This notice (Privacy Notice) applies to information held about you and individuals connected to your business by HSBC Bank plc, London, Zurich branch and other members of the HSBC Group as data controllers, as described below. It explains what information we collect about you and individuals who are connected to your business, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.
It continues to apply even if your agreement for banking, or other products and services with us ends. It should also be read alongside your banking terms and conditions (or other applicable product or service terms and conditions), as these include sections relating to the use and disclosure of information.
This Privacy Notice covers any commercial banking products or services you have with us, including savings, loans, credit cards, commercial mortgages, investments, trade finance, invoice financing, asset financing and payment services. Sometimes we may need to provide you with separate or further information about specific products and services. This will also apply if you also have a relationship with other entities of the HSBC Group in any other countries. These entities will provide you with information separately where required.
Some of the links on our websites lead to other HSBC or non-HSBC websites with their own privacy notices, which may be different to this notice. You’ll need to make sure you’re happy with their privacy notices when using those sites.
Wherever we’ve said ‘you’ or ‘your’, this means you, any authorised person on your account, anyone who does your banking or deals with us for you (eg trustees or executors, attorneys under a Power of Attorney) and other related people (including authorised signatories, partners, members, trustees and beneficiaries of payments).
Parts of this notice relate only to individuals, and we have highlighted this where relevant. This includes individuals whose business does not have a separate legal identity (eg sole traders and partners in a general partnership, but excluding limited companies and other forms of corporate entity), and individuals connected to your business.
An individual connected to your business could be any guarantor, a director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person, or beneficial owner, trustee, settlor or protector of a trust, account holder of a designated account, recipient of a designated payment, your attorney or
representative (eg authorised signatories), agent or nominee, or any other persons or entities with whom you have a relationship that’s relevant to your relationship with us.
Before you (or anyone on your behalf) provide information about an individual connected to your business to us, or an entity of the HSBC Group, you must ensure that you have a legitimate interest, lawful purpose or the agreement of
the relevant individual. You must also ensure that they have been provided with this notice, which explains the way in which their information will be processed and their rights in relation to their information.
When we say ‘we’, we mean HSBC Group companies which act as a data controller in respect of your personal data. Unless otherwise stated below, the data controller for the purposes of this notice will be HSBC Bank plc, London, Zurich branch.
The address for HSBC Bank plc, London, Zurich branch is Gartenstrasse 26, 8002 Zurich, Switzerland. If you’d like to get in touch with us, you can also find contact details below.
When you have a contractual relationship with another HSBC Group company, this entity will act as a data controller for the personal data collected in relation to the product or service it provides you with.
We’ll only collect your information and information relating to individuals connected to your business, in line with relevant regulations and law. We may collect it from a range of sources and it may relate to any of our products or services you apply for, currently hold or have held in the past. We may also collect information about you and individuals connected to your business when you or they interact with us, eg visit our websites or mobile channels, call or visit us, or ask about any of our products and services.
Some of this information will come directly from you and individuals connected to your business, eg when providing ID to open an account. It can also come from your financial advisor, solicitor, broker or other intermediary, other HSBC Group companies, or other sources you’ve asked us to obtain information from. We might also get some of it from publicly available sources.
The information we collect may include:
Information relating to you and individuals connected to your business that you provide to us, or which others provided to us on your behalf eg
Information we collect or generate about you and individuals connected to your business eg
Information we collect from other sources relating to you and individuals connected to your business, eg
We’ll only use information on you and individuals connected to your business where we have consent or we have another lawful reason for using it. These lawful bases include where we:
Further details of how we’ll use your information can be found in the Appendix below.
How we make decisions about you
We may use automated systems to help us make decisions, (eg when you apply for products and services, to make credit decisions and to carry out fraud and money laundering checks). We may use technology that helps us identify the level of risk involved in customer or account activity (eg for credit, fraud or financial crime reasons, or to identify if someone else is using your card without your permission).
Tracking or recording what you say or do
To help keep you and your money safe, we may record details of your interactions (and the interactions of the individuals connected to your business) with us. We may record and keep track of conversations with us including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication.
We may use these recordings to check your instructions to us, assess, analyse and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also capture additional information about these interactions (eg telephone numbers that we are called from and information about devices or software that are used).
We use closed circuit television (CCTV) in and around our sites and these may collect photos, videos or voice recordings of you and the individuals connected to your business.
Compliance with laws and regulatory compliance obligations
We’ll use your information and information relating to individuals connected to your business to meet our compliance obligations, to comply with laws and regulations that HSBC Group companies are subject to and to share with our regulators and other regulators and authorities.
This may include using information to help detect or prevent crime (including terrorism financing, money laundering and other financial crimes). We’ll only do this on the basis that it’s needed to comply with a legal obligation or it’s in our legitimate interests and that of others.
Marketing and market research
We may use your information and information relating to individuals connected to your business to provide information about HSBC products and services, and also products and services from our partners and other relevant third parties.
We may send marketing messages by post, email, telephone, text or secure messages. If you or individuals connected to your business wish to change how marketing messages are sent or wish to stop receiving these, please contact us in the usual way (please note the contact information at the end of the privacy notice).
It may take us a short period of time to update our systems and records to reflect requests to stop receiving marketing messages, during which time you and individuals connected to your business may continue to receive marketing messages. Even if you tell us not to send marketing messages, we’ll continue to use contact details to provide important information, such as changes to our terms and conditions or if we need to tell you, or individuals connected to your business, something to comply with our regulatory obligations.
We may use your information and information relating to individuals connected to your business for market research and to identify trends. Subject to the legal and regulatory framework applicable to us, market research agencies acting on our behalf may get in touch with you or individuals connected to your business by post, telephone, email or other methods of communication to invite you or them to take part in research. We won’t invite you or individuals connected to your business to take part in research using a communication method if you (or they) have asked us not to get in touch that way. Any responses that are provided whilst participating in market research will be reported back to us anonymously unless you or the individuals connected to your business give us permission for the relevant details to be shared.
Subject to the legal and regulatory framework applicable to us, we may share your information and information relating to individuals connected to your business with others where lawful to do so including where we or they:
Subject to the legal and regulatory framework applicable to us, we may share your information and information relating to individuals connected to your business for these purposes with others, including:
Sharing aggregated or anonymised information
We may share aggregated or anonymised information within and outside of the HSBC Group with partners such as research groups, universities or advertisers. Neither you nor individuals connected to your business will be able to be identified from this information (eg we may share information about general spending trends in Switzerland to assist in research).
We’ll store information in line with our data retention policy. For example, we’ll normally keep your core banking data for a period of ten years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or to use your information where we need to for our legitimate purposes such as managing your account and dealing with any disputes or concerns that may arise.
We may need to retain information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes (eg to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc.).
If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.
Where you receive products and services from third parties (eg insurance) to whom HSBC has introduced you, those third parties may keep your information, and information relating to individuals connected to your business, in line with the terms and conditions and privacy notice of such third party.
Your information and information relating to individuals connected to your business may be transferred to and stored in locations outside Switzerland, respectively the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer information in this way to carry out our contract
with you, to fulfil a legal obligation and/or to protect the public interest. In some countries the law might compel us to share certain information (eg with tax authorities). Even in these cases, we’ll only share information with people who have the right to see it.
You can obtain more details of the protection given to your information (and information relating to individuals connected to your business) when it’s transferred outside Switzerland (including the list of destination countries) by contacting us using the details in the ‘More details about your information and information about individuals connected to your business’ section below.
Subject to the legal and regulatory framework applicable to us, individuals have a number of rights in relation to the information that we hold about them. These rights include:
You’re responsible for making sure the information you give us, information which is provided by individuals connected to your business, or information which is otherwise provided on your behalf is accurate and up to date, and you must tell us if anything changes as soon as possible.
We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.
More details about your information and information relating to individuals connected to your business
You and individuals connected to your business can obtain further information on anything we’ve said in this Privacy Notice in contacting us at HSBC Bank plc, London, Zurich branch Gartenstrasse 26, 8002 Zurich, Switzerland.
This Privacy Notice may be updated from time to time and the most recent version can be found at https://www.hsbc.ch/en-gb/privacy.
We’ll use your information and information about individuals connected to your business for the following purposes: