and suppliers:

• Master and inventory data, including but not limited to name, address, date of birth, nationality, contract number and duration, gender, copy of passport or ID, telephone number, e-mail address, documents to establish customer identity, information on the account, on concluded transactions or on third parties who are also affected by data processing;
• Tax residence and any other tax-relevant documents and information (e.g. tax identification number);
• Transaction or order and risk management data such as, in particular, but not limited to, details of beneficiaries for transfers, beneficiary bank, details of assets, cases of fraud, details of current and previous transactions, number and value of shares held, share register;
• Data on financial and economic situation, bank details, extract from the register of the debt enforcement and bankruptcy office, financial and credit history, extract from the commercial register, extract from the Central Office for Credit Information (ZEK);
• Marketing data such as needs, wishes and preferences;
• technical data such as internal and external identifiers, business numbers, IP addresses, transaction numbers, records of access or changes.

For reasons of evidence and quality, Kamuno may record telephone conversations. These recordings are subsequently deleted at regular intervals.

3.2 Access data

Kamuno collects data about every access to the website (so-called server log files).

The access data includes:

• Name of the website accessed, file(s)
• Date and time of retrieval
• Amount of data transferred
• Notification of successful retrieval
• Browser type and version of the user’s operating system
• Referrer URL (the previously visited page) and exit pages
• IP address and the requesting provider
• Location data (especially when using mobile devices)
• Information on interaction between pages (e.g. scrolling, clicking, mouseovers)

Kamuno uses the log data only for statistical evaluations for the purpose of the operation, security and stability of the system as well as the optimization of the offer. Kamuno reserves the right to check the log data retrospectively if there is a justified suspicion of unlawful use based on concrete evidence.

3.3 Origin

The personal data may originate from the following sources:

• Personal data provided to Kamuno, e.g. in the context of establishing a business relationship and when using the website;
• Personal data that is generated as a result of the use of services and is transmitted to Kamuno through the technical infrastructure or through work-sharing processes, e.g. websites, apps, payment transactions, cooperation with other financial or IT service providers, partners and intermediaries, marketplaces and online platforms;
• Personal data from third-party sources, publicly accessible sources, databases provided by official authorities, e.g. debt collection registers, commercial registers, data providers for credit information, authorities or sanction lists of the UN, SECO and the EU, Internet, social services, correspondent banks, recruitment agencies, criminal/civil authorities, enforcement authorities.

Purposes of data processing

Kamuno may process the personal data described in Section 3 for the purpose of providing its own services and for its own purposes or those provided for by law or for the legitimate interests it pursues.

Kamuno understands this to mean the following in particular:

• Customer acceptance procedures, implementation, processing and management of business relationships and products and services (e.g. identity confirmation, application evaluation, credit decisions, financing, payments, communication);
• The management of pre-contractual relations and subsequently the opening and management of a business relationship with Kamuno, including all formalities relating to customer identification and, where applicable, the identification of all third parties involved;
• Conducting statistics or tests, planning or product development, business decisions (e.g. determining key figures on the use of services, utilization figures, transaction analyses, developing ideas for new or assessing or improving and reviewing existing products, services, processes, technologies, systems and returns);
• Monitoring and management of risks, business review, business opening, timely business processing (e.g. fraud prevention, limits, market, credit or operational risks and system and product training) as well as all measures introduced in the area of risk management and risk assessment;
• Marketing, market research, comprehensive support, advice and information on the range of services, preparation and provision of customized services (e.g. direct marketing, advertising in print and online, customer, prospective customer or cultural events, sponsoring, competitions, determination of customer satisfaction, future customer needs or behaviour or assessment of customer, market or product potential);
• Legal or regulatory obligations to provide information, disclosure or reporting to courts, authorities, compliance with official orders (e.g. automatic exchange of information with foreign tax authorities, orders from FINMA, public prosecutors’ offices, in connection with money laundering and terrorist financing or for recording and monitoring communications);
• Review of compliance with legal obligations in relation to financial market regulations, including sanctions and embargoes;
• Any form of cooperation with the competent authorities, such as the supervisory authorities, the authorities involved in the automatic exchange of information in tax matters and the authorities responsible for combating money laundering and terrorist financing;
• Safeguarding the interests and securing the claims of Kamuno in the event of claims against Kamuno or customers of Kamuno and safeguarding the safety of customers and employees;
• the recording of telephone and electronic contacts with customers or third parties for the purposes of documentation, quality assurance, employee training, preservation of evidence and the prevention, detection and investigation of fraud;
• Any processing required to provide Kamuno with proof of transaction;
• Collection or assignment of receivables;
• Any processing necessary to enable Kamuno to establish, exercise or defend itself against an actual, potential or future claim or to enable Kamuno to comply with an investigation by an authority in Switzerland or abroad;
• any processing necessary to enable Kamuno to obtain the necessary information about you (in particular to check your creditworthiness) from third parties such as law enforcement agencies and credit information providers and to report or notify accordingly;
• Any processing that serves to maintain the business relationship with customers;
• Any processing with a view to improving Kamuno’s internal business organization and operational activities;
• The management of Kamuno’s IT environment and its configuration;
• Processing to ensure IT security;
• The use of data to develop business offers and marketing measures;
• Any other purposes of which you will be informed by Kamuno.

Outsourcing and transfer of data

5.1 Transfer of data

Kamuno may outsource certain services or disclose customer data to third parties for the fulfillment of the purpose, in particular in the areas of IT, hosting and support, digital onboarding, qualified digital signature, credit checks, scoring, marketing, sales. These third parties may in turn use subcontractors, provided Kamuno has given its consent. These third parties are also contractually obliged to protect the confidentiality and security of the data. If personal data is processed by external processors, we ensure that the legal requirements are complied with. In addition, Kamuno will take the appropriate measures necessary to secure the transfer of data to third parties. Data will only be passed on to third parties if:

• this is necessary for the performance of the contract with you;
• the disclosure is permissible on the basis of a balancing of interests;
• we are legally obliged to disclose (e.g. courts, supervisory authorities, law enforcement authorities, tax authorities, child and adult protection authorities, etc.); or
• you have given your consent in this respect.

Kamuno also reserves the right to disclose or make the data available to its auditors and/or legal advisors and/or IT service providers, e.g. in the context of maintenance, support or services. Processors are third parties who process personal data on behalf of and for the purposes of Kamuno, e.g. IT, marketing, sales or communication service providers, debt collection agencies, fraud prevention agencies, credit agencies or consulting companies. If personal data is disclosed to such a processor, the processor may only process the personal data received in the same way as Kamuno itself. Kamuno selects its processors carefully and contractually obliges them to guarantee the confidentiality and security of the personal data.

5.2 Transfer abroad

Kamuno may be required to disclose, communicate, transfer and/or store data abroad:

• if the disclosure is necessary to protect an overriding public interest;
• in the context of the conclusion or performance of a contract directly or indirectly related to the business relationship (i.e. a contract concluded with you and/or a third party concerned, but in your interest and/or that of the third party concerned);
• if it concerns the outsourcing of activities and/or services that form the basis of Kamuno’s business;
• if the disclosure is necessary for Kamuno to establish, assert or defend a present or future claim;
• to enable Kamuno to comply with an investigation by an authority in Switzerland or abroad; or
• in exceptional cases duly provided for by applicable laws.

Depending on the type of product or service used, personal data may also have to be disclosed to third parties (including processors) based in countries that do not have an adequate level of data protection. To this end, certain data may be made accessible to IT service providers in these countries, particularly in the case of maintenance/support/services/social media/email marketing. The United States of America, for example, does not have an adequate level of data protection. In the event of a transfer to such a country, Kamuno checks that the recipient takes appropriate measures to protect personal data (e.g. by agreeing so-called EU standard clauses, other precautions or based on justification grounds).

The following data disclosures outside the EU are possible:

• Google (Google LLC based in the USA);
• Microsoft Teams (Microsoft Corporation, based in the USA);
• Mailchimp (newsletter and email marketing, based in the USA)

For social media plug-ins, please refer to section 8.

Use of cookies

In order to make visiting the Kamuno website attractive and to enable the use of certain functions, we use so-called cookies on various pages, including those created by third-party providers. These are small text files that are stored on your end device and that store certain settings and data for exchange with our system via your browser. Some of the cookies we use are deleted again at the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your end device and enable us to recognize your browser on your next visit (persistent cookies). Cookies do not contain any personal data and therefore cannot be directly assigned to a user. Please note that certain cookies are already set as soon as you enter the website. You can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If you do not accept cookies, the functionality of the website may be restricted.

Below you will find information about the cookies we use.

• Analytical / performance cookies: These cookies make it possible to collect anonymized data about the usage behavior of our visitors. This data is analyzed by us, for example to improve the functionality of the website and to show you interesting offers.
• Functional cookies: These cookies are used for certain functionalities of our website, e.g. to suggest a better navigation flow on our website.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to tailor our website and the advertising you see to your interests.
• Third-party cookies: These cookies from some of our advertising partners help to make the Internet offer and our website more interesting for you. For this reason, cookies from partner companies are also stored on your storage medium when you visit our website. These are temporary cookies that are automatically deleted after the specified time. Cookies from partner companies are usually deleted after a few days or up to 26 months, in some cases even after several years.

How can I configure my browser’s cookie settings?

Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:

Chrome™: Delete, allow and manage cookies in Chrome - Computer - Google Chrome Help

Firefox™: Improved activity tracking protection in Firefox for Desktop | Firefox Help (mozilla.org)

Internet Explorer™: Managing cookies in Microsoft Edge: view, allow, block, delete and use - Microsoft Support

Safari™: Deleting cookies in Safari on the Mac - Apple Support (EN)

Use of Google for web analysis

This website uses a Google Tag Manager. The Tag Manager in turn collects some personal data. It enables the use of code fragments (so-called tags) or tools to record the user’s interactions.

The website also uses Google Analytics, a web analysis service of Google Inc (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.

The following data is collected:

• Your IP address
• Browser used (version and operating system)
• Server
• Source or reference, i.e. website from which you access a Kamuno website
• Time at the time of access
• Pages and files accessed
• Time spent on the pages accessed
• Behavior on the pages (clicks, scrolling behavior)
• Achievement of website goals (e.g. newsletter registrations)
• Your approximate location (country and city)
• Gender
• Age

The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by the provider of the web analysis service (e.g. Google in the USA). We would like to point out that the same level of protection under data protection law cannot be guaranteed in the USA as in Switzerland. However, if IP anonymization is activated on this website, your IP address will be shortened by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 14 months. Other data remains stored in aggregated form indefinitely.

This website also actively uses Google signals. This is a function of Google Analytics that links the visit data collected on the website with Google information from accounts of logged-in users of the Google account who have consented to this linking for the purpose of ad personalization. This Google information may include the user’s location, search history and data from websites that work with Google and is used to provide aggregated and anonymized insights into user behavior across devices.

You can prevent the installation of cookies or the collection of data by setting your browser software accordingly, although in this case you may not be able to use all the functions of this website to their full extent. As a user of our website, you also have the option of giving your consent to the use of cookies in the consent banner. This allows you to consent to or reject the processing of personal data.

By using this website, you consent to the processing of the data collected about you by the providers of the web analysis services in the manner described above and for the aforementioned purpose.

7.1 Use of Google Ads Conversion Tracking

The website is connected to the online advertising program “Google Ads” of Google Inc (www.google.com). Google uses cookies to enable companies that pay Google to place ads (advertisers) to determine how many people who click on your ads subsequently buy your products (conversion tracking). The conversion tracking cookie is only stored on your end device if you click on an ad placed by Google where the advertiser has opted for conversion tracking. These cookies expire after 90 days and do not contain any information that can be used to identify you personally. If you visit certain pages of an advertiser’s website and the cookie has not yet expired, Google and the advertiser can recognize that you clicked on the ad and were redirected to this page. Each advertiser receives a different cookie. Cookies can therefore not be tracked via the websites of advertisers. If you wish to deactivate cookies for conversion tracking, you can set your browser to block cookies from the domain “googleadservices.com”.

7.2 Use of Google Ad Manager

The website uses Google Ad Manager from Google LLC. (“Google”) is used on the website to deliver and optimize advertisements. Google Ad Manager uses cookies to present advertisements on the website. The information stored in the cookie can be recorded, collected and analyzed by Google or third parties. In addition, the Ad Manager also uses so-called “web beacons” (small invisible graphics) to collect information, whereby information about visitors to this page is collected (e.g. browser, operating system, previously visited page, IP address, date/time). Through their use, simple actions such as visitor traffic on the website can be recorded, collected and analyzed. The information generated by the cookie and/or web beacon about your use of this website is transmitted to a Google server in the USA and stored there. Google observes the data protection provisions of the “US Privacy Shield” and is registered with the “US Privacy Shield” program of the US Department of Commerce. Google uses the information obtained in this way to evaluate your usage behavior with regard to the ads managed by Ad Manager. Google may also transfer this information to third parties where required or permitted to do so by law, or where such third parties process the information on Google’s behalf. You can prevent the storage of cookies on your hard disk and the display of web beacons. To do this, you must select “do not accept cookies” in your browser settings. You can find more information here: Advertising - Privacy Policy & Terms of Use - Google Personalized advertising by Google can be found here: Manage access to your Google Ads account - Disable Google Ads Help. You can find more information on how to block certain advertising by Google here: Manage displayed ads directly from Ads - My Ads Center Help (google.com)

Use of Mailchimp for e-mail communication

We use Mailchimp, a service provided by Intuit Inc., to send emails, in particular newsletters. Mailchimp enables us to organize and analyze email campaigns. Personal data, such as your email address and any other voluntarily provided information (e.g. name, interests), is stored and processed on Mailchimp’s servers in the USA.

The following data may be collected and processed when using Mailchimp:

• Your e-mail address
• Name (if specified)
• IP address of the calling device
• Time of registration for the newsletter
• Opening and click rates as well as your behavior in the email (e.g. clicked links, dwell time)

The processing is carried out for the purpose of delivering our newsletter and analyzing and optimizing our email campaigns. These analyses help us to better tailor the content of our emails to the interests of our recipients.

Data is transferred to the USA on the basis of the Standard Contractual Clauses (SCC) concluded by Mailchimp to ensure an adequate level of data protection. Nevertheless, we would like to point out that the same level of data protection cannot be guaranteed in the USA as in Switzerland or the EU.

If you do not wish to be analyzed by Mailchimp, you can unsubscribe from the newsletter. You will find a corresponding unsubscribe link in every email. Alternatively, you can contact us directly to have your e-mail address removed from the mailing list.

Further information on data processing by Mailchimp can be found in Déclaration de confidentialité.

Social media plug-ins

Kamuno uses the social plug-ins listed below on its website to share knowledge and to make the company better known. Responsibility for data protection-compliant operation must be guaranteed by the respective external provider. Data processing in connection with these plug-ins is carried out with the user’s consent when using the plug-ins.

If the user uses the services of these social networks independently of or in connection with this website, they will evaluate the use of the plug-in. In this case, information about the plug-in is forwarded to the social networks:

• LinkedIn: Plug-ins from the social network LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA, are installed on this website. The LinkedIn plug-in can be recognized by the LinkedIn logo.
  Further information can be found here: www.linkedin.com/legal/privacy-policy
• YouTube: The website uses YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, for the integration of videos. We have no knowledge of and no influence on the possible collection and use of your data by YouTube.
  Further information can be found here: https://policies.google.com/privacy?hl=en-GB
• Instagram: This website uses the plug-in of the social network Instagram, which is offered by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA.
  Further information can be found here: https://about.instagram.com/blog/announcements/instagram-community-data-policy/
• Facebook: This website uses plug-ins from the social network Facebook, which is offered by Facebook Inc. 1601 S. California Ave, Palo Alto, CA 94304, USA.
  Further information can be found here: https://developers.facebook.com/docs/plugins?locale=en_US
• TikTok: This website uses plug-ins from the social network TikTok, which is offered by TikTok Inc, 10100 Venice Blvd, Culver City, CA 90232, USA.
  Further information can be found here: https://www.tiktok.com/legal/page/eea/privacy-policy

Rights

Subject to legal restrictions, you have the right to information, rectification, erasure, restriction, correction of your data, objection and – where applicable – the right to data portability. You also have the right to lodge a complaint with a competent data protection supervisory authority.

Kamuno accepts requests for information in writing, together with a legible copy of a valid official identification document (e.g. passport, identity card, driver’s license).

The rights to erasure and objection are not unrestricted rights. Depending on the individual case, overriding interests may make further processing necessary. Kamuno examines each individual case and informs you of the result. If personal data is processed for direct marketing, your right to object also extends to direct marketing, including profiling for marketing purposes. You can object to direct marketing at any time by notifying Kamuno accordingly.

You can revoke any consent given to Kamuno for the processing of personal data at any time. Please note that the revocation is only effective for the future. Processing that took place before the revocation is not affected. Even if you object to data processing, Kamuno is entitled to continue processing if this is required by law, necessary for the performance of a contract with you as a contracting party, necessary for the performance of tasks in the public interest or necessary for the protection of Kamuno’s legitimate interests, including the establishment, exercise or defense of legal claims.

Changes to personal data

You undertake to inform Kamuno immediately of any changes to the data collected using the usual means of communication. You also undertake to provide Kamuno, upon simple request, with any additional information that Kamuno deems appropriate for the continuation of the business relationship and/or for compliance with contractual, legal or regulatory provisions.

Automated individual decisions, profiling

Kamuno reserves the right to analyze and evaluate customer data (including data of affected third parties), including by automated means, in order to identify significant personal characteristics of the customer or to predict developments and create customer profiles. These are used in particular for business checks and for individual advice and the provision of offers and information that Kamuno may make available to the customer. Automated decisions are made on the basis of customer profiles, e.g. automated credit rating decisions. Kamuno ensures that a suitable contact person is available if the customer wishes to comment on an automated individual decision and that such an opportunity to comment is provided for by law. Certain data is processed automatically to assess personal aspects (profiling), e.g. due to legal and regulatory requirements (combating money laundering or terrorist financing), for risk management, for marketing and communication purposes (in particular to offer customers specific products or services according to their needs) or to assess and monitor the customer’s creditworthiness (scoring).

Data security

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorized or unlawful processing and to counteract the risks of loss, unintentional alteration, unwanted disclosure or unauthorized access.

Kamuno attaches great importance to data security. In addition to complying with legal requirements, Kamuno implements a variety of technical and organizational security measures to protect your privacy (e.g. use of firewalls, personal passwords and encryption and authentication technologies, access restrictions, employee awareness and training).

Data retention

Kamuno stores your personal data for as long as is necessary for the fulfillment of contractual, legal or regulatory obligations. Data processing will continue beyond this period if required by legal or regulatory retention periods (e.g. in accordance with the Swiss Code of Obligations, the Money Laundering Act, various tax laws, in connection with dormant assets) or if Kamuno needs the data for the assertion, exercise or defense of its own legal claims. If the purpose of storage no longer applies, the personal data will be deleted insofar as this is technically possible.

Changes

We reserve the right and may also be obliged to amend the provisions of this privacy policy. We will publish such changes in an appropriate manner (e.g. on the website). It is your responsibility to inform yourself regularly about the currently applicable provisions of this privacy policy.

Your data is safe with us.