3. Disclosure of personal data
3.1 Disclosure to third parties
In order to provide its products and services, BCV may disclose personal data to:
- Third parties involved in the transaction or acting on the customer’s behalf, such as the operator of a financial market infrastructure (e.g., an exchange), a broker, a correspondent bank, a sub-custodian, or an issuer;
- External service providers, such as for IT services and hosting;
- Providers of audit, analysis, and advisory services, such as credit reporting agencies, marketing agencies, audit firms, and other external advisory services.
In accordance with Article 17 of its General Conditions, BCV contractually requires its service providers to protect and maintain the confidentiality of the personal data that they process.
3.2 Disclosure to authorities
Personal data may be disclosed to public, judicial, or administrative authorities or to regulatory or governmental bodies (such as supervisory authorities), upon their request. Personal data may also be disclosed to these entities so that BCV can determine facts, exercise its rights or defend itself from a current or future claim, or respond to an investigation carried out by a public authority in Switzerland or abroad.
3.3 Cross-border disclosure
Personal data may also be disclosed outside of Switzerland to the individuals mentioned in sections 3.1 above, as long as it complies with Swiss law. If personal data is disclosed to a State that cannot guarantee adequate protection as set out in the Act, BCV will put in place adequate technical, organizational, and legal measures to protect the personal data, including binding contractual commitments with the personal data recipient.
With regard to the disclosure of personal data to authorities outside Switzerland within the meaning of section 3.2 above, BCV complies with the applicable legal provisions on international judicial assistance and with FINMA’s provisions on the direct transmission of non-public information to foreign authorities and entities.