Privacy Notice

Last updated: 21st August 2023

1. What is this Privacy Notice about?

The True Partners AG (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».
In this Privacy Notice, we describe what we do with your data when you use truepartners.ch, our other digital platforms under the second level domain truepartners.ch or creditinsurance.ch (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice.

If you disclose data to us or share data with us about other individuals, such as co-workers, etc., we assume that you are authorized to do so, and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA». However, the application of these laws depends on each individual case.

2. Who is the controller for processing your data?

The True Partners AG, Bisikon (the «True Partners») is the controller for the True Parnters AG’s processing under this Privacy Notice, unless we tell you otherwise in an individual case.


You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:

True Partners AG
Ziegelhüttenstrasse 12
CH-8307 Bisikon
datenschutz@truepartners.ch

3. What data do we process?

We process various categories of data about you. The main categories of data are the following:

  • Technical data: When you use our website or other online offerings (for example free Wi-Fi), we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for 6 months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
  • Registration data: Certain offerings (for example login areas of our website, newsletters, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or service. We generally keep registration data for 12 months from the date the use of the service ceases or the user account is closed.
  • Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we must or want to determine your identity, we collect data to identify you (for example a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years. Chats are generally stored for 2 years.
  • Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, newsletters, etc.). We receive master data from you (for example in the course of business or as part of a registration), from parties you work for, or from third parties such as contractual partners, and from public sources such as public registers or the internet (websites, social media, etc.). We may also process health data and information about third parties as part of master data. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is usually much shorter, usually no more than 2 years from the last contact.
  • Contract data: This means data that is collected in relation to the conclusion or performance of a contract, claims data, as well as data from the period leading up to the conclusion of a contract. This includes health data and information about third parties. We generally collect this data from you, your employer, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
  • Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example at events, with security cameras, etc.). We may also collect data about who participates in events and who uses our infrastructure and systems and when. The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few weeks for contact tracing and visitor data, which is usually kept for 3 months, to several years or more for reports about events with images.

Much of the data set out in this Section 3 is provided to us by you or your employer (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases, for example within the framework of binding health protection concepts (legal obligations). If your employer enters into contracts with us or uses our services, they must also provide us with certain data, in particular master data, contract data, claims data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided.

Data is provided to us also by insurance companies or third parties involved in the processing of contracts or claims.

As far as it is not unlawful we also collect data from public sources or receive data from public authorities and from other third parties.

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries.

We process data for the conclusion, administration and performance of contractual relationships.


We process data for marketing purposes and relationship management. This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events) and may also include free services (for example invitations). You can object to such contacts at any time or refuse or withdraw consent to be contacted for marketing purposes.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and trainings.

5. On what basis do we process your data?

Where we ask for your consent for certain processing activities, we will inform you separately about the relevant processing purposes. You may withdraw your consent with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you or your employer or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law).

We may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.

6. What applies in case of profiling and automated individual decisions?

We will not automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3).

In certain situations, it may be necessary for the efficiency and consistency of decision-making processes that we automate discretionary decisions that produce legal effects concerning you or similarly significantly affect you («automated individual decisions»). In these cases, we will inform you accordingly and take the measures required by applicable law.

7. With whom do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

  • Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, login service providers). This may include health data. One of our service providers in the IT area is Microsoft. We use Microsoft 365 and Azure and, if possible, Microsoft’s dataserver in Switzerland.
  • Contractual partners including customers: This refers to customers and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. This may include health data. These recipients also include contractual partners with whom we cooperate (for example international broker network).
  • Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests or our clients’ interests. This may include health data. These authorities act as separate controllers.
  • Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4.

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

We reserve the right to make such disclosures even of secret data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, except if we are required to do so by law). Notwithstanding the foregoing, your data will continue to be subject to adequate data protection in Switzerland and the rest of Europe, even after disclosure. For disclosure to other countries, the provisions of Section 8 apply. If you do not wish certain data to be disclosed, please let us know so that we can review if and to what extent we can accommodate your concern (Section 2).

In addition, we enable certain third parties to collect personal data from you on our website and at events organized by us (for example providers of tools on our website, etc.). Where we have no control over these data collections, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 12 for the website.

8. Is your personal data disclosed abroad?

As explained in section 7, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed in Europe; in exceptional cases, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

9. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

10. How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

11. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights;

If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.

12. Do we use online tracking techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»).

We use these technologies on our website. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):

  • Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to 24 months.
  • Performance cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.

13. Web server protocols

When you visit or interact with our website, we automatically collect and store information in so-called server logs («log files») that your browser automatically transmits to us. These are:

  • browser type and browser version
  • Operating system used
  • origin URL
  • host name of the accessing computer
  • time of the server request
  • IP address

This data is not merged with other data sources. This data is stored on the web server for 3 months.

14. Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.