This page explains the policy of the FCT, FCT 1e and Trianon SA (hereinafter "Trianon") regarding the collection, use and disclosure of personal data when the visitor uses the online services and visits the websites of the FCT and FCT 1e and the secure portal Employee Benefits Center (EBC) of Trianon SA.

Personal data of visitors is used to provide and improve the services. By using the online services, the visitor consents to the collection and use of information in accordance with this policy. 

Unless otherwise defined in this policy, terms used have the meanings set out in Section III below.

 

SECTION I: FCT AND FCT 1E WEBSITE

The FCT and FCT 1e website is operated by Sinartis, headquartered at 11 rue de Cossonay, 1023 Crissier.
It allows any internet user (hereinafter the "visitor or data subject”) to subscribe to the Newsletter of FCT and FCT 1e and to request to be contacted for any information. It also allows the visitor to obtain information about the services of FCT and FCT 1e. 
Finally, it allows the visitor affiliated with FCT and/or FCT 1e to access the Employee Benefits Center (EBC) portal (hereinafter the "Secure Portal") provided by FCT and FCT1e processor Trianon. 


SECTION II: SECURE EBC PORTAL

The secure portal is operated by Trianon SA, headquartered at chemin de la Redoute 54b, 1260 Nyon, Switzerland.
FCT and FCT 1e have entrusted Trianon SA with the administrative management of their services linked to occupational benefits LPP/BVG. To this end, all the information as well as the related forms and documents are visible and downloadable on the secure portal.


PARTIE III: DEFINITIONS

Personal Data

Personal Data means all information concerning an identified or identifiable living natural person. Personal and sensitive Data are defined by the DPA. They include surname, first name, marital status, postal and e-mail addresses, home address, AVS number, salary, start and exit dates, activity rate, buy-in calculations, early withdrawals, benefit calculations, incapacity to work and their nature, health data, cookies and IP address, browser type, browser version, pages viewed, date and time of visit and time of visit.

Cookies

Cookies are small files stored on the visitor's electronic device (computer or mobile device).

Data controller

The Data controller means the natural or legal person (alone, jointly or jointly with other persons) who determines the purposes and manner in which the Personal Data are or are to be processed. For the purposes of this policy, FCT and FCT 1e are Data controllers.

Processors (or service providers)

The term processor (or service provider) means any natural or legal person who processes the data on behalf of the controller. For the purposes of this policy, Trianon SA is a processor. FCT and FCT 1e may use the services of multiple service providers in order to process Personal Data more efficiently.

Data Subjects (or visitor)

The data subject or visitor means any living person who uses the online services and accesses the Sites and whose Personal Data is processed. 

 

SECTION IV GENERAL CONDITIONS OF USE OF THE FCT AND FCT 1E WEBSITE AND SECURE PORTAL ("THE SITES")

FCT, FCT 1e and Trianon undertake to process the collected Personal Data, where applicable, when using the Sites in accordance with this policy and in strict compliance with the Federal Data Protection Act (FDA) and its Ordinance (OPDo).

 

1. Purpose and acceptance of these provisions

These provisions govern the processing of the Personal Data of visitors collected when accessing the Sites via https://fctpension.swiss/en and www.trianon.ch and/or when using online services by the visitor.
In this context, these provisions automatically and unquestionably apply to any visitor of the Sites.

They are communicated when the visitor first accesses the Sites. Browsing the Sites by the visitor can only take place when the visitor has confirmed that he has read them. 

 

2. Collection, purpose of Personal Data

A. FCT and FCT 1e Website

When the visitor browses FCT and FCT 1e website, he/she may be asked to provide certain Personal Data.

Personal Data is used for the following purposes:

  • Providing and ensuring the implementation services of compulsory and optional occupational benefits and the development of the foundations (hereinafter referred to as "the services")

  • Communicate changes to services

  • Allow the use of the interactive features of the services at any time

  • Customer support

  • Collect analytical data to improve service quality

  • Monitoring the use of services

  • Detecting, preventing and resolving technical problems

  • Send Newsletters, commercial communications, invitations to events and other information that may be of interest to the visitor. The visitor may choose not to receive any communications or to receive only some communications by clicking on the unsubscribe link or by following the instructions provided in each of the emails sent.

 

B. Secure portal

Personal Data about the visitor is collected when he/she completes an online form or subscribes to certain services offered by the secure portal, and are then used or processed by Trianon, FCT, FCT 1e or by the visitor. The visitor undertakes to provide the Personal Data requested in full and in accordance with reality and to communicate any changes without delay.

Personal Data are collected and processed for:

  • The implementation of compulsory and optional occupational benefits schemes within the meaning of the LPP/BVG and the OPDo

  • Allow the use of the interactive features of the services at any time

  • Customer support

  • Collect analytical data to improve the quality of services offered by the secure portal

  • Monitor the use of the services offered by the secure portal

  • Detecting, preventing and resolving technical problems

 

3. Retention of data

The Personal Data of the visitor are stored in an identifiable form only to the extent and for the duration required for the processing of his/her request, where applicable to the extent and for the duration required by the services subscribed. They are then deleted.

Retention beyond that period and disclosure to the competent authorities shall be reserved, in accordance with the applicable legal requirements, in particular in the event of suspicion of illegal activity and/or at the request of the authorities.


4. Use of traceability systems and cookies

A. FCT and FCT 1e Website

The FCT and FCT 1e website uses cookies and other similar tracking technologies to track activity. 

Cookies are small data files that may contain an anonymous unique identifier. Cookies are sent to the visitor's browser from a website and are stored on the visitor's device. Other tracking technologies such as pixels, beacons and scripts are also used to collect and track information and to improve and analyze services. Visitors may ask their browser to refuse all cookies or to notify them when they are sent. However, if the visitor does not accept cookies, he/she may not be able to use certain elements of the website.

The FCT and FCT 1e website uses the following cookies:

  • Session cookies. These cookies are used to store data on the visitor's session.

  • Preference cookies. These cookies are used to remember the preferences and different settings of the visitor.

  • Security cookies. These cookies are used for security reasons.

  • Advertising cookies. These cookies allow us to present our visitors with advertisements that may be of interest to them and correspond to their interests.

The FCT and FCT 1e site uses the following systems:

Publicity

The FCT and FCT1e may use third-party service providers to deliver advertisements that help support and maintain their service.

Google AdSense and DoubleClick Cookie

This system enables Google and its partners to serve advertisements to users based on their use of the services or other websites. The DoubleClick cookie may be refused by consulting the Google Ads Settings web page (Google Ads settings): http://www.google.com/ads/preferences/.

AdMob by Google

The AdMob by Google service is provided by Google Inc. The AdMob by Google service may be refused by following the instructions given by Google https://support.google.com/ads/answer/2662922?hl=en. 

For more information on how Google uses the collected data, visit the "How Google uses data when you use our partners' sites or app" page http://www.google.com/policies/privacy/partners/ or Google's privacy policy: http://www.google.com/policies/privacy/.

Behavioral Remarketing

The FCT and FCT1e use remarketing services to deliver advertisements on third-party sites to the visitor after the visitor has consulted their services. They and their third party providers use cookies to shape, optimize and deliver ads based on the visitor's previous use of their services.

Google Ads (AdWords)

The FCT and FCT1e use remarketing services to deliver advertisements on third-party sites to the visitor after the visitor has consulted their services. They and their third party providers use cookies to shape, optimize and deliver ads based on the visitor's previous use of their services.

The Google Ads remarketing service (AdWords) is provided by Google Inc. You may refuse this service by consulting the Google Ads Settings page: http://www.google.com/settings/ads.  Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - in the web browser. The Google Analytics Opt-out Browser Add-on allows visitors to prevent Google Analytics from collecting and using their data. 

Facebook

To opt out interest-based Facebook ads, the visitor can follow Facebook's instructions on the following page: https://www.facebook.com/help/568137493302217 
For more information on Facebook's privacy practices, please consult Facebook's data policy: https://www.facebook.com/privacy/explanation.

Google Analytics

Google Analytics is a web analytics service provided by Google that tracks and reports on website traffic. Google uses the data collected to track and monitor the use of our service. This data is shared with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

The visitor can prevent his/her activities from being made available to Google Analytics by installing the browser plug-in Analytics Opt out browser add-on from Google Analytics. This plug-in prevents the Google Analytics JavaScript code (ga.js, analytics.js and dc.js) from sharing information about visit activities with Google Analytics. For more information about Google's privacy practices, please visit: https://policies.google.com/privacy?hl=en.

 

B. Secure portal

The secure portal uses its own analytical tools and analytical products developed by third parties that use Personal Navigation Data, in particular with the aim of facilitating navigation, improving and personalizing the services and compiling statistics on page viewing or other reports requested by the Pension Fund.

These tools work with cookies. Cookies are completely anonymous and do not contain any Personal Data about the visitor. To learn more about Google's privacy policy, please visit the following link: http://www.google.com/intl/fr/policies/privacy/partners/. 
By using the secure portal, the visitor agrees to the processing of his/her Personal Browsing Data by Google under the conditions and for the purposes described above.

Cookies can always be deactivated by the visitor using the settings tools of their browser.

 

5. Links to other sites

The visitor may access third-party sites via hypertext links. In this case, such access is at the sole and exclusive responsibility of the visitor and the visitor acknowledges that Personal Data concerning him or her will not be processed on these sites in accordance with these provisions, but in accordance with the privacy policy of the third party operator, to the exclusion of any liability of FCT, FCT 1e or Trianon. 


6. Disclosure of Personal Data

Personal Data of the visitor are transmitted to third parties:

  • only with its prior consent, or

  • to fulfill a legal obligation, or

  • to protect and defend the rights or assets of the FCT and FCT 1e, or

  • to prevent or investigate possible wrongdoing in connection with the services,

  • to ensure the personal safety of service users or the public,

  • to protect against civil liability.

 

7. Security of Personal Data

Personal Data is stored with care and discretion, using appropriate security, technical and organizational measures in accordance with best practice and applicable data protection laws. These measures are intended to protect Personal Data against any infringement, access or unlawful use, bearing in mind that absolute security cannot be guaranteed on the Internet.


8. Rights

The rights of the data subjects under the DPA are as follows: 

a) Right of access – Data subjects have the right to request copies of their data at any time without giving reasons. 

b) Right to information – Data subjects have the right to be informed about how their data are used. This policy, and any additional information, is intended to provide that information.

c) Right to withdraw consent: Where data are processed on the basis of consent, consent may be withdrawn at any time. 

d) Right of rectification – data subjects have the right to request the rectification of inaccurate data and the completion of incomplete data. 

e) Right to restriction of processing – data subjects may request restriction of data processing, if permitted by law.

f) Right to erasure/deletion – Data subjects have the right to request erasure or deletion of data unless a legal basis or the legitimate interest of FCT, FCT 1e or Trianon requires or permits them to retain the data.

g) Right to object to processing – Data subjects have the right to object to the processing of their data at any time.

h) Right to the provision or transmission of data – Data subjects have the right to request the provision or transmission of data in a portable format where the processing of data is carried out by automated means, on the basis of consent or a contract.

i) Right to complain: If the data subjects are not satisfied with the way the data are processed, they may complain to the courts or to the federal data protection authority.

 

9. Contact

A. FCT and FCT 1e Website

For any request relating to Personal Data (including access to data, rectification or deletion, etc.) processed through the FCT and FCT 1e website, the visitor may contact Ms Isabelle Hering: 

  • By registered mail: 

         Ms Isabelle Hering
         DPO-Associates Sarl
         Place du Marché 1
         1260 Nyon

  • By e-mail: contactdpo@dpo-associates.ch

 

B. Secure portal

For any request relating to Personal Data (including access to, rectification or deletion of, etc.) in the processed through the secure portal, the visitor may contact: dataprotectionofficer@trianon.ch.

 

10. Entry into force and final provisions

These provisions come into force on 1 September 2023. The FCT and FCT1e may amend them at any time. The amendments are effective immediately to all visitors, even if they have already accessed the Sites.

If any provision herein were to be null and void, the remaining provisions would still be applicable. In such a case, the null and void provision would be interpreted as closely as intended.

The content of the Sites is intended for visitors located in Switzerland. Thus, even if the visitor accesses the sites from a computer abroad, Swiss law remains applicable.
These Rules may be translated into several languages, however the French is the only authoritative text.

 

11. Forum and applicable law

Any dispute arising from the collection or processing of Personal Data by FCT and FCT 1e, through the FCT and FCT 1e website, shall be subject exclusively to Swiss law, to the exclusion of any other law and conflict of laws rule. The exclusive forum for any proceedings arising therefrom shall be Geneva.
 


October 2023