We at Swisscare Europe Ltd. take the protection of your personal data seriously. This privacy policy (hereinafter: the “Privacy Policy”) will inform you about the processing of your personal data as well as your related rights. When processing your personal data, we comply with the applicable data protection law. Please contact us if you have any questions or concerns in this context. We are happy to help!
Table of Contents
- Data controller
- Data Subjects
- Personal data collected
- Processing of personal data
- Purpose of the data processing
- Recipients of personal data
- Transfers abroad
- Storage of personal data
- Confidentiality/security
- Your rights
- Duty to provide personal data
- Cookies and social media
- Google Maps
- Changes to the privacy policy
1. Data controller
The Privacy Policy informs you about the collection, processing, and use of your personal data, in the sense of data protection laws, for which Swisscare Europe Ltd., Landstrasse 20, 9496 Balzers (Liechtenstein) acts as data controller (hereinafter: “We”).
We process personal data as a data controller for example when you subscribe to one of our products, use our mobile application “MySwisscare” or visit our website (swisscare.com). In this regard, we process personal data for our website and application jointly with our affiliated company Swisscare Switzerland Ltd.
If you have any questions about your personal data processing regarding our products and our services please contact us using the details below:
Data Protection Officer
Swisscare Europe Ltd.
Landstrasse 20
9496 Balzers – Liechtenstein
If you have any question regarding specifically our website and application, please contact Swisscare Switzerland Ltd using the details below:
Data Protection Officer
Swisscare Europe Ltd.
Landstrasse 20
9496 Balzers – Liechtenstein
If you have subscribed to a product from Swisscare Switzerland Ltd, please consult the Swisscare Switzerland Ltd's privacy policy.
2. Data Subjects
We process personal data about the following categories of natural persons:
- Our clients, the insured persons, the policies’ holders;
- All other persons who have direct or indirect contact with us, such as visitors to our website, users of our app, interested parties, service providers, intermediaries, trustees, accountants, suppliers, representatives and employees of legal entities and job applicants, or their respective contacts.
If you disclose data to us about persons related to you as well as third parties, we will assume that you are authorised to do so and that this data is correct and that you have ensured that these persons have been informed about this privacy policy, insofar as a legal duty to inform applies (e.g. by bringing this privacy policy to the attention of these persons in advance).
3. Personal Data collected
Personal data includes any data that relates to an identified or identifiable natural person. Depending on your role and your relationship with us as a data subject, we particularly process the following categories of personal data:
- Contact data (e.g. surname, first name, address, e-mail, telephone number);
- Identification data (e.g. personal details, date of birth, place of birth, nationality, address, civil status, occupation, gender, social security number, number, ID and passport data);
- Communication data (data arising in the course of written, telephone or electronic communication with you);
- Documentation data (e.g. minutes of consultations and conversations);
- Contract data;
- Insurance data (e.g. information on existing and former insurances, policies, pension and daily allowance payments, information on claims or insurance cases);
- Health data (e.g. information on current and past physical or mental illnesses, injuries, disabilities, allergies, accidents, planned and past medical treatments);
- Physical data (e.g. height, weight, existing pregnancies);
- Financial data (e.g. bank account data, billing data, credit rating data);
- Data from public registers (e.g. debt enforcement register, cadasters, commercial register);
- Application details (e.g. details in the curriculum vitae, qualifications, proof of performance);
- Behavioural and preference data (e.g. visits to our website, interest in services);
- Technical data related to the website (e.g. cookies, IP address).
4. Processing of personal data
We process your personal data in the following cases, i.e.:
- When you use our website;
- When you use our app;
- When you engage or have a contractual relationship with us as a potential client, service provider, intermediary, trustee, accountant supplier, prospective client, website user or in any other role;
- When you apply for a job with us;
- When you have contact with us in the course of our other business;
- If we permissibly obtain it from publicly available sources when providing our services (e.g., debt enforcement registers, cadastres, commercial registers, media, internet);
- When one of the aforementioned persons gives us information about you for the performance of our services.
5. Purpose of the data Processing
Your personal data is processed for the following processing purposes:
a. For communication purposes
We process your personal data for the provision, administration and execution of written, telephone and electronic contact and communication with you (e.g., for processing enquiries, providing information).
This processing is necessary for the performance of a contract to which you are a party or for the performance of pre-contractual measures taken at your request.
b. To fulfil our contractual and pre-contractual obligations/provision of our services
We process your personal data in order to fulfil our contractual obligations towards our customers and other contractual partners (e.g., suppliers, service providers, insurance companies, intermediaries, brokers, accountants, trustees), i.e. in particular for services in the area of insurance brokerage and in the context of offering services for the conclusion of an insurance policy. In addition, data processing takes place for the implementation of pre-contractual measures and for the conclusion of contracts (e.g., clarifications prior to the order, processing of incoming applications).
This processing is necessary for the performance of a contract to which you are a party or for the performance of pre-contractual measures taken at your request.
c. To comply with legal and regulatory requirements
We process your personal data to comply with legal requirements and regulatory requirements, including disclosure, information or notification obligations, as well as to comply with the orders of a court or authority (e.g. notification obligations to regulatory authorities).
This processing is necessary to comply with our legal obligations.
d. In order to protect our legitimate interests
Where necessary, we process your data beyond the actual provision of our services to protect our legitimate interests or those of third parties. Examples of this are:
- Assertion of legal claims and defence in legal disputes;
- Ensuring IT security and IT operations;
- Developing and managing services;
- Quality assurance (e.g., internal training and education);
- Business and risk management measures;
- Advertising and marketing;
- Analysis of internet traffic on our website to improve the functionality of our website;
- Prevention and investigation of criminal offences or other misconduct.
e. Based on your consent
For certain purposes, we may ask for your consent. In such case, the legality of these processing operations is your consent. A given consent may be revoked at any time. The revocation of consent does not affect the legality of the data processing until the time of revocation.
6. Recipients of personal data
Personal data will only be disclosed to third parties if this is in accordance with the legal provisions or if a sufficient legal basis for this exists (e.g., contract fulfilling purposes, a legitimate interest, or your consent). Furthermore, data may be transferred to other third parties if we are bound to do so by legal provisions or by an enforceable official or judicial order
Service providers we use also may receive data, in compliance with the legal, if they maintain the appropriate level of confidentiality. We have carefully selected these service providers and oblige them to handle and secure the respective data with care.
Your personal data may be disclosed to the following categories of recipients:
- our affiliated companies;
- Insurance companies;
- Authorities, courts and other state institutions (e.g., regulatory authorities);
- Experts and surveyors;
- Loss adjusters;
- Affiliated companies;
- Providers to whom we have outsourced certain services (e.g., IT service providers, payment service providers, external accountants, collection service providers, marketing service providers);
- Other business partners and auxiliary persons (e.g., lawyers, tax experts, auditors).
7. Transfers abroad
If data is transferred to a country without an adequate level of protection, an appropriate level of protection is guaranteed by the conclusion of standard contractual clauses recognized and approved by the competent supervisory authorities for the protection of personal data. A copy of the standard contractual clauses would be available on request from one of the contact address mentioned in section 1.
Data may also be sent to other countries where appropriate. In such cases, the Company will comply with the applicable rules and adopt the necessary measures prior to the transmission of personal data abroad.
8. Storage 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 other purposes pursued with the processing, and as long as we have a legitimate interest in retaining the respective personal data.
Moreover, we store personal data that is subject to legal storage periods, or that is still required for criminal prosecution, or for securing, asserting, or enforcing legal claims.
The (temporary) further processing of personal data is necessary for the following purposes, among others the fulfilment of retention obligations under commercial and tax law (usually ten years) and the preservation of evidence within the framework of the legal prescription provisions.
9. Confidentiality/security
All personal data collected, processed, and stored by us will be treated confidentially. To adequately protect this data from unauthorised access and misuse, we have implemented technical and organisational measures (e.g., controlled access and access restrictions to data, IT security applications and measures, etc.). In addition, electronic data is retained with all due care and stored on servers in Switzerland.
We would like to point out that in the event of data being sent by e-mail, data is transmitted unencrypted. Therefore, it cannot be ruled out that data may be lost during transmission or may be viewed by third parties. Such online transmission of personal data is therefore at your own risk.
10. Your rights
You are entitled to assert the right to information, the right to rectification, the right to erasure and the right to restriction of data processing as well as the right of access and data portability. You can assert your rights with the data controller under point 1.
Furthermore, you can revoke any consent you have given us to process your personal data. Please note that the revocation is only effective for the future. Data processing that took place before the revocation is thereby not affected.
Any data subject shall have the right to file a complaint with the competent data protection authority, without prejudice to any other administrative or judicial remedy. The competent data protection authority is that of the EEA Member State in which you are located. In Switzerland the competent data protection authority is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
11. Duty to provide personal data
In the context of our business and customer relationship, you must provide the personal data that is required for the establishment, execution and fulfilment of the business and customer relationship, so that we can fulfil our contractual obligations and collect or process the data that we are legally obliged to. Without this data, we will generally not be able to enter a business and customer relationship with you or execute a relevant contract.
12. Cookies and social media
a. Cookies
We use so-called cookies on our website. This is a technology with which your browser or device can be identified. These are small text files that are filed and stored on the computer system via an internet browser. When a user visits a website, a cookie may be stored on the user's operating system. A cookie contains a characteristic string of characters that enables the browser to be clearly identified when the website is visited again.
We use cookies to facilitate access to our website, to understand how you navigate our site and to identify the website malfunctions. It also enables us to improve your experience and the design and content of the website. The legal basis for processing is the pursuit of our legitimate interest in improving your experience on our website and getting to know you better.
As a data subject, you can prevent the storage of cookies by our website at any time through via our cookie manager, which allows you to set your preferences with regard to the collection of advertising cookies or cookies essential to the operation of the website or through an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, you can delete cookies that have already been set at any time via an internet browser or other software programs.
If the user does not accept a cookie for application, the presentation of the usability of our website may be restricted for the respective user.
b. Social media
When you allow a third-party social network (such as Facebook, YouTube or LinkedIn etc.) to share with our accounts, we may receive any data you share publicly on that social network and data that forms part of your profile. This may include basic data relating to your account (e.g. first name, last name, e-mail address, gender, birthday, city of residence, profile photo, user ID, etc.) and any other data or activity that you authorize the third-party social network to share. These social networks are governed by their own terms of use and privacy policies, which we invite you to read.
13. Google Maps
In addition, in the context of using our app, we use the Google Maps service to display your location and map information for the purpose of using the "Doctors nearby" functionality. Google Maps is a mapping service provided by Google LLC, for the display of an interactive map and for the creation of directions. This is a service of Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.
If you call up the app, the integrated Google Maps component is also activated, and Google activates a cookie on your end device. To display your location and create directions, your user settings and data are processed. Through the connection to Google established this way, Google can determine to which IP address the directions are to be transmitted.
The Google privacy policy and additional terms of use for Google Maps can be found at:
https://policies.google.com/privacy?hl=en-GB
In addition, for our insurance offer for Spain ("International student health insurance Spain"), a check is made by means of the Google Maps Platform whether the address specified in the insurance application exists.
The use of the functions and content of Google Maps is subject to the current terms of use and privacy policy:
https://maps.google.com/help/terms_maps/
https://policies.google.com/privacy
14. Changes to the privacy policy
We reserve the right to change this privacy policy at any time. The current version that we publish on our website applies. The date of the last update can be found at the end of this privacy policy.
Status: August 2024