Privacy Policy

A. GENERAL INFORMATION

This section tells you who is responsible for processing your data, who you can contact if you have any questions or complaints about data protection, how we protect your data and how you can protect your data in general.

This Privacy Policy is designed to meet the requirements of the Swiss Data Protection Act (“DPA”). However, whether and to what extent these laws are applicable depends on the individual case.

I. Controller

The controller responsible for the collection and use of your personal data on our online platform and when using our services within the meaning of data protection laws is:

Clark Switzerland AG
Frikartstrasse 5
4800 Zofingen

The content and works contained on this site and created by the website operator are subject to Swiss copyright law. The reproduction, processing, distribution, and use of any kind not covered by copyright law require the written consent of Clark Switzerland AG. Downloads and copies of this website are permitted for private, non-commercial use only. Insofar as any content on this site was not created by the operator, all third-party copyrights are observed. Third-party content is specifically marked as such. Nevertheless, should you become aware of any copyright infringement, please notify us accordingly. We will remove such content immediately, as soon as we become aware of any such infringement.

info@ch.clark.io

If you have any questions about the collection and use of data, you can contact us at any time.

II. Data security & data protection-friendly default settings

1. Data Security

Clark takes 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 modification, unwanted disclosure or unauthorized access.

2. Privacy-friendly Default Settings

To remove or clean up existing cookies or similar technologies from other sites, you can set privacy-friendly default settings in your browser or use certain opt-out options. Here are some steps you can take:

  1. Delete cookies:
    Most browsers offer the option of deleting stored cookies. To do this, go to your browser settings and look for the section on privacy or data protection settings. There you will usually find an option to manage and delete cookies.
  2. Use incognito/private mode:
    Many browsers have an incognito or private mode that restricts the storage of cookies and other data while browsing. You can activate this mode to prevent new cookies from being saved.
  3. Use browser extensions: 
    There are various browser extensions and add-ons that help block or control the tracking of cookies and similar technologies. Search for such extensions that are compatible with your browser and install them according to the instructions of the respective provider.
  4. Use opt-out options:
    Some companies and advertising networks offer opt-out options with which you can object to certain tracking cookies. Visit the websites of these companies and advertising networks to find out more about their privacy policies and opt-out options.

Please note that deleting cookies or adjusting browser settings may affect the functionality of certain websites or services. It is advisable to check the impact of these changes beforehand.

B. YOUR PRIVACY RIGHTS

You can find out what privacy rights you have in relation to your data in this section on your privacy rights. These rights include the right to information about the data stored about you, a right to rectification and – if the legal requirements are met – a right to erasure of your data. Whenever we ask you for your consent to process your data, you also have the right to withdraw your consent at any time and without giving reasons.

I. Information

You have the right to request information about the processing of your personal data by us at any time. When providing you with information, we will explain the data processing and provide you with an overview of the data stored about you.

If you request information about your data, we will provide you with comprehensive information about how your data is processed, where it comes from and where it goes.

 II. Correction

If the data we have stored is incorrect or no longer up to date, you have the right to have this data corrected.

We will comply with your request without delay.

You can send us the correct data for the correction and we will take care of the rest.

III. Deletion

You can also request the deletion of your data.

If deletion is exceptionally not possible due to other legal provisions, the data will be blocked so that it is only available for this legal purpose.

IV. Restriction

You can also have the processing of your data restricted.

While we check your aforementioned rights, you can have the processing restricted.

V. Transfer

Furthermore, you have the right to request that we transfer the data concerning you in the form of a digital copy if you have consented to the data processing or if it is based on a contract existing between us.

If you request the transfer of the data that you have provided to us, we will make it available to you in a portable format.

VI. Objection

You have the right to object to the processing of your data. If you file an objection, we will check whether we have compelling reasons for processing. If this is not the case, we will no longer process the data. In the case of direct marketing, you have a general right to object.

VII. Revocation

You have the right to revoke any consent you have given us at any time by sending a message to info@ch.clark.io. As a result, we will no longer continue the data processing that was based on this consent in the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

If you withdraw your consent, we will stop the data processing based on it.

VIII. Complaint

Finally, you have the right to lodge a complaint with the data protection supervisory authority responsible for us. You can assert this right with a supervisory authority in the Member State of your place of residence, your place of work or the place of the alleged infringement.

You can contact the Federal Data Protection and Information Commissioner (FDPIC) here: www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.

C. DATA PROCESSING FOR CONTRACT EXECUTION

In this section we inform you about the processing of your data in connection with the initiation and/or execution of a contract in insurance matters with us or if you have commissioned us to process your tax return. You will find out which categories of data we process for which purposes and to whom we pass on your data, e.g. to service providers who provide us with technical support or to tax authorities, broker pools and insurers.

I. Processed data

We process your personal data in order to perform our task. This includes information that allows conclusions to be drawn about your person, such as your name, your telephone number, your address or your e-mail address.<br>

Statistical data that cannot be linked to your person is not considered personal data.

As a broker, we need to process certain information about you:

First of all, we need your contact data:

  • name, address, date of birth, age
  • telephone number, e-mail address
  • bank details

You provide us with this data as part of your registration.

We also process the following personal data:

  • Marital status
  • Occupation and salary
  • Special data categories (e.g. health data)
  • Current insurance situation
  • Family situation (partner, children)
  • Housing situation (current and planned)
  • Hobbies and interests
  • Pets
  • Other personal/economic circumstances, care wishes

You provide us with this data as part of the needs or pension check.

We also derive your product interests from this data.

In addition, we process your insurance data:

  • Application data (data provided by you when you apply to take out insurance)
  • Contract data for a specific contract (such as policy number, sum insured, term, premium, risk, investment amounts, credit amounts)
  • Benefit data (insured events, data on the occurrence of a claim or benefit event)

You provide us with this data when you take on or manage a brokerage mandate. If we take over an existing broker mandate, we will also receive the data from the insurers with your consent.

We also process your tax data:

  • Other personal details (e.g. date of birth, religious denomination)
  • Tax documents (e.g. tax returns, dispositions)
  • Information on income (e.g. salary statements, accounting for self-employed persons, alimony, income from securities, gambling winnings, pensions from AHV and occupational pension schemes)
  • Professional details and professional expenses (e.g. workload, transportation costs, work-related training costs and general work-related expenses)
  • Information on vehicles
  • Family circumstances (e.g. marital status, partner, children)
  • Health data (e.g. medical expenses, costs of health insurance premiums)
  • Housing situation and other properties (e.g. current and planned, rent or mortgage interest, maintenance costs)
  • Other financial circumstances (e.g. contributions to pillar 3a, account statements, receipts for securities, donation receipts)

You provide us with this data to process your tax return.

We also collect your usage data:

  • Interactions on the website and app or with e-mails (clicks, etc.)
  • Visits to the websites and app (which ones were accessed?)
  • Time spent on websites and app (how long did you look at a page)
  • Origin page (ref URL)
  • Time and date, e.g. when you visited our website and app.

We collect this data when you use our website and app.

Finally, we collect the following of your device, browser and location data:

  • Operating system of your end device (e.g. Windows, Android or iOS)
  • Model of your end device (e.g. iPhone, Samsung Galaxy)
  • Settings of your end device, e.g. screen resolution
  • Browser settings, e.g. language setting, time zone, installed plugins and fonts
  • IP addresses
  • Your location (we do not use GPS data, but only the information that can be derived from the IP address).

We collect this data when you use our website and app.

II. Why does Clark need my consent?

We may need your consent if we pass on particularly sensitive personal data to third parties. This includes, for example, information about your state of health. We need this information if we advise you on insurance products, in particular when processing claims for health and liability insurance.

We therefore ask for your consent when you decide on a corresponding product. You can revoke your consent at any time for the future by sending a message to info@ch.clark.io.

We may also require your consent in order to send you advertising information and to personalize it for the analysis of the usage behavior of our websites and apps. These consents are voluntary. It is also possible to use our services without this consent.

III. General information about our cooperation partners and data transfer

1. Broker pools

We use broker pools to offer you the best possible insurance policies at favorable rates. In order to provide you with a quote, we need to send them your personal data.

Our broker pools are:

Baumassurance AG Versicherungsbroker
Badenerstrasse 681
8048 Zurich

Global Sana AG
Thurgauerstrasse 30/32
8050 Zurich

By cooperating with broker pools, we can always provide you with the best and most favorable insurance policies for your situation.

2. Insurers

If you apply to us to take out insurance, we will send the relevant personal data to the insurer in question. You will find a list of these insurers in our form in accordance with Art. 45 of the Insurance Supervision Act (ISA).

As an insurance broker, we transmit information between you and the insurers.

3. Asset managers and mortgage partners

If you wish to make use of corresponding services, we may also pass on your data to asset managers (particularly in the area of vested benefits), mortgage partners and brokers and other financial experts.

4. Service providers

Some of the data processing may also be carried out by our service providers. In addition to the service providers mentioned in this privacy policy, these may include, in particular, data centers and cloud service providers that store our website and databases, IT service providers (including cloud, software and hosting providers) that operate and maintain our systems, consulting companies and service providers to whom we outsource certain tasks. If we pass on data to our service providers, they may only use the data to perform the tasks specified by us.

5. Official, legal and judicial inquiries and other third parties

In addition, data may be passed on in connection with official submissions and inquiries, court orders and legal proceedings if we are instructed to do so (e.g. in the context of tax returns) or if we believe in good faith that we are legally obliged to do so.

In addition, we may also disclose data to third parties such as auditors or if we believe in good faith that it is necessary for the following: To detect, prevent and prosecute fraud, unauthorized use of our product, and other harmful or illegal activities.

In individual cases, we disclose data to authorities or courts in response to legitimate requests.

6. Disclosure of personal data abroad

When using service providers and third parties, we generally only work with companies that process data within Switzerland or the European Economic Area (in particular Spain), or are located in countries that guarantee an adequate level of data protection in accordance with an adequacy decision by the Federal Council. One of our service providers to whom we outsource certain work has subcontractors in India. In exceptional cases, your data may also be processed in any country in the world.

If, when using service providers, your data is exceptionally processed in countries outside Switzerland or the EEA without an adequacy decision, we have concluded special contracts with the service providers for order processing, which contain the standard contractual clauses of the European Commission, unless they are already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exemption clause. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have given your consent or if it concerns data that you have made generally accessible and whose processing you have not objected to.

 IV. Data processing as part of the app and when providing advice

 1. Conclusion of mandate and identification

Processing purpose and use

The purpose of data processing is to mandate Clark to provide support in insurance matters.

By doing so, you commission us to arrange insurance contracts for you. This includes in particular the preparation and conclusion of insurance contracts as well as assistance in the administration and fulfillment, especially in the event of a claim.

In order to carry out the identification process, we need your telephone number so that we can send you a verification code. Your signature is required to conclude the brokerage mandate.

For the brokerage mandate and the commencement of our work, it is important that you identify yourself and that we know who you are.

Processed data

  • Contact data
  • Signature data

2. Account for the provision of our services

Processing purpose and use

To be able to use our service, you sometimes need a Clark account.

Registration and login take place when you use our services (in particular to process your tax return).

All information relevant to the use of our app and website is stored in your account.

Data processed

  • Account information
  • Contact information

3. Processing and submitting the tax return (incl. “Tax Wallet”)

Purpose of processing and use

Data processing is used to complete and submit the tax return. You can upload your tax documents to a tax wallet via our app. This ensures that all possible tax deductions are made. These documents may also contain particularly sensitive personal data

If you also upload insurance policies and pension documents, these will be analyzed for the purpose of a price-performance indication and, if necessary, you will be contacted by us for further advice. We will accompany you from the selection of the right insurance or investment product, through the conclusion of the contract with the insurance company, during the term of the contract, to the end of the contract. We draw on the experience of our employed advisors and sales partners as well as the latest digital technologies to provide you with the best conditions.

Processed data

  • Contact information
  • Tax information
  • Insurance data

Forwarding of data for this purpose

Tax authorities

This data is included in your tax return and, with your prior consent, is forwarded to the relevant tax authority or authorities for the purpose of filing your tax return.

4. Needs check

Purpose and use

On our website and in the app, we offer you a needs check that allows us to determine together in just a few minutes which insurance policies are suitable for your life situation.

We can then identify individual savings potential as a result of duplicate insurance cover or a lack of cover. The needs are determined by asking questions about your personal life situation.

We offer the needs check to fulfill a new brokerage contract or to implement your existing one.

If you have not concluded a brokerage contract with us and are not interested in detailed advice, you can still use some of our services.

Processed data

  • Personal data
  • Product interests
  • Contact information

6. Conclusion of insurance contracts

Processing purpose and use

The core area of our activity is to provide you with the best possible insurance policies. Therefore, we also process your data in the context of concluding contracts with insurers if you wish to purchase a specific insurance product.

In order to conclude such a contract, insurers will ask for a variety of information about you and your person.

Data processed

  • Contact information
  • Signature data
  • Insurance data
  • Payment information
  • Possible health data

Forwarding of data for this purpose

Broker pools

Broker pools enable us to efficiently connect to a large number of insurance companies in order to provide you with an optimal market overview.

Insurers

Our insurers process your data in Switzerland and, depending on the insurance, possibly in Liechtenstein or Germany. If it is necessary for your data to be transferred to other countries as part of an insurance policy, we will inform you in advance.

7. Communication

Purpose of processing and use

We process your data so that you can contact us via the contact form, live chat or telephone and we can respond to your inquiry.

Contact is made for the purpose of providing advice as part of our brokerage activities and processing tax returns.

Processed data

  • Contact details
  • Communication content

 8. Support for broker mandates

Purpose of processing and use

As your insurance broker, we support you in all insurance matters and on the topics for which you have added insurance policies in your profile, which interest you or for which we have identified a need for you. We use your personal details and your insurance data, i.e. the details of your insurance contracts or individual insurance cases, to:

  • provide you with secure and reliable information about your insurance policies;
  • make you better or more favorable offers for existing insurance policies;
  • inform you about relevant news or offer you new insurance policies that meet your needs and are appropriate for your life situation.

We use Salesforce to manage broker mandates and to optimize and automate sales processes.

Salesforce gives our sales consultants a quick and easy overview of the requirements of a mandate and helps us to meet our broker obligations. An interface is provided from which our communication can take place.

Processed data

  • Contact information
  • Insurance information
  • Payment information

Forwarding of data for this purpose

Broker pools

Broker pools enable us to efficiently connect to a large number of insurance companies in order to provide you with an optimal market overview.

Insurers

Our insurers process your data in Switzerland and, depending on the insurance, possibly in Liechtenstein or Germany. If it is necessary to transfer your data to other countries as part of an insurance policy, we will inform you in advance.

Salesforce – Sales Cloud

SFDC Ireland Limited
3rd and 4th Floor
1 Central Park Block G
Central Park
Leopardstown
18 Dublin
Ireland

To protect your data, we have concluded an order processing agreement and standard contractual clauses with Salesforce, which guarantee the level of protection of the DPA.

 9. Opportunity Generation

Purpose of processing and use

We use the information we have to analyze what interests or needs you have as a customer so that we can recommend suitable products for you. We perform this task as part of our duty to advise you as a broker.

To do this, we analyze the data according to certain criteria based on our experience as a broker, in particular on the basis of the information from the needs check. For example, if you indicate that you have a car, we will recommend a new or better car insurance policy if the analysis of an existing policy shows a need for optimization.

In order to constantly improve and further automate our product and our recommendations, we also use statistical methods to determine both your insurance needs and your satisfaction with your current insurance situation.

The aim of this is, on the one hand, to be able to provide you with the best experts and, on the other, to optimize the utilization of our insurance advisors.

Processed data

  • Contact information
  • Product interests
  • Insurance information

10. Database

Amazon Web Services (website host)

Our website and app are hosted by AWS (Amazon Web Services), an external service provider (host). The personal data collected on this website is stored on the host’s servers. This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

Our hoster will only process your data to the extent necessary to fulfill its performance obligations and follow our instructions with regard to this data.

D. DATA PROCESSING ON THE WEBSITE

We use cookies on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. We only use so-called session cookies, which are only used during a session and are deleted after your visit to the website.

You can set your browser to reject cookies, only store them for one session or otherwise delete them prematurely. Most browsers are pre-set to accept cookies.

E. DATA PROCESSING FOR MARKETING PURPOSES

 I. Newsletter

Purpose of processing and use

We use these emails to send you information about our products, special offers, discounts or other relevant news that may be of interest to you.

We also include visible and invisible image elements in some of these emails, where permitted, which we can retrieve from our servers to determine if and when you have opened the email so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are set to do this by default.

Data processed

  • Contact information
  • Product interests
  • Usage behavior
  • IP address

Data shared for this purpose

Salesforce

SFDC Ireland Limited
3rd and 4th Floor
1 Central Park Block G
Central Park
Leopardstown
18 Dublin
Ireland

 II. Data processing in the context of our partnerships

We cooperate with various partners to provide you with additional benefits. Certain of your data must be passed on so that our partners can check that you meet the relevant requirements.

With your application will be sent your number of insurance policies and a corresponding identifier. This allows us to check whether you meet the requirements for the respective benefit.

F. DATA PROCESSING ON SOCIAL MEDIA

 1. General

We may operate our own presences on social networks and similar third-party platforms. If you communicate with us via such sites or comment on or disseminate content from us, we collect the relevant information and process it in accordance with our privacy policy. At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g. about your behavior and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalize advertising) and to control their platforms (e.g. which content they show you).

We process this data in particular for communication, marketing purposes (including advertising on these platforms) and market research. We may redistribute content published by you (e.g. comments on an announcement) ourselves (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy policies of the platforms. There you can also find out in which countries they process your data, what information, deletion and other data subject rights you have and how you can exercise these or obtain further information.

 2. Facebook

We operate the page https://www.facebook.com/clarkschweiz on Facebook. The controller for the operation of the platform for users from Europe is Meta Platforms Ireland Ltd, Dublin, Ireland. Their privacy policy is available at https://www.facebook.com/policy. Some of your data will be transferred to the USA. You can object to advertising here: https://www.facebook.com/settings?tab=ads. We are jointly responsible with Meta Platforms Ireland Ltd, Dublin, Ireland, for the data collected and processed when you visit our website for the creation of “Page Insights”. As part of Page Insights, statistics are compiled about what visitors do on our site (comment on posts, forward content, etc.). This is described at https://www.facebook.com/legal/terms/information_about_page_insights_data. It helps us to understand how our site is used and how we can improve it. We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information at https://www.facebook.com/legal/terms/page_controller_addendum.

3. Instagram

We have a profile on Instagram at https://www.instagram.com/clarkschweiz. The provider is Instagram Inc. The provider is Instagram Inc, Menlo Park, USA, which belongs to the Meta Group (Facebook). Their privacy policy is available at https://privacycenter.instagram.com/policy. Some of your data will be transferred to the USA. You can object to advertising here: https://www.facebook.com/help/contact/1994830130782319. In connection with the operation of our Instagram profile, we use the Instagram Insights function to obtain statistical evaluations of the users of our posts. Information on Instagram Insights can be found in the privacy policy and at https://help.latest.instagram.com/788388387972460.

4. LinkedIn

We also operate a profile on LinkedIn at https://www.linkedin.com/company/clark-switzerland-ag. The provider is LinkedIn Ireland Unlimited Company, Dublin, Ireland. You can find more information on data protection on the LinkedIn platform in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy. Some of your data will be transferred to the USA. You can object to LinkedIn processing here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further settings can be made via the objection form: https://www.linkedin.com/help/linkedin/answer/a1338610/widerspruch-gegen-die-datenverarbeitung-einschrankung-der-datenverarbeitung?lang=en. In connection with the operation of our LinkedIn profile, we use LinkedIn Page Analytics. This provides us with information about the use of our content. We have regulated our responsibilities regarding data protection in accordance with the information at https://legal.linkedin.com/pages-joint-controller-addendum.

G. DURATION OF DATA STORAGE

We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e., for example, for the duration of the entire business relationship (from the initiation, execution to the termination of a contract) and beyond in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible.

H. FINAL PROVISION

This privacy policy is not 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.