TWINT AG (TWINT) is the operator of the TWINT ID in-app solution and shall therefore be responsible for the collection, processing and use of your personal data as well as for the compliance of data processing operations with the applicable data protection law. TWINT ID is a TWINT service that is independent of the bank that issues your TWINT app (issuer bank). The issuer bank is not responsible for data processing. It has no influence on data processing and no access to your personal data, which is recorded and processed within the TWINT ID function.

Please take note of the following information to find out what personal data we collect from you and for what purposes we use this information.

Information on the processing of your personal data during the general use of TWINT can be found in the Data Privacy Statement of your TWINT app.

1. Scope and purpose of the collection, processing and use of personal data

a. Creating a TWINT ID account

To be able to use TWINT ID, you must register for TWINT ID in the area for which TWINT is responsible. We collect the following personal data for this purpose:

• First name
• Last name
• Street and house number
• Postcode and town/city
• Date of birth
• Telephone number
• E-mail address

If you do not provide us with this information, you will not be able to use TWINT ID. We only use this data to allow you to use TWINT ID. You can delete your TWINT ID account at any time by contacting us (see Section 8 below) or by deleting the TWINT ID account directly in the TWINT ID function.

b. Use of TWINT ID

You can use your TWINT ID, for example, to simplify the checkout process or the verification of your identification with various service providers. Depending on the service provider or the service you receive from the service provider, different data from your TWINT ID may be processed and transmitted to the selected service provider. The following personal data may be transmitted to the selected service provider:

•  First name
• Last name
• Street and house number
• Postcode and town/city
• Date of birth
• Telephone number
• E-mail address

Additional information (e.g. your vehicle’s licence plate number)
If, in individual cases, some of the mandatory information required for the use of TWINT ID is not available in connection with the selected service provider, this data can be subsequently entered by you and saved in TWINT ID. If, in individual cases, all or some of the mandatory information is missing, TWINT ID cannot be used in connection with the service provider concerned until all of the mandatory information has been recorded. You can voluntarily disclose further (i.e. non-mandatory) information to the selected service provider. Subject to your separate consent, the personal data shall be transmitted to the selected service provider as part of the requested service.

The data shall not be transmitted to third parties without your prior consent or, where necessary, the addition of the mandatory personal data

c. Contact by telephone or e-mail

You may contact us by telephone or e-mail and ask us questions about the TWINT ID functions and services.

We shall only collect the personal data that you disclose to us. Consequently, you shall be responsible for the content of your message as well as for deciding what information you send us. We recommend that you do not transmit any sensitive information. To ensure that we are able to answer your questions, we may ask you to provide us with additional information (e.g. your address or e-mail address). We shall only collect the personal data that is necessary to answer your questions or to provide the services you have requested.

d. Optimisation of TWINT ID

Only the data required for the performance of TWINT ID services shall be collected. This data allows TWINT to optimise TWINT ID and adapt it as well as possible to the needs of users. Specifically, the service provider with which a user uses TWINT ID shall be recorded and analysed.

2. Centralised storage and linking of data

We shall store your personal data on secure servers in Switzerland or in the European Union.

3. Disclosure of data to third parties

We shall only disclose your personal data if you have expressly consented to this (e.g. for the transfer of data to a service provider), if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the relationship between you and TWINT.

Furthermore, we shall only disclose your data to third parties insofar as this is necessary for the provision of the services requested by you and the analysis of your user behaviour in the context of the use of TWINT ID. The use of the data disclosed for this purpose by third parties shall be strictly limited to the stated purposes.

4. Transmission of personal data abroad

TWINT shall never disclose personal data that you have entered in TWINT ID to third parties outside of the use of TWINT ID. The only exception shall be the transfer of data-to-data processors who process certain data on behalf of TWINT so that TWINT can ensure the provision of the service. These data processors are obliged to comply with data protection laws to the same extent as TWINT. If the level of data protection in a country does not correspond to the Swiss level of data protection, TWINT shall contractually ensure that the level of protection provided to your personal data corresponds to the level provided in Switzerland at all times.

5. Data security

We shall use suitable technical and organisational security measures to protect the personal data you saved with us against manipulation, partial or complete loss and unauthorised access by third parties. Our security measures are constantly being updated and improved in line with technological developments. We also take internal data protection very seriously. Our employees and the service providers commissioned by us have been obliged by us to maintain confidentiality and to comply with data protection provisions.

6. Your rights

You have the following rights:

Right to information: You have the right to request access to your personal data stored by us at any time and free of charge when we are processing it. This gives you the opportunity to check what personal data pertaining to you we are processing and to ensure that we are using it in accordance with applicable data protection regulations.

Right to rectification: You have the right to have incorrect or incomplete personal data rectified and to be notified of the rectification. In this case, we shall inform any potential recipients of the data concerned of the amendments made, unless this is impossible or involves disproportionate effort.

Right to erasure: You have the right to have your personal data deleted under certain circumstances. In individual cases, the right to erasure may be excluded.

Right to restrict processing: Under certain circumstances, you have the right to request that the processing of your personal data be restricted.

Right to data transmission: Under certain circumstances, you have the right to obtain from us free of charge in a machine-readable format the personal data you have provided to us.

Right of appeal: You have the right to file a complaint with a responsible supervisory authority about the way in which your personal data is processed.

Right of revocation: You have the right to revoke your consent at any time with effect for the future. Processing activities performed in the past based on your consent do not become unlawful as a result of your revocation. Revocation of consent may result in the discontinuation of the TWINT service.

7. Storage of data

We shall only save personal data for as long as is necessary to provide you with services that you have requested or for purposes for which you have given your consent.

All the data collected by TWINT within the scope of TWINT ID shall be deleted or anonymised as soon as it is no longer required and/or (where applicable) the statutory retention period has expired. If you do not use TWINT ID for a period of 2 years, we shall assume that you have deleted the TWINT app and shall delete all your data that no longer has to be stored by law. We shall store contract data for longer as this is stipulated by statutory retention obligations. This data shall be blocked if we no longer require it for the purpose of providing services to you. This means that the data may only be used for the purposes provided for by law.

8. Contact

Should you have any questions about data protection at TWINT ID, you want to receive information, or you want to request the deletion of your data, please send an e-mail to [email protected].

Please send any letters to the following address:

TWINT AG
Stauffacherstrasse 41
CH-8004 Zurich