This Cookie Policy explains how Swiss RepLink SA, a company incorporated under the laws of Switzerland with its registered office at 2 rue Saint-Léger, 1205 Geneva (“we”, “us”, or “our”), uses cookies and similar technologies on the website www.swissreplink.ch (the “Website”).

This Cookie Policy is intended to comply with the Swiss Federal Act on Data Protection of 25 September 2020 (“FADP”), as revised and in force since 1 September 2023, its implementing ordinances, and applicable guidance of the Swiss Federal Data Protection and Information Commissioner (FDPIC). As a regulated financial institution, we also take into account applicable requirements and supervisory expectations of the Swiss Financial Market Supervisory Authority (FINMA), in particular with respect to data security, outsourcing, and operational risks.

1. What are cookies?

Cookies are small text files that are stored on your device (computer, tablet, smartphone) when you visit a website. Cookies allow a website to recognize your device and store certain information about your preferences or past actions.
Cookies may be:

• Session cookies, which are deleted when you close your browser; or
• Persistent cookies, which remain on your device for a specified period or until deleted.

2. Types of cookies we use

In line with FINMA supervisory expectations, we follow a data-minimisation approach and limit the use of cookies to what is necessary for secure operations, regulatory compliance, and clearly defined purposes.

2.1 Strictly necessary cookies

These cookies are essential for the operation and security of the Website and cannot be disabled in our systems. They are usually set in response to actions made by you, such as setting privacy preferences, logging in, or filling in forms.
Legal basis: Our legitimate interest in providing a functional and secure website (Art. 31 FADP).

2.2 Functional cookies

These cookies enable the Website to provide enhanced functionality and personalization, such as remembering your language preferences or region.
Legal basis: Your consent, where required, or our legitimate interest, depending on the cookie and its purpose.

2.3 Performance and analytics cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. We use analytics tools in a configuration that, where possible, avoids or reduces the processing of personal data (e.g. IP anonymisation, aggregation, limited retention periods).
Analytics data is generally aggregated and does not directly identify you.
Legal basis: Your consent, where required. Where analytics are strictly necessary for security, stability, or fraud-prevention purposes, our overriding legitimate interest may apply (Art. 31 FADP).

2.4 Marketing and third-party cookies

As a FINMA-regulated entity, we either do not use marketing and profiling cookies or use them only in a very limited manner. Where such cookies are used, they are not essential for the operation of the Website and are activated only with your explicit consent.
Legal basis: Your explicit consent.

3. Third-party cookies

Some cookies are placed by third parties that provide services on our behalf, such as analytics providers, hosting providers, or social media platforms.
Any third parties engaged in connection with cookies are carefully selected and contractually bound by data protection and confidentiality obligations. Where relevant, such arrangements may qualify as outsourcing under applicable FINMA regulations and are governed accordingly.

4. Consent and cookie management

When you first visit our Website, you may be presented with a cookie banner or consent management tool that allows you to accept or reject certain categories of cookies.
You can withdraw or modify your consent at any time by:

• Adjusting your cookie preferences via the “Manage Consent” button located at the bottom right of the screen (on desktop devices), or
• Changing your browser settings (see section 5 below).

Please note that disabling certain cookies may affect the functionality of the Website.

5. Managing cookies via your browser

Most web browsers allow you to control cookies through their settings. You can:

• Delete existing cookies;
• Block all or certain cookies; or
• Set your browser to notify you before cookies are stored.

Instructions for managing cookies can usually be found in the help section of your browser.

6. Data protection, confidentiality, and security

To the extent cookies process personal data, such processing is governed by our Privacy Policy.
We implement appropriate technical and organisational measures to ensure data security and confidentiality, taking into account regulatory requirements applicable to FINMA-regulated institutions (including information security, access controls, and auditability).
Under the FADP, you may have rights such as the right to access, rectification, deletion, and objection, subject to applicable legal and regulatory requirements.

7. Changes to this Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in technology, law, or our practices. The updated version will be published on this page with a revised “Last updated” date.