1. Data controller
The controller for the personal data collected via this website (hereinafter the “Site”) is:
Swiss Premium Insurance Sàrl
Place Cornavin 14, 1201 Geneva, Switzerland
Email: contact@3emepilier-infos.ch · Phone: +41 22 559 86 84
2. Legal framework
We process your data in accordance with the Federal Act on Data Protection (the revised FADP, known as the nFADP) and its implementing ordinance. Where the European Union’s General Data Protection Regulation (GDPR) applies — for example to people residing in the EU — we also ensure that we respect its principles.
3. Data we collect
Depending on how you use the Site, we may process the following categories of data:
| Data you provide to us | First name, last name, phone number, email address, as well as the information you enter in our forms or simulator (e.g. age, situation, indicative income, professional status, preferred call-back time). |
|---|---|
| Data collected automatically | IP address, browser type and version, operating system, device type, time zone, pages viewed, date and duration of the visit, referring site or ad, and identifiers linked to cookies. |
You can browse the Site without providing identifying data. However, certain features, such as requesting a call back or a personalised simulation, require you to provide certain data; without it, we will not be able to act on your request.
We do not collect health data via the Site.
4. Purposes and legal bases
We process your data for the following purposes:
| Purpose | Legal basis |
|---|---|
| Contacting you and responding to your request for a quote, simulation, or call back regarding the 3rd pillar | Your consent and the performance of pre-contractual measures at your request |
| Supporting you in choosing and setting up a pension solution | Performance of the relationship / pre-contractual measures |
| Ensuring the operation, security, and improvement of the Site, and preventing fraud and abuse | Our legitimate interest |
| Measuring audience and the effectiveness of our advertising campaigns (e.g. Google Ads), and sending you marketing communications | Your consent (via the cookie banner) |
We do not sell your personal data.
5. Cookies and tracking technologies
A cookie is a small file placed on your device when you visit the Site. We use:
- Necessary cookies: essential to the operation of the Site; they do not require your consent.
- Analytics cookies: to understand how the Site is used and to improve it.
- Marketing and advertising cookies: to measure and optimise our campaigns, in particular via Google Ads, and to limit ad repetition.
On your first visit, a banner lets you accept or decline non-essential cookies. You can change your choice at any time via your browser settings. Declining certain cookies may limit some features of the Site.
On this Site, we use the following tools: Google Analytics 4 (audience measurement), Google Ads (tracking and optimisation of our advertising campaigns, conversion measurement), and Google Tag Manager (tag management). These tools are provided by Google and are only activated after you consent to analytics and marketing cookies.
6. Recipients and data sharing
Your data may be shared with:
- our authorised staff and advisers, within the limits of their duties;
- our technical service providers acting as processors (hosting, customer relationship management tool, analytics and advertising tools), who are required to guarantee an adequate level of protection;
- insurance companies and partner providers, where necessary to prepare an offer or set up the solution you request;
- the competent authorities, where required by law.
7. Transfer of data abroad
Some of our providers may be located outside Switzerland, including in the European Union or the United States. In such cases, we ensure that the transfer is accompanied by appropriate safeguards (countries offering adequate protection, or standard contractual clauses), in accordance with the nFADP.
8. Retention period
We keep your data for as long as necessary for the purposes described above, then for the periods required by our legal obligations (in particular accounting obligations and those linked to insurance intermediary activity), before deleting or anonymising it.
9. Security
We implement reasonable technical and organisational measures (restricted access, encryption of communications, firewalls) to protect your data against loss, unauthorised access, disclosure, or alteration. However, since no transmission over the internet can be guaranteed to be completely secure, we cannot guarantee absolute security.
10. Your rights
Within the limits set by applicable law, you have the following rights regarding your data:
- the right to be informed and the right of access;
- the right to rectification;
- the right to erasure;
- the right to restriction and the right to object to processing;
- the right to data portability;
- the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before that withdrawal.
To exercise these rights, write to us at contact@3emepilier-infos.ch or at the postal address given in point 1. We may ask you to prove your identity. You also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).
11. Minors
The Site is intended for adults. We do not knowingly collect data concerning minors without the consent of their legal representative.
12. Changes
This policy may be adapted to reflect changes in our practices or in the legal framework. The applicable version is the one published on the Site.