Digital Communications Policy

The controller for data processing purposes is:

Aargauische Kantonalbank
Bahnhofplatz 1
CH-5001 Aarau

If you have any questions relating to data processing, please contact:

Aargauische Kantonalbank
Data Protection
Bahnhofplatz 1
CH-5001 Aarau

datenschutz@akb.ch

AKB processes data in accordance with Swiss data protection law, including in particular the Swiss Federal Act on Data Protection [Bundesgesetz über den Datenschutz] (DSG) and the Swiss Ordinance to the Federal Act on Data Protection [Verordnung zum Bundesgesetz über den Datenschutz] (VDSG).

AKB processes the personal data that are necessary in order to be able to conduct its activities and operations securely, reliably, in a user-friendly fashion and on an ongoing basis. These personal data may contain in particular master data, contact data, browser and device data, content data, metadata and usage data, location data, sales data as well as contractual and payment data. 

AKB processes personal data for the period of time that is necessary for the respective purpose or purposes or that is required by law. Where technically possible, any personal data that no longer need to be processed are anonymised or erased.
AKB can arrange for personal data to be processed by a third party, process personal data in conjunction with third parties or transmit personal data to third parties. Such third parties include in particular specialist providers, the services of which AKB avails itself. AKB warrants that data will be protected also by such third parties.

Personal data are only processed with the consent of the data subject, unless processing is permitted according to another legal basis. Processing without consent may be permitted for instance for the purpose of the performance of a contract concluded with the data subject and in relation to steps taken prior to entering into a contract, in order to uphold the overriding legitimate interests of AKB, on the grounds that processing is readily apparent under the circumstances or subject to prior notification.

AKB also processes personal data that it receives from third parties, that it obtains from publicly accessible sources or that it collects during the performance of its activities and operations, where and insofar as such processing is permitted by law.
 

AKB processes personal data relating to job applicants where this is necessary for assessing suitability for appointment or for the subsequent conclusion of an employment contract. The personal data required are obtained in particular from questionnaires requested, for example within the ambit of a job advert. AKB also processes any personal data that job applicants voluntarily disclose or publish, in particular within a covering letter, CV or other job application documents as well as in online profiles.

AKB may enable job applicants to lodge their details in a talent pool so that they can be considered for future vacancies. This information may also be used for maintaining contact and providing information concerning any new developments. Should AKB take the view that, on the basis of this information, a job applicant is a candidate for a vacancy, AKB may inform the job applicant accordingly.

AKB uses third-party services in order to advertise positions via e-recruitment and also to facilitate and manage the job application process.

Further information may be found in the Privacy Policy for Job Applicants and Employees.
 

AKB processes personal data as a general rule, in Switzerland and the European Economic Area (EEA). However, under exceptional circumstances your data may also be processed in the USA or in another country around the world. In the event that a processor third party is situated in a country without an adequate level of data protection under law, AKB undertakes to oblige it under contract in accordance with Article 16 DSG to ensure the applicable level of data protection, unless it is already subject to a framework for ensuring data protection recognised by law, you have granted your express consent as a data subject or there is a direct connection with the conclusion or performance of a contract.

Data subjects whose personal data are processed have rights under the Swiss Data Protection Act [Datenschutzgesetz] (DSG). These include a right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to object to processing and the right to data portability. As a data subject, you can also withdraw at any time any consent to the processing of personal data previously given to AKB, although a withdrawal of consent is only effective vis-a-vis future processing. In addition, you as a data subject have a right to lodge a complaint with the competent data protection supervisory authority.

Please contact the Data Protection Unit of AKB directly in order to exercise your rights against AKB under data protection law. The respective contact information may be found in Section 1 of this Policy. In order to exclude the possibility of abuse, the Bank needs to identify you (e.g. using a copy of an identity document, if this is not possible in any other manner). 
 

The AKB website can be accessed via transport encryption (SSL/TLS, in particular according to the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers flag transport encryption using a padlock symbol in the address bar.

As is the case for any form of digital communication, digital communications involving AKB are generally speaking subject to mass surveillance without any requirement of suspicion as well as other forms of monitoring by security services in Switzerland, elsewhere in Europe, the United States of America (USA) and other countries. AKB is unable to exert any direct influence on the respective processing of personal data by governmental agencies.
 

8.1 Cookies

Cookies are small text files that are stored on your computer’s browser, or your mobile device’s browser, whenever you visit the AKB website. They store particular settings within your browser and collect statistical information. Cookies have a number that is allocated to your browser in order to enable the information contained in it to be identified.

Most cookies used by AKB are temporary session cookies, which are automatically deleted after the end of the browser session. Permanent cookies remain stored on the device until you delete them or are automatically disabled upon expiry of the pre-set period. Permanent cookies are stored for a particular period of time. Cookies make it possible in particular to recognise a browser the next time the AKB website is visited, and thus for instance to measure the reach of the AKB website. However, permanent cookies can also be used for instance for online marketing.

Cookies can be disabled or deleted at any time, either entirely or in part, via the browser settings. It is possible that the website will no work properly if cookies are disabled. AKB will ask you to consent expressly to the disabling of cookies – at least where and insofar as necessary.

A general opt-out can be activated via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA) for numerous services that use cookies to measure success and reach, as well as for advertising.

8.2 Server log files

AKB may record the following information whenever its website is accessed, where it is transmitted by your browser to the AKB server infrastructure or can be identified by the AKB server: date and time including timezone, internet protocol address (IP address), access status (HTTP status code), operating system including user interface and Version, browser including language and version, individual subpages on the AKB website visited including the quantity of data transmitted, and finally any websites accessed via the same browser window (referrer).

AKB stores this information, which may also contain personal data, within server log files. The information is necessary in order to operate the AKB website in a reliable, user-friendly manner on an ongoing basis and to ensure data security, and thus in particular protection for personal data – including by or with the assistance of third parties.

8.3 Tracking pixels

AKB may use tracking pixels on its website. Tracking pixels are referred to as web beacons. Tracking pixels – including those of third parties the services of which AKB uses – are small, normally invisible images that are automatically retrieved whenever the AKB website is visited. Tracking pixels can record the same information as server log files.
 

AKB sends notifications and messages by email and through other communication channels, such as for instance instant messaging or SMS.

9.1 Success and reach measurement

Notifications and messages may contain links to websites or tracking pixels, which record whether an individual message has been opened and whether any links to websites contained within it have been clicked on. Any such links to websites and tracking pixels may also result in notifications and messages being recorded with reference to a specific individual. AKB needs to keep these statistical records concerning usage for the purpose of success and reach measurement so that it can send notifications and messages that are tailored to the needs and reading habits of recipients in an effective and user friendly manner and also securely and reliably on an ongoing basis.

9.2 Consent and objections

As a general rule, you need to expressly consent to the usage of your email address and any other contact addresses you have, unless such usage is permitted according to another legal basis. Where possible, AKB uses the “double opt-in” procedure for providing consent; this means that you will receive an email containing a link that you need to click on as confirmation, in order to avoid any misuse by unauthorised third parties. AKB is able to log any such consent granted, including the internet protocol address (IP address) along with the date and time as evidence and for security reasons.
As a general rule, you can opt out at any time from receiving notifications and messages, such as for instance newsletters. By opting out, you will also be deemed to have objected at the same time to the collection of statistical information relating to use for the purpose of success and reach measurement.
The above does not apply to any notifications and messages that are necessary in relation to the activities and operations of AKB.

9.3 Service providers for notifications and messages

AKB sends notifications and messages using specialist service providers.
AKB uses in particular:

• mailXpert: newsletter dispatch; provider: mailXpert GmbH (Switzerland); information concerning data protection: Privacy Policy, “Data Location Switzerland”

AKB is present on social media and other online platforms in order to communicate with any people with an interest and so that it can provide information concerning its activities and operations. Personal data may be processed also outside Switzerland and the European Economic Area (EEA) within the ambit of these platforms.

In each instance the general terms and conditions (GTC), the terms of use and the privacy policies and other provisions of the individual platform operators are also applicable. These terms and conditions provide information in particular concerning the rights that data subjects have directly against the respective platforms, including for instance the right of access.

AKB has the status of controller alongside Meta Platforms Ireland Limited (Ireland) for AKB’s social media presence on Facebook, including Page Insights. Meta Platforms Ireland Limited is one of the Meta Companies (which are based in the USA, amongst other countries). Page Insights provides information on how visitors interact with AKB's Facebook profile. AKB uses Page Insights to manage its social media profile on Facebook effectively and in a user-friendly manner.

Further information concerning the nature, scope and purpose of data processing, information concerning the rights of data subjects as well as contact details for Facebook, including the Facebook Data Protection Officer, may be found in Facebook’s Privacy Policy. 
 

AKB uses the services of specialist third parties in order to be able to conduct its activities and operations securely, reliably, in a user-friendly fashion and on an ongoing basis. These services enable, amongst other things, functions and content to be embedded within the AKB website. Where such services are embedded, due to mandatory technical reasons the services used record users’ IP addresses (IP addresses) at least temporarily.

The third parties whose services AKB uses may process data in relation to activities and operations in aggregated, anonymised or pseudonymised form for necessary system-relevant, statistical and technical purposes. These may include for instance performance or usage data in order to be able to offer the respective services. 

AKB uses in particular:

• Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; general information concerning data protection: “Privacy Principles”, Privacy Policy, “We are committed to complying with applicable data protection laws”, “Google Product Privacy Guide”, “How Google uses information from sites or apps that use our services” (information provided by Google), “How Google uses cookies and other technologies”, “Personalised ads” (turn on / turn off / settings)
• Microsoft services: Provider: Microsoft Corporation (USA) / Microsoft Corporation Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; general information concerning data protection: “Privacy at Microsoft”, “Privacy (Trust Center)”, Privacy Policy

11.1 Audio and video conferences

AKB uses specialist services for audio and video conferences in order to be able to communicate online. These enable for instance virtual meetings to be held. The legal texts applicable to the individual services, such as privacy policies and terms of usage, also apply in the event of participation in audio and video conferences.

Depending upon the user’s immediate surroundings, AKB recommends that the microphone be muted by default in the event of participation in audio or video conferences and that the background be blurred or a virtual background be set.

AKB uses in particular:

• Microsoft Teams: platform for, amongst other things, audio and video conferences; provider: Microsoft; information specific to Teams: “Privacy and Microsoft Teams”
• Webex: video conferences; provider: Cisco Systems Inc. (USA); information concerning data protection: “Cisco Online Privacy Statement”, “Compliance and certification for Cisco Webex”

11.2 Maps

AKB uses third-party services in order to be able to incorporate maps into the AKB website.

AKB uses in particular:

• Google Maps including the Google Maps platform: map service; provider: Google; information specific to Google Maps: “How Google uses location information”

11.3 Digital audio-video content

AKB uses the services of specialist third parties in order to enable audio and video content, such as for instance music or podcasts, to be played back directly.
AKB uses in particular:

• Podigee: Podcast hosting; provider: Podigee GmbH (Germany); information concerning data protection: Privacy Policy.
• YouTube: Video platform; provider: Google; information specific to YouTube: “Privacy and safety center”, “Your Data in YouTube”.
• Vimeo: provider: Vimeo; information concerning data protection: Privacy Policy

11.4 Fonts

AKB uses third-party services so that it can embed selected fonts such as icons, logos and symbols within its website.
AKB uses in particular:

• fonts.com: fonts; provider: Monotype Imaging Holdings Inc. (USA); information concerning data protection: “Your Privacy” (“Your Privacy”), Privacy Policy, “Web Font Tracking Privacy Policy”

11.5 Identity check

AKB uses third-party services in order to be able to check users’ identities. These services are required in particular for identity checks when accessing protected areas or for products in relation to which “Know Your Customer” (KYC) obligations apply.

11.6 Advertising

AKB takes advantage of the opportunity to display targeted advertising for its activities and operations on third-party websites, such as for instance social media platforms and search engines. 

In operating this advertising, AKB aims in particular to reach people who are already or may potentially be interested in its activities and operations (remarketing and targeting). For this purpose specific information – which may potentially contain personal data – is transmitted to the third parties that enable such advertising. In addition, AKB is able to establish whether its advertising has been successful, i.e. in particular whether it has generated visits to the AKB website (conversion tracking).

Third parties with which AKB places adverts, on whose systems you are logged in as a user, may potentially allocate your usage of the AKB website to your profile with that operator.

AKB uses in particular:

• Facebook Ads: social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta Companies (which are based in the USA, amongst other countries); information concerning data protection: remarketing and targeting, in particular using Facebook Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy, “Ad Preferences” (logging in as a user necessary)
• Google Ads: search engine advertising; provider: Google; information specific to Google Ads: advertising based amongst other things on search queries, with various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – being used for Google Ads, “Advertising” (Google), “Why this ad?”
• Instagram Ads: social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta Companies (which are based in the USA, amongst other countries); information concerning data protection: remarketing and targeting in particular using Facebook Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), “Ad Preferences” (Instagram) (logging in as a user necessary), “Ad Preferences” (Facebook) (logging in as a user necessary)
• LinkedIn Ads: social media advertising; provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); information concerning data protection: remarketing and targeting in particular using the LinkedIn Insight Tag, “Privacy”, Privacy Policy, Cookie Policy, opt out of personalised advertising
• Microsoft Advertising: search engine advertising with Bing, DuckDuckGo and Yahoo!; provider: Microsoft; information specific to Microsoft Advertising: “Microsoft Advertising Privacy Policy”, “Microsoft Advertising Policies: Legal, privacy and personalization”, “Ad settings” (opt out of personalised advertising)
• TikTok Ads: social media advertising; provider: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland / TikTok Inc. (USA) for users in the USA / TikTok Pte. Ltd. (Singapore) for users in the rest of the world; Privacy Policy, “Privacy Policy for Younger Users”, Cookie Policy, “TikTok for Business - Privacy and Cookie Policy”
   

AKB uses plugins for its website in order to be able to use additional functions, including in particular: 

12.1 Contact forms and counters

When using any AKB contact forms or calculators (mortgage calculator, savings calculator, budget calculator, pillar 3 savings calculator, pension calculator), as a general rule it is possible that your identification data (e.g. form of address, name), contact details (e.g. email, telephone number), financial circumstances (e.g. income) as well as the information entered by you may be transmitted to AKB, irrespective of the specific service used. AKB uses this information for the purpose of performance of a contract or in relation to steps taken prior to entering into a contract, for example in order to contact you, to deal with the specific issue raised by you or to inform you concerning particular products and services. Where technically possible, personal data are erased at regular intervals.

12.2 Surveys and competitions

You will be informed separately about how your personal data are processed in relation to surveys and competitions on the AKB website.
 

AKB uses services and programmes to establish how its online content is used. This may enable for instance the success and reach of its activities and operations to be measured as well as the efficacy of any third-party links to the AKB website. AKB can also for instance test and compare how different versions of its online content, or any parts thereof, are used (“A/B test” method). Success and reach measurement may enable in particular errors to be rectified, popular content to be enhanced or improvements to be made to AKB’s online content.

When using services or programs for measuring success and reach. it is necessary to store individual users’ internet protocol addresses (IP addresses). IP addresses are generally truncated (“IP masking”) in order to comply with the principle of data minimisation through the related pseudonymisation and thus to improve data protection for users.

When using services and programs for measuring success and reach, it is possible that cookies may be saved and user profiles created. User profiles record for instance the pages visited or the content viewed on the AKB website, information concerning the screen or browser window size as well as the – at least approximate – location. User profiles are created as a general rule exclusively in pseudonymised form. AKB does not exploit user profiles in order to identify individual users. Individual third-party services to which users have logged in may potentially allocate usage of the AKB online content to the user’s profile with the respective service.

AKB uses in particular:

• Google Analytics: success and reach measurement; provider: Google; information specific to Google Analytics: measurement also across different browsers and devices (cross-device tracking) as well as using pseudonymised internet protocol (IP) addresses, which are only transmitted in full to Google in the USA under exceptional circumstances, “Safeguarding your data”, “Google Analytics Opt-out Browser Add-on”
• Google Tag Manager: incorporation and management of other services for measuring success and reach along with additional services from Google and third parties; provider: Google; information specific to Google Tag Manager: “Data collected by Google Tag Manager”; further information concerning data protection can be obtained from the respective individual services embedded and managed.
   

AKB may amend this Privacy Policy at any time. The version published on this website is the relevant up-to-date version. Further information concerning the processing of your data can be found in the Privacy Policy.