Data protection notice

Data protection policy for the processing of personal data in connection with the MyBestFX service

The Data Controller is Union of Financial Corners (Switzerland) SA, located at Rue de Mont-Blanc 11, 1201 Geneva, Switzerland (hereinafter “UFC” or “we”). The protection of your Personal Data is essential. We will process your Personal Data in accordance with the Federal Data Protection Act of September 25, 2020 (hereinafter “DPA”) and its implementing regulations and ordinances.

The term “Personal Data” refers to all information concerning an identified or identifiable natural person. The term “Processing” refers to any operation relating to Personal Data, regardless of the means and procedures used, in particular the collection, recording, storage, use, modification, communication, archiving, deletion or destruction of data.


The term “User” or “you” refers to any person who creates a User Account and uses our Platform and its services. In accordance with the DPA, you are considered a “Data Subject” if you are an identifiable natural person, directly or indirectly, whose Personal Data is processed when using the Platform. All natural persons creating a User Account are automatically considered Data Subjects. On the other hand, legal entities, such as companies, are not considered Data Subjects, and their data is not processed as Personal Data.

This Data Protection Policy (hereinafter “Policy”) explains in simplified terms how your personal data will be processed when using the MyBestFX Platform (hereinafter “Platform”).

Types of personal data collected and processing principles 

The personal data we collect and process in order to register and open a User Account are surname, first name, e-mail address and telephone number. This registration enables you to use the Fix & Collect service. The collection and processing of your Personal Data when you open a User Account is based on the performance of the contract between us under the Platform Terms of Use. 

This data will be processed in order to enable the use of the Platform and the provision of the associated services. The personal data we collect and process to complete the User profile once you have registered are as follows: date of birth, nationality, address, profession, estimated annual income and amounts to be exchanged via the Platform, reason for transactions and origin of funds, identification documents and other information necessary to ensure our compliance with money laundering regulations. The profile thus completed enables you to use the Online Exchange service.

The collection and processing of your Personal Data to complete the User profile is based on our legal and regulatory obligations, in particular those relating to the fight against money laundering and the financing of terrorism (AMLA regulations). This data will be processed to enable the use of the Platform and the provision of the Change online services. 

We may communicate with you about the Platform and its services, including for marketing purposes and to conduct surveys. The purpose of our communications will be to provide you with information about our services or other services offered by our Affiliates. Communications concerning other services, including for marketing and survey purposes, are based on our legitimate interest in conducting our business. Our legitimate interest also justifies the transfer of your Personal Data to our Affiliates. The purpose of this transfer is to process the data in order to improve our services, as well as for statistical, research and development purposes. It also contributes to the protection and defense of our rights, property and safety, as well as those of our customers and other Platform Users.

The processing of your data to send you commercial information about our Partners' offers and products is based on your consent, which you give by agreeing to open a User Account. You may withdraw this consent at any time. If you withdraw your consent, we may retain certain data (such as your e-mail address) to record and respect your choice to no longer receive commercial communications about our Partners' services. We will not transfer your Personal Data to third parties or to our Partners without your explicit consent. 

We may use your Personal Data to communicate with you after you have unsubscribed from the Platform and up to the point at which you object to the sending of such messages. You will have the opportunity to object to such processing before unsubscribing. 

We may process Personal Data collected for any other purpose compatible with the purposes set out above. For example, we may use Personal Data for archiving and statistical purposes relating primarily to the use of the services.  

In addition, we may process Personal Data collected in order to ensure the compliance of our activities with the regulations in force in Switzerland, in particular the laws and regulations relating to the fight against money laundering and the financing of terrorism (AMLA regulations).

You may provide personal data when using other services or when contacting us, for example when subscribing to our newsletter. These databases are managed independently, so unsubscribing from the Platform will not automatically apply to these other services. Please take the time to indicate your consent or opposition to the processing of your data for each service. 

The Platform is not intended for persons under the age of 16. If you are under the age of 16, you must obtain permission from your parents or guardian before providing us with your Personal Data and using the Platform.  

Retention period 

We will only retain Personal Data for as long as is necessary for the purposes described in the section above “Types of Personal Data collected and Processing principles”. We may retain Personal Data collected after you have unsubscribed where you have given your consent or to the extent necessary to achieve a purpose compatible with the aforementioned purposes. More specifically: 

- Personal Data collected when using the Platform is used to manage our contractual relationship and to provide you with access to the Platform's features and services. Your Personal Data will be deleted after you unsubscribe, unless you give us permission to use it for marketing communications. In this case, we and our Affiliates will continue to use this data to communicate with you, even after you have unsubscribed from the Platform. 

- Personal Data processed for the purpose of sending you marketing communications about our Partners' offers will be retained until you withdraw your consent. Certain data, such as your e-mail address, may be saved in order to respect your choice to no longer receive such communications. 

- Personal Data collected in order to ensure the compliance of our activities with the regulations in force in Switzerland, in particular those relating to the fight against money laundering, will be kept for up to ten years after the termination of the business relationship or after the conclusion of the transaction. 

 - Personal Data that you transmit by e-mail, via a contact form, or by post will be kept for the time necessary to respond to your requests, depending on their nature.


Third-party access to data 

Third-party IT service providers may have access to some of your personal data. These service providers mainly assist us in the maintenance and support of our IT systems, the hosting of databases or the distribution of marketing communications. These databases are stored on servers located in Switzerland.

We may need to disclose and/or transfer your Personal Data if required to do so by applicable law, to comply with legal process, a court order, a legal obligation, or as part of an investigation by a public or judicial authority, or to protect and defend our rights.

Transmission outside Switzerland and the EEA

Personal Data is hosted on servers located in Switzerland. It will not be transferred outside Switzerland.

 Your rights regarding your personal data 

You have the following rights concerning your personal data: 

- Right of access: upon request and subject to the conditions and limits determined by applicable law, we will provide you with a copy of the Personal Data we hold about you. 

- Right of rectification/erasure: upon request, we will rectify or erase any of your Personal Data that is inaccurate or incomplete. We recommend that you regularly update your Personal Data stored on the Platform.

- Right to object to processing: upon request and subject to conditions and limits determined by applicable law, we will restrict/limit the processing of your Personal Data or delete your data. 

- Right to withdraw consent: you have the right at any time to withdraw any consent given for the processing of your Personal Data. Processing carried out prior to your withdrawal remains lawful. 

We encourage you to contact us with any questions or requests relating to the above rights via the address: support@mybestfx.ch. We will contact you as soon as possible. 

Modifications

We reserve the right to modify this Data Protection Policy at any time in order to adapt it to technical or legal developments or when introducing new features and services. The applicable Data Protection Policy is that in force at the time of connection to and use of the Platform by the User.