Privacy Statement of SIX

This Privacy Statement explains how SIX Group Services Ltd. (“SIX”) collects, uses and discloses (hereinafter referred to together as “processes”) personal user data (hereinafter “Personal Data”) of visitors to this website (hereinafter “User”), and the means by which this is done. The Privacy Statement also describes how SIX safeguards the confidentiality of the Personal Data processed.
 

The User agrees to SIX¹ processing Personal Data in accordance with the Privacy Statement. Legal or contractual duties to maintain confidentiality to which SIX is subject in relation to the User's Personal Data are not affected by this Privacy Statement.

SIX may amend the Privacy Statement unilaterally at any time. The most recent version is published online by SIX.

1. Data Protection @ SIX

The activity of SIX Group as an infrastructure provider for securities, payments and financial information requires us to obtain and process a large amount of data. Thus, data protection is a central issue for us. The basic principle is that wherever data is processed, a high level of data protection and security must be guaranteed. This applies to data from customers and business partners as well as to employee data. Because privacy is above all protection of the person. That’s why we attribute such a high priority to compliance with the applicable laws and to protecting privacy and the private sphere of affected persons in order to adhere to national and international legal requirements.

2. Type of collected Personal Data

SIX processes Personal Data about the User if the latter

• visits websites of SIX,
• applies for or uses products or services offered by SIX online; this includes, in particular, registration for specific services or web content only accessible by means of a personal login and subscriptions to print media or online newsletters,
• obtains, installs and/or uses apps of SIX from the relevant app stores, or
• takes part in a competition.

In selected cases, Personal Data is processed if SIX records telephone calls with Users, whether this be to meet its own legal obligations or for training or quality assurance purposes.

SIX processes the personal data (such as name, gender, address, e-mail address, telephone and fax number) that the user expressly and actively makes available to SIX. This also applies if the user takes part in events of SIX (online or in person). The web server of SIX – and in the case of www.six-structured-products.com the web server of Ariva.de AG – automatically records details of the user's visit (such as IP address, browser type and version, operating system used, originating website, pages accessed, date, length of visit).

3. Usage of Personal Data and legal basis

By processing Personal Data according to this Privacy Statement, SIX is able to improve the quality of its products and services.

Personal Data is processed for the following purposes in particular:

• technical management as well as research and further development of websites,
• user administration and marketing,
• user information on the services and products rendered by SIX, provided the User has given their consent for this,
• selecting competition winners and awarding prizes,

SIX processes your Personal Data according to the applicable law. Depending from the processing purpose, the legal basis for the processing of the User’s Personal Data will be one of the following:

(a)   necessary for the legitimate interests of SIX, without unduly affecting your interests or fundamental rights and freedoms,

(b)   necessary for taking steps to enter into or executing a contract with the User for the services or products requested or for carrying out our obligations under such a contract,

(c)   User’s consent.

Examples of the ‘legitimate interests of SIX’ referred to above are:

• pursuing certain of the above mentioned purposes
• exercising SIX’ rights, including the freedom to conduct a business and right to property,
• providing products and services and assuring a consistently high service standard across the whole SIX Group, and keeping our customers, employees and other stakeholders satisfied, and
• meeting our accountability and regulatory requirements,

in each case provided such interests are not overridden by the User’s privacy interests.

4. Data transfers

The User authorizes SIX to transmit Personal Data to employees, agents or other third parties within or outside the country where the User lives in order to provide services and for the purposes indicated above. Employees, agents and other third parties which have access to Personal Data are required by SIX to ensure compliance with all applicable data protection provisions. Any person who authorizes SIX to access their Personal Data as defined in this Privacy Statement will be made aware of the data security and data protection implications. When Personal Data of the User are transferred to other countries, SIX will ensure data protection by granting the protection level required by the applicable law, e.g. by adopting EU Standard Contractual Clauses (SCC) or similar safeguards.

SIX reserves the right to disclose Personal Data to regulatory and supervisory authorities, as well as, pursuant to this Privacy Statement, to Analysis Service Providers. In so doing, SIX will comply at all times with applicable regulations, laws, court orders or official requests.

5. Data protection measures

SIX protects Personal Data with appropriate physical, electronic and process-related security measures, such as firewalls, personal passwords, encoding and authentication technologies. Personal Data collected via a website owned by SIX will be encrypted during transmission using SSL Secure Sockets Layer (SSL) technology, which currently provides the best-available security for data transfers.

6. Data Subject’s Rights

Users whose Personal Data is processed within the scope of this Privacy Statement have the following rights:

to receive information on whether SIX may save Personal Data and what form this Personal Data may take (which categories of data, recipients or categories of recipients, retention periods for Personal Data or criteria governing retention periods)

• to receive a copy of the Personal Data
• to request the rectification of Personal Data if it is incorrect
• to request the deletion of Personal Data
• to request restrictions on processing Personal Data
• to receive Personal Data in a structured, accessible and machine-readable format (if available)
• to submit an objection to processing, especially for the purpose of direct advertising

The rights specified above may be denied or restricted if the interests, rights and freedoms of third parties take precedence or if processing is necessary to establish, exercise or defend legal claims of SIX.

Queries in relation to processing Personal Data are to be directed to the Data Protection Officers of SIX:

To exercise your rights with regards to data protection please use this link.

You can also direct your queries to:

SIX Group Services Ltd.
Data Protection Officer
Hardturmstrasse 201
8005 Zurich
Switzerland
E-Mail: dataprotection@six-group.com

Users have also the right to make a complaint to the data protection authority responsible for them or in the place where they think an issue in relation to the Data has arisen

7. Storage

SIX will only retain your Personal Data for as long as necessary to fulfil the purpose for which they were collected or to comply with legal or regulatory requirements.

8. Links

The websites of SIX may contain hyperlinks to other websites which are not operated or monitored by SIX. Third-party websites are not subject to this Privacy Statement. SIX is not responsible for their content or how they handle Personal Data. 

9. Social Media Buttons

Functions (plugins) of third-party providers or social media platforms (Facebook, Twitter, Google+, etc.) are embedded into the websites of SIX. These plugins enable the User to share content on the social networks mentioned. The interfaces are deactivated by default when the website is accessed. This means that no Personal Data is transmitted to the respective third-party providers without intervention on the part of the User. Once the User has activated the interfaces, data (incl. also Personal Data) is automatically transmitted to the relevant third-party providers by the plug-ins. If the User is simultaneously logged in to the network of the respective third-party provider when they visit the website, the third-party provider can assign the visit to the User's network account. SIX has no influence on this. The purpose and scope of such a form of data collection and the further processing and usage of Personal Data are outlined in the data protection guidelines of the individual social networks. Users can also obtain information there on rights and settings options in relation to protecting their privacy.

10. Data Controller and representative in the EU/UK

SIX Group Services Ltd.
Pfingstweidstrasse 110
8005 Zurich
Switzerland

E-Mail: communication@six-group.com

EU representative: SIX Financial Information Deutschland GmbH in Frankfurt (Theodor-Heuss-Allee 108, D-60486 Frankfurt am Main).

UK representative: SIX Financial Information UK Ltd. in London (6 Devonshire Square, Spitalfields, London EC2M 4YE).

11. Right to withdraw consent in respect of data protection

Anyone affected by the processing of Personal Data can withdraw their consent to this effect at any time. This must be done in writing or by e-mail to the Data Protection Officer of SIX.

12. Cookies

The websites of SIX use cookies, which are saved on the User's computer. These enable SIX to retrace the User's visit and to save their preferences if they switch pages or revisit the website at a later date.

Cookies particularly serve the following purposes:

• save the User's preferred language and country settings
• perform a statistical analysis of the number of users and of their usage habits
• improve the loading speed of the individual pages

The User can control cookie specifications via their browser settings. The relevant browser options and instructions on use can generally be found in the browser manual or help file. If the User rejects, blocks or deactivates cookies, this may restrict the availability of the services offered via the website. In addition, parts of the website may not work correctly under certain circumstances.

13. Web analysis

SIX analyses how its websites are used with the help of third-party analysis tools, such as Google Analytics (hereinafter «Analysis Service Providers»). SIX assumes no responsibility or liability for any data processed by Analysis Service Providers.

Google Analytics
Google Analytics, a web-based analysis service by Google Inc. (hereinafter “Google”), uses cookies, which are saved on the User's computer. The information generated by the cookie concerning their visit is usually sent to and stored on a Google server in the USA. If SIX activates IP anonymization for this website, Google shortens the User's IP address within Member States of the European Union or in other partner states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and anonymized there. Google evaluates the information that has been saved on behalf of Google for the purpose of compiling reports on the website's usage and in order to provide other associated services for SIX. Google may combine the IP address transmitted from the User's browser by Google Analytics with other data that has been collected.

etracker (only for SIX Structured Products)
The www.six-structured-products.com website uses technologies of etracker GmbH (www.etracker.com) to collect and store data for marketing and optimization purposes. User profiles may be created from this data under a pseudonym. The data collected with etracker technologies is not used without the data subject's specific consent to identify the visitor of this website personally and is not combined with personal data about the bearer of the pseudonym.

Detailed information on this can be found at https://tools.google.com/dlpage/gaoptout?hl=en and https://www.google.com/intl/en/analytics/privacyoverview.html (general information on Google Analytics and data protection) and at https://www.etracker.com/en/data-privacy/ (general information on data protection of etracker).

Captchas
In specific cases SIX uses the Google reCAPTCHA v2 to avoid the usage of text fields by automated programs/bots. It helps to support the security of our website and to avoid spam for Users. This is our legitimate interest and fulfills our legal obligation.
The collected data is hardware and software information, such as device and application data and the result of integrity checks. This data will be sent to Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data will not be used by Google for personalized ads.
Further information can be found in their privacy policy: https://policies.google.com/privacy. Further documentation can be found here: https://developers.google.com/recaptcha/, https://www.google.com/recaptcha/admin/create

Tracking pixels
SIX may use customized electronic marketing technology based on “tracking pixels” provided by Facebook, Twitter, LinkedIn, and Google. A tracking pixel collects information from the header of a webpage, such as a visitor’s IP address or browser, which is forwarded to an advertiser (Facebook, Google, etc.) for the purpose of providing advertising to its customers that is based on their personal interests. SIX may use tracking pixels to investigate the effectiveness of advertising for statistical and market research purposes. The data that is collected cannot be used to identify the User as it is anonymous. However, above advertisers do store and process this data. More information on how they process data can be found in the privacy policies of Facebook, Twitter, LinkedIn, and Google.

¹ For the purpose of this Privacy Statement, “SIX” refers to SIX Group Ltd and all of its subsidiaries and branches.