3. What data do we process? We process various categories of data about you. The main categories are as follows:
Master and portfolio data such as name, address, date of birth, contract number and duration, doc-uments to establish the customer's identity, in-formation on the account, custody account, con-cluded transactions or on third parties such as life partners, authorised representatives and advisors who are also affected by data processing. Residence for tax purposes and any other documents and information relevant for tax purposes. Transaction or order and risk management data such as beneficiary details, mandate details where applicable, details of your assets, investment products, risk and investment profile, fraud. Records of telephone calls between you and us, if applicable. Marketing data such as needs, wants, preferences. Technical data, such as internal and external identifiers, business numbers, IP addresses, records of access or changes.
4. For what purposes do we process your data? We process your data for the following purposes (in addition to those we notify you of separately):
Communication with you Contract conclusion/processing with you, your employer and customers Operation of infrastructure, website, app Marketing (e.g. mailings, with unsubscribe link/option, occasions), relationship management Market analyses, planning, development of products & services, R&D Compliance (adherence to laws, industry standards, directives, etc.) Legal procedures, investigations Safeguarding security, access control Management, Risk Management Corporate transactions (e.g. M&A) Media relations, PR, publications Shareholder Services, Investor Relations Training, instruction, further education Fighting crime and fraud
5. On what basis do we process your data? Depending on the products and services we may provide to you or the purpose for which the person-al data is processed, the data processing is based on the following:
Entering into, concluding or performing a contract or business relationship with you or for the performance of our obligations under such contract or business relationship. To safeguard our legitimate interests, e.g. statistics, planning or product development, business decisions; monitoring and controlling risks, business auditing; marketing, market research, comprehensive support, advice and information on the range of services, preparation and provision of tailor-made services - insofar as no objection has been made; safeguarding our interests and securing the claims of our company, customers and employees. To fulfill legal or regulatory obligations of our company or the performance of tasks in the public interest. Based on your consent.
6. Do we use online tracking techniques? We use various techniques on our website which enable us and third parties engaged by us to recognise you when you use our website and, in some circumstances, to track you across multiple visits. We inform you about this in this section.
In essence, this is so that we can distinguish accesses by you (via your system) from accesses by other users, so that we can ensure the functionality of the website and carry out evaluations and personalisations. In doing so, we do not want to infer your identity, even if we can do so insofar as we or third par-ties engaged by us can identify you through a combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of the third parties) assigning you or your browser a specific identification number (so-called "cookie").
Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can there-fore be "tracked" (traced). If we integrate offers from an advertising contractor or provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in individual cases.
We use such techniques on our website and allow certain third parties to do so as well. You can pro-gramme your browser to block or deceive certain cookies or alternative techniques, or to delete existing cookies. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword "data protection") or on the websites of the third parties that we list below.
A distinction is made between the following cookies (techniques with comparable functions such as fin-gerprinting are included here):
Necessary cookies: Some cookies are necessary for the website to function as such or for certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary ("session cookies"). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one session (i.e. one visit to the website) if you use this function (e.g. language selected, consent given, the function for automatic login etc.). These cookies have an expiry date of up to 24 months.
Performance cookies : In order to optimise our website and corresponding offers and to better adapt them to the needs of users, we use cookies to record and analyse the use of our website, possibly even beyond the session. We do this through the use of third-party analytics services. We have listed these below. Performance cookies also have an expiry date of up to 24 months. Details can be found on the websites of the third-party providers.
Google Analytics: Google Ireland (based in Ireland) is the provider of the "Google Analytics" service and acts as our processor. Google Ireland relies on Google LLC (based in the USA) as its processor (both "Google"). Google uses performance cookies (see above) to track the behavior of visitors to our website (duration, frequency of pages accessed, geographical origin of access, etc.) and compiles reports for us on the use of our website on this basis. We have configured the service so that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the USA and therefore cannot be traced back. We have switched off the "Data sharing" and "Signals" settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you agree to the use of Google Analytics, you explicitly consent to such processing, which also includes the transfer of personal data (in particular usage data for the website and app, device information and individual IDs) to the USA and other countries. You can find information on Google Analytics data protection here and if you have a Google account, you can find further information on processing by Google here .
7. Who do we disclose your data to? Lumen is generally bound by the confidentiality agreement with its clients. In principle, your personal data will only be disclosed to service providers and agents (if necessary, also during a negotiation/testing phase) of Lumen or you as well as other third parties, if this is necessary for the fulfillment of contractual (including execution of customer orders such as payment and securities orders) or legal or regulatory obligations or due to outsourcing by Lumen.
8. Does your personal data also end up abroad? Yes, this is possible, to the EEA, but exceptionally to any country in the world (conceivable especially for online services that we use). If this is a country without sufficient data protection, we conclude contracts (so-called EU SCC), but may also rely on consent or transfer data abroad on a case-by-case basis, because it is necessary for the processing of a contract, where it concerns data published by you or it is necessary for legal proceedings abroad.
9. How long do we process your data? The duration of the storage of personal data is determined by legal retention obligations or the pur-pose of the respective data processing. As a rule, we store personal data for the duration of the business relationship or the duration of the contract and then for a further five, ten or more years (depend-ing on the applicable legal basis).
10. How do we protect your data? We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect against the risks of loss, accidental alteration, unauthorised disclosure or access.
11. What rights do you have? You have the right to information, correction, deletion, restriction, objection and - if applicable - the right to data portability. Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority. If you wish to exercise the above rights against us), please contact us in writing, at our premises or, unless otherwise stated or agreed, by e-mail. You will find our contact details in para. 2. In order for us to be able to exclude misuse, we must identify you (e.g. with a copy of your ID card, unless otherwise possible).
12. Digital infrastructure We use the services of specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
webflow: Privacy Policy for users in the European Economic Area, the United Kingdom and Switzerland ("EU & Swiss Privacy Policy") , Privacy Policy for users in the rest of the world ("Global Privacy Policy") , Cookie Policy .
13. Maps We use third-party services to embed maps in our website.
We use in particular:
14. can this privacy policy be changed? This privacy policy does not form part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.
Last update: November 23, 2023
