Data protection policy

Data protection policy

This data protection policy (the “Data Protection Policy”) informs you about the processing of your personal data during your visits to the websites “hublemania.ch”, “votre-prevoyance.ch” and “clm4pension.jcloud.ik-server.com” and the latter’s aliases “clm.hublemania.ch” (hereinafter the “Site”) carried out by the Fondation Lemania de Libre Passage (the “FLLP” or “we”), having its registered office at rue de la Muse 2, 1205 Geneva in accordance with the laws in force in Switzerland, in particular the Federal Act on Data Protection (the “FADP”), as well as with this Data Protection Policy

This Data Protection Policy may be modified or supplemented at any time; users of the Site (the “Users”) are therefore required to consult it regularly.

If you have any questions or complaints, please contact us by email at the following address: data@fllp.ch.

  1. Personal data collected

We collect and process your personal data as well as the data relating to your occupational or individual pension plan that you provide to us when you contact us via the online contact form, during the digital onboarding process or during any other communication with us via the Site, in particular: your surname, first name, gender, date of birth, nationality(ies), AHV number, address, telephone number, marital status as well as the date of marriage if married, email, capacity and experience in the field of finance, and bank account details.

In addition, when you visit the Site, personal data such as the IP address of the electronic device from which you are visiting the Site and the geographic location indicated by the device, the date and time, the type and version of your browser and operating system, the URL of the site you previously visited and your preferences may be collected.

  1. Purpose of the treatment

Your personal data may be processed in particular for the following purposes:

  • Contact you and identify yourself;
  • To satisfy your requests, to optimize the organization of your occupational and individual pension plan, to ensure the follow-up of our relationship with you;
  • To analyze and improve the use of the Site and its functionality;
  • To send newsletters and offers related to our marketing activity (unless otherwise agreed);
  • To meet our legal obligations and to comply with any request from an authority or court or to pursue legal claims in the event of litigation.


  1. Cookies, tracers and analysis tools

The Site may use “cookies” and other similar tools to identify your browser or device and collect personal data (see section 1 above). A cookie is a small data file stored on your electronic device, through your browser when visiting the Site, which collects information such as your IP address, pages viewed and use of the site, date and time, location, etc. There are different types of cookies: those that are used only during a session and are deleted after your visit to the Site (session cookies) and cookies that save the settings you choose and other information for a period of time (permanent cookies). Permanent cookies are cookies that are stored on your computer and are not deleted automatically when you exit your browser, unlike a session cookie, which is deleted when you exit your browser. In general, you can set your browser to refuse cookies, save them only for a session, or delete them. Please note that by disabling cookies, some features of the Site may not work.

In particular, the Site may use analytical cookies via Google Analytics, which is a service provided by Google Inc. with headquarters in the United States of America. Google Analytics is a tool that analyzes the use of the Site. This tool can use cookies to collect anonymous information and generate reports in the statistics of use of the Site without the User being personally identifiable by Google. The information generated by these cookies (including the User’s IP address) may be sent to and stored on Google servers in the United States of America. If the User does not want Google Analytics to record data about the User’s visit, the User can install a browser add-on to disable Google Analytics.

In our newsletters and other electronic marketing e-mails, we may include, within the permitted limits, tracers that allow us to determine whether and when you have opened the e-mail. You have the option of blocking this process in your email program.

Finally, the Site may include social plugins for various social networking sites, such as LinkedIn (LinkedIn Corporation). When the User visits our Site, his browser connects directly to the servers of the corresponding social networks. The social networks may link your visit to our Site to a User account. For more information on the purpose and scope of data collection and data processing by the respective social network, as well as the User’s rights and means of protecting the User’s privacy, please consult the social network’s privacy policy.

  1. Transmission to third parties

Your personal data will be passed on to third parties if this is necessary for the performance of the requested services, to carry out the tasks required for our business, to meet our legal obligations, if there is a legitimate interest or if you have expressly consented to this. In particular, your personal data may be passed on to our contractual partners in the context of the requested services and for the purpose of promoting our services, in particular banks and insurance companies, or to our subcontractors and auxiliaries, such as our IT service providers for the hosting and maintenance of our IT system.

  1. Transmission abroad

The majority of the recipients of your personal data are located in Switzerland, but it is possible that under certain circumstances your data may be transferred abroad. If recipients are located abroad, we will ensure that the data is transferred to a country offering an adequate level of protection or, if not, that the transfer is governed by the relevant contracts in accordance with Swiss law.

  1. Conservation

We process and store your personal data for as long as it is necessary for the fulfilment of our contractual and legal obligations or for the purposes pursued by the processing (see above section 2). We may retain personal data for the period during which claims can be made against us and because we are obliged to do so by law or by legitimate interests (e.g. for evidential or documentation purposes).

  1. Security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access or misuse, such as computer and network security solutions and encryption of data carriers.

  1. Your rights

You have a right of access in accordance with Article 8 FADP, a right of rectification in accordance with Article 5 FADP, a right to erasure in accordance with Article 5 FADP, a right to limitation of processing in accordance with Articles 12, 13, 15 FADP and a right of objection in accordance with Article 4 FADP.

You can access your data at the following address: https://www.votrehttps://www.hublemania.ch/acces-donnees/

You may withdraw the consent you have given us to process your personal data at any time. Please note that withdrawing consent applies only for the future and may prevent you from accessing certain parts of the Site or certain features. If you object to the processing of your personal data, we will no longer process it unless there are legal obligations or legitimate interests in favour of processing it that override your right.