Privacy Policy

1. Introduction

Henry Dannell Switzerland GmbH (“we”, “us”, “our”) is committed to protecting your personal data in compliance with the Swiss Federal Act on Data Protection (FADP), the General Data Protection Regulation (GDPR) (EU 2016/679) where applicable, and the Data Privacy Framework (DPF) Principles.

Henry Dannell Switzerland GmbH is registered with the Swiss Federal Data Protection and Information Commissioner (FDPIC).

This Privacy Notice explains how we collect, use, disclose, and protect your personal data when providing our services.

2. Data Collection and Processing

We collect and process your personal and financial data under:

• Article 6(1)(b), 6(1)(c), and 9(2)(a) of GDPR
• Articles 4, 5, and 6 of the Swiss FADP
• The DPF Principles for data transfers involving the EU, UK, and Switzerland

We process your data to:

• Fulfil our contractual obligations
• Comply with legal and regulatory requirements
• Provide you with the financial services outlined in our agreement

We will store your personal data for a maximum of 7 years, unless a longer retention period is required by law or regulatory obligations.

3. Categories of Data We Process

We may collect and process the following personal data:

• Identity data: Full name, date of birth, address, email, phone number, Swiss Social Security Number (AHV/AVS) or National Insurance Number
• Financial data: Income details, bank account information, tax data, investment details
• Regulatory and compliance data: Documentation necessary for anti-money laundering (AML) and Know Your Customer (KYC) requirements

If you do not proceed with our services, your personal data will be deleted unless retention is required by law.

4. Data Sharing and Disclosure

To provide our services, we may share your personal data with:

• Affiliated companies and service providers, including electronic verification providers, compliance service providers, and financial institutions (e.g., lenders, banks, insurers, fund managers, platform providers)
• Regulatory and supervisory authorities, including:
  • Swiss Federal Data Protection and Information Commissioner (FDPIC)
  • Swiss Financial Market Supervisory Authority (FINMA)
  • UK Information Commissioner’s Office (ICO)
  • EU Data Protection Authorities (DPAs)
  • Financial Ombudsman Service (FOS)
  • Financial Services Compensation Scheme (FSCS)

We are required to disclose your personal data to these authorities where necessary for investigations, regulatory audits, or dispute resolution.

For compliance and auditing purposes, we may share your data with:

• QDEX AI Limited
• Salesforce
• HubSpot

5. Processing of Sensitive Data

We may process special categories of personal data, such as:

• Health data
• Ethnic origin
• Criminal records

This data is only processed where necessary (e.g., when advising on protection or annuity products) and obtained from trusted sources, such as your employer, credit reference agencies, and fraud prevention bodies.

6. Compliance with the Data Privacy Framework (DPF)

We are committed to upholding the Data Privacy Framework (DPF) Principles for data transfers between Switzerland, the EU, and the UK. This includes:

• Dispute Resolution: We commit to resolving complaints regarding our collection or use of personal information under the Data Privacy Framework (DPF). Any questions or concerns should be directed to our Data Protection Officer (DPO) at kem.kemal@henrydannell.co.uk
• Cooperation with Authorities: In the event of unresolved DPF complaints, we cooperate with:
  • The EU Data Protection Authorities (DPAs)
  • The UK Information Commissioner’s Office (ICO)
  • The Swiss Federal Data Protection and Information Commissioner (FDPIC)

These authorities provide independent dispute resolution mechanisms for cross-border data transfers.

7. Your Rights Under Swiss Data Protection Law

You have the following rights under the Swiss FADP and GDPR (where applicable):

• Right to access – Request a copy of your personal data.
• Right to rectification – Correct any inaccurate or incomplete data.
• Right to deletion – Request deletion of your data when legally applicable.
• Right to restrict processing – Limit the use of your data in certain situations.
• Right to object – Withdraw consent or object to processing.
• Right to data portability – Receive a structured copy of your data.

To exercise these rights, please contact info@henrydannell.ch.

8. International Data Transfers

If we transfer your personal data outside Switzerland, the EU, or the UK, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the Swiss FDPIC and the European Commission
• Adequacy decisions where applicable
• Binding Corporate Rules (BCRs) for affiliated companies

9. Contact Information

If you have any questions about this Privacy Notice or how we handle your personal data, please contact our Data Protection Officer (DPO):

Kem.kemal@henrydannell.co.uk