(as at December 2021)
Among other services, Avadis Vorsorge AG (hereinafter referred to as ‘Avadis’) provides asset management services to pension funds, foundations and other institutional investors (hereinafter referred to as ‘clients’). Avadis has set up the Infront Customer Account (hereinafter referred to as ‘ICA’) to offer its clients a portal comprising a Mailbox function where clients can access the client reporting and a Portfolio Access function where clients can view their assets and transactions.
Data protection and data security are high priority issues for Avadis. The protection of personal data in all business processes performed by Avadis is therefore a very important concern for us.
1. Data controller / data protection officer
Responsibility for the data collected and compiled in connection with the ICA lies with Avadis Vorsorge AG, Zollstrasse 42, 8005 Zurich.
Please send any queries regarding the processing of personal data (cp. para. 6) by letter or by e-mail to the data protection officer at Avadis:
Data protection officer
P.O. Box 1077
2. Processing purposes
The data collected on the ICA portal are processed for the following purposes:
Provision of client reporting;
Granting clients/users access to their assets and transactions;
Maintenance and safeguarding of the secure and efficient operation of the application and safeguarding of all appropriate and necessary further development of the software.
3. Categories of personal data that are subject to processing
The following personal data is processed on the ICA:
Surname/first name and e-mail address of the ICA user
Clients’ account no., BIC
Clients’ assets and transactions
4. Transfer of personal data to third parties
Avadis may transfer the personal data processed in connection with the use of the ICA (cp. para. 3) for the purposes specified in para. 2 to other Avadis Group companies or to third parties which process such personal data on behalf of Avadis in the context of a contractual relationship.
Within the Avadis Group, employees’ access to personal data is restricted to the extent necessary for the performance of their work.
Third parties to whom data is transferred in the context of a contractual relationship may exclusively process such data for the purposes specified above. In this connection, the respective contract will guarantee that such third parties comply with the provisions under the data protection laws, that the third parties will not use the personal data beyond the scope of their specific contract and that they will neither use the personal data for their own purposes nor transfer them to other third parties, or exclusively transfer them to subcontractors that have received the prior approval of Avadis.
5. Transmission of personal data abroad
Avadis may transmit personal data outside Switzerland provided this complies with the local data protection rules. In principle, personal data may be transmitted to any country in the world, especially to all countries where service providers engaged by Avadis process personal data on Avadis’ behalf.
In the event of the transmission of personal data to countries that do not guarantee an adequate level of data privacy, Avadis is required to safeguard the protection of personal data by means of appropriate contractual guarantees in accordance with the applicable data protection rules, namely the Federal Data Protection Act, or to rely on an exemption applicable to the situation in question.
6. Rights of the data subject / complaint procedure
Data subjects have the right to assert against the data controller, i.e. Avadis (cp. para. 1), the data subject rights pertaining to their personal data to which they are entitled according to the applicable data protection rules, namely the Federal Data Protection Act, at any time, for example the right to information, the right to erasure, the right to rectification or the right to restriction of processing. If the processing of the personal data requires the consent of the data subject, this consent may be revoked in whole or in part at any time.
Data subjects may address any complaints concerning their data subject rights to the data protection officer at Avadis by letter or by e-mail:
Data protection officer
Zollstrasse 42 / P.O. Box 1077
Avadis reserves the right to restrict the rights asserted by data subjects within the limits of the applicable law.
Users of the ICA are also entitled to lodge a complaint regarding the processing of their personal data by Avadis with the competent data protection authority.
7. Data security
Avadis has implemented the technical and organisational measures necessary to protect the personal data processed on the ICA portal against unauthorised access and unauthorised data processing. These measures are subject to regular review and conform to the respective state of the art.
Please send any general queries regarding the ICA to the following e-mail address:
9. Final provisions
Avadis is not responsible for ensuring that users can/are permitted to access or download information, software and/or documentation on the ICA from locations outside Switzerland. Where users access the ICA from locations outside Switzerland, they are solely responsible for compliance with the relevant regulations according to the respective national law.
Avadis may amend or discontinue the ICA at any time.
Swiss law applies exclusively to any queries and disputes in connection with the ICA, to the express exclusion of the conflict of law rules. The exclusive place of jurisdiction is Zurich.