PRIVACY STATEMENT
BHBAI appreciates your visit to this website and your interest in our association. Your privacy is of utmost importance to us. To understand how BHBAI processes your data, please read this Privacy Statement.
DATA PROTECTION UNDER THE SWISS DATA PROTECTION LAW
To manage our association, BHBAI processes information about natural and legal persons (“Data”), including information about our participants, employees, and business partners (“Parties”).
BHBAI takes your privacy seriously. This Privacy Notice (“Notice") contains information on what Data BHBAI collect(s), what we do with that information, and what rights you have.
As part of our commitment to protect your Data, we want to inform you in a transparent manner:
why and how BHBAI collects, uses, and stores your Data;
the lawful basis for the use of your Data; and
what your rights are in relation to such processing and how you can exercise them.
Table of Content
1. What does this Notice cover?
2. What types of Data do we collect?
3. For which purpose do we process your Data and what legal basis do we rely on?
4. How do we protect Data?
5. Who has access to Data and with whom are they shared?
6. How long do we store your data?
7. What are your rights and how can you exercise them?
8. Changes to your Data
9. Updates to this Notice
1. What does this Notice cover?
This Notice applies to any and all forms of use (“processing”) of Data by us.
2. What types of Data do we collect?
For prospective Parties with whom we have not yet made contact, we collect (to the extent permitted by applicable law):
personal identification details (such as name, address, gender, nationality), contact information (such as telephone, e-mail address);
information related to the professional profile (such as directorship / positions and professional networks) and information related to their employer and background.
For participants or prospective participants with whom we are taking steps to enter into a relationship, we collect (to the extent permitted by applicable law):
personal details such as your name, compliance related documents, phone number, address and domicile, electronic address, and employer details;
financial information, including payment and transaction records;
tax domicile and other tax-related documents and information;
where relevant, professional information about you, such as your job title and responsibilities;
your knowledge of and experience in AI matters;
details of our interactions with you and the services you use, including electronic interactions across various channels such as e-mails and mobile applications;
any records of phone calls between you and BHBAI, specifically phone log information such as your phone number, calling-party number, receiving-party number, forwarding numbers, time and date of calls and messages, duration of calls, routing information, and types of calls;
identifiers we assign to you, such as your employer, business relation, contract, partner or account number, including identifiers for accounting purposes;
when you access BHBAI websites or some of our applications, your activity in our products and services, data transmitted by your browser or device you are using and automatically recorded by our server, including date and time of the access, name of the accessed file as well as the transmitted data volume and the performance of the access, your device, your web browser, browser language and requesting domain, and IP address (additional data will only be recorded via our website if their disclosure is made voluntarily, e.g., in the course of a registration or request); and
in some cases (where permitted by law), special categories of Data, such as your business affiliations.
We may use cookies, tracking technologies and other means (e.g., web beacons, pixels, gifs, tags, unique identifiers) to collect and process the above information from different channels and devices you use, including email and devices that you use to interact with us to access BHBAI websites, BHBAI platforms, services and applications for mobile devices.
For our usage of cookies and other tracking technologies in relation to BHBAI websites, please also refer to the BHBAI Website Usage and Cookie Notice. We may use Data for analytics and measurement (incl. AI and machine learning) to process the above information, including profiling based on the processing of your Data, for instance by looking at information we obtain via cookies and tracking technologies. In some cases, we collect this information from public registers, public administration or other third-party or public sources, intermediaries that facilitate data portability, and other BHBAI-related entities.
If relevant to the services we provide to you, we will collect information about your employer. We may also collect information about your directors, representatives, employees, shareholders or beneficial owners. Before providing BHBAI with this information, you should inform those persons accordingly and provide a copy of this notice to them.
3. For which purposes do we process your Data and what legal basis do we rely on?
3.1 Purposes of processing
We always process your Data for a specific purpose and only process the Data which is relevant to achieve that purpose. In particular, we process Data, within applicable legal limitations, for the following purposes:
a) Participant Onboarding:
b) Relationship Management:
to manage our relationship with you, including communicating with you in relation to the services you obtain from us and from our business partners, handling member service-related queries and complaints;
to help us to learn more about you as a participant, your preferences on the services you receive, and other services, including those offered by us and our business partners you may be interested in receiving, including profiling based on the processing of your Data, for instance by looking at the types of applications, platforms, products and services that you use, information we obtain via tracking technology, and how you like to be contacted;
to collect and analyse your individualized and personal or anonymous and group-based activity and potential interests in the use of our services, of BHBAI websites, our applications for mobile devices and BHBAI platforms, multimedia portals and social networks.
c) Service implementation and execution:
to provide services to you and ensuring their proper execution;
to provide IT advisory to you and ensure their proper execution in accordance with your instructions and our contractual arrangements with you, for instance by providing incident management and testing directly connected to the provision of the service, or by supporting your controller obligations regarding Data storage, legal and regulatory compliance, audit activity and investigations;
d) Engaging in prospecting and business development and / or protecting and enhancing the BHBAI brand:
to evaluate whether and how BHBAI may offer services and events, including those offered by us and our other business partners that may be of interest to you;
to ensure individualized and personal or anonymous and group-based matching of offers on BHBAI websites, on our applications for mobile devices, on BHBAI platforms, on multimedia portals and social networks and other BHBAI products and services you may use;
to contact you about services we think will be of interest to you, including those offered by us and our business partners;
to create audiences on various digital platforms.
e) Compliance:
to carry out legal and regulatory compliance checks and periodic compliance checks, including to comply with anti-money laundering regulations, fraud prevention and financial crime prevention sanctions country screening. This involves profiling based on the processing of your Data, for instance by looking at how and from which geographic location you use applications, products and services from us.
to meet our on-going regulatory and compliance obligations (e.g., laws of the financial sector, antimoney laundering and tax laws), including in relation to recording and monitoring communications, disclosures to tax authorities, financial service regulators and other regulatory, judicial and governmental bodies. This involves profiling based on the processing of your Data, for instance by looking at how and from which geographic location you use applications and services from us;
to receive and handle complaints, requests or reports from you or third parties made to designated units within BHBAI;
to reply to any actual or potential proceedings, requests or the inquiries of a public or judicial authority.
f) Supporting, Enhancing and Maintaining BHBAI's technology:
to take steps to improve our services and our use of technology, including testing and upgrading of systems and processes, and conducting market research to understand how to improve of our services or learn about other services we can provide;
to analyze the results of our activities to measure their effectiveness and relevance of our services.
g) Other purposes:
for the BHBAI's prudent operational management (including technological support services, reporting, audit, systems and training and administrative purposes);
to collect data to ensure the security of buildings, the safety of staff and visitors, as well as property and information located, stored on or accessible from the premises, to prevent, and if necessary, investigate unauthorized access to secure premises (e.g., maintaining building access logs and CCTV system images to prevent, detect and investigate a theft of equipment or asset owned by BHBAI, visitor or staff, or threats to the safety of personnel working at our place of business);
to undertake transactional and statistical analysis, and related research; or to exercise our duties and/or rights vis-à-vis you or third parties.
3.2 Basis for processing of Data
BHBAI processes your Data within the applicable legal framework. Where required and depending on the purpose of the processing activity (see Section 3.1), the processing of your Data will be one of the following grounds:
necessary for taking steps to enter into or executing a contract with you for the services you request, or for carrying out our obligations under such a contract, such as when we use your data for some of the purposes in Section 3.1 a) and c) above, as well as certain data disclosures described in Section 5 below;
required to meet our legal or regulatory responsibilities, including when we conduct the legal and regulatory compliance checks, such as when we use your data for some of the purposes in Section 3.1 e) and g) above, and make the disclosures to authorities, regulators and government bodies referred to in Section 5 below;
necessary for the legitimate interests of BHBAI, without unduly affecting your interests or fundamental rights and freedoms and to the extent such Data is necessary for the intended purpose (such as when we use your data for some of the purposes in Section 3.1 a), b), d), e), f) and g). See below for more examples of legitimate interests of BHBAI);
in some cases, we have obtained your consent (for instance where required by law) or processed, where required under applicable laws or regulations, with your explicit consent in the case of special categories of Data; or
in some cases, necessary for the performance of a task carried out in the public interest.
A legitimate interest of BHBAI is in particular considered in the following instances. The processing is necessary to:
manage our relationship with you and to help us to learn more about you as a participant, the services you receive, and other services you may be interested in receiving (see Section 3.1 b) above);
evaluate whether and how BHBAI may offer services and events that may be of interest to you (see Section 3.1 d) above;
prevent fraud or criminal activity, misuses of our services as well as the security of our information, IT systems, architecture and networks and security of BHBAI premises (see Section 3.1 e) and g) above);
receive and handle complaints, requests or reports from you or third parties made to designated units within BHBAI (see Section 3.1 e) above);
take steps to improve our services and our use of technology and to conduct market research (see Section 3.1 f) above);
cooperate with a request made in any actual or potential proceedings or the inquiries of a public or judicial authority (see Section 3.1 e) above);
exercise our rights under Articles 26 and 27 of the Federal Constitution of the Swiss Confederation, including our freedom to operate an asssociation and right to property;
meet our accountability for prudent operational management (see section 3.1 g) above) and regulatory requirements around the world; and certain situations when we make the disclosures referred to in Section 5 below, providing products and services and assuring a consistently high service standard across BHBAI, and keeping our participants, employees and other stakeholders satisfied.
To the extent BHBAI has obtained your consent to process ordinary Data in the past in any service-specific terms and conditions for the purposes of data protection law only, BHBAI will no longer rely on such consent, but instead will rely on lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests (as specified in this Notice), and BHBAI's ability to rely on that consent is hereby waived.
For the avoidance of doubt, any consent given for any other reason, for instance (and if applicable) e-Privacy (including direct marketing) and decisions based solely on automated processing remains unaffected by this paragraph.
Where the Data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this Data, there is a possibility we may be unable to onboard you as a participant or provide services to you (in which case we will inform you accordingly).
To the extent that we process any special categories of data relating to you, we will do so because:
the processing is necessary for the establishment, exercise or defense of a legal claim;
the processing relates to data which are manifestly made public by you; or
you have given your explicit consent to us to process that information (where legally permissible).
4 How do we protect Data?
All BHBAI employees accessing Data must comply with our internal rules and processes in relation to the processing of your Data to protect them and ensure their confidentiality. BHBAI has also implemented adequate technical and organisational measures to protect your Data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing.
5 Who has access to Data and with whom are they shared?
5.1 Within BHBAI we usually share Data for the purposes indicated in Section 3.1, to ensure a consistently high service standard, and to provide services to you. Other entities related to BHBAI may process your Data on behalf and upon request of BHBAI.
5.2 Outside BHBAI
5.2.1 Third Parties
We transfer Data to business partners and to our professional advisers and consultants to perform the business relationship with you. In particular, when providing services to you, we will share Data with persons acting on your behalf or otherwise involved (depending on the type of service you receive from us), including, where relevant the following types of entities:
a party in connection with the service (such as an IT service provider);
associations and other networks of which BHBAI is a member;
participants;
Financial institutions;
any third-party IT manager who provides services to you;
any introducing party to whom we provide introductions or referrals, and
lawyers, auditors, accountants, and consultants.
5.2.2 Service Providers
In some instances, we also share Data with our suppliers, who are contractually bound to confidentiality, such as IT hardware, software and outsourcing providers, logistics, mail, courier, printing services and storage providers, marketing and communication providers, facility management companies, market data service providers, transportation and travel management providers and others. When we do so we take steps to ensure they meet our data security standards, so that your Data remains secure.
Where BHBAI transfers your data to service providers processing data on BHBAI’s behalf, we take steps to ensure they meet our data security standards, so that your Data remains secure. Service providers are thereby mandated to comply with a list of technical and organizational security measures, irrespective of their location, including measures relating to: (i) information security management; (ii) information security risk assessment and (iii) information security measures (e.g., physical controls; logical access controls; malware and hacking protection; data encryption measures; backup and recovery management measures).
5.2.3 Public or regulatory authorities
If required from time to time, we disclose Data to public authorities, regulators or governmental bodies, courts or party to proceedings, where we are required to disclose information by applicable law or regulation, under a code of practice or conduct, at their request, or to safeguard our legitimate interests.
5.2.4 Others
We may need to disclose Data to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.
5.3 Data transfers to other countries
The Data transferred within or outside BHBAI is in some cases also processed in other countries. We only transfer your Data abroad to countries which are considered to provide an adequate level of data protection, or in the absence of such legislation that guarantees adequate protection, based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission or another statutory exemption) provided by local applicable law. A copy of these measures can be obtained by contacting the Data Protection Officer.
If and to the extent required by applicable law, we implement the necessary legal, operational and technical measure and/or enter into an agreement with you before such transfers.
6. How long do we store your data?
We will only retain Data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your Data depending on its purpose. In general, although there may be limited exceptions, data is kept for the time period defined in the BHBAI Records Management Policy.
As far as necessary, we will keep your data for the duration of our relationship subject to applicable legal and regulatory requirements. In addition, we might process your Data after the termination of our relationship for compliance in accordance with the applicable laws as well as pursuant to various retention and documentation obligations or if it is in BHBAI’s legitimate interest. In general, BHBAI will retain data for the period of the relationship or contract with BHBAI plus 10 years, reflecting the length of time for which legal claims may be made following the termination of such relationships or contract. If you wish to have your Data removed from our databases, you can make a request as described in Section 7 below, which we will review as set out therein.
7 What are your rights and how can you exercise them?
7.1 Your rights
You have a right to access and to obtain information regarding your Data that we process. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction of your Data.
You also have the right to:
object to the processing of your Personal Data;
request the erasure of your Personal Data;
request restriction on the processing of your Personal Data; and/or
withdraw your consent where BHBAI obtained your consent to process Personal Data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).
When Data is processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketing by clicking the "unsubscribe" link in any of our e-mails to you, or by emailing us at the addressed indicated in Section 7.2 at any time.
Where we process your Data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to request your Data be transferred to you (known as the ‘data portability’ right). You also have the right to ask BHBAI for information regarding some or all of the Data we collect and process about you. BHBAI will honor such requests, withdrawal or objection as required under applicable data protection rules but these rights are not absolute: they do not always apply, and exemptions may be engaged. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to understand your request better. If we do not comply with your request, we will explain why. In certain circumstances BHBAI may process your Data through automated decision-making. Where this takes place, you will be informed of such automated decision-making that uses your Data and be given information on criteria and procedures applied. You can request an explanation about automated decision making carried out and that a natural person reviews the related decision where such a decision is exclusively based on such processing.
7.2 Exercising your rights
Should you have a request regarding the processing of your data, or to exercise your rights, please contact:
Karl Beck
BHBAI Data Protection Officer
karlbeck@bhbai.com
BHBAI
Hardstr. 201
8005 Zürich
Switzerland
Our office at Hagenholzstrasse 81, 8050 Zürich will be opening soon.
8. Changes to your Data
We are committed to keeping your Data accurate and up to date. Therefore, if your Data changes, please inform us of the change as soon as possible.
9. Updates to this Notice
This Notice was updated in July 2025. We reserve the right to amend it from time to time. Any amendment or update to this Notice we will make available to you here. Please visit the BHBAI website frequently to understand the current Notice, as the terms of this Notice are closely related to you.
