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Privacy Policy

  1. General and scope

This Privacy Policy (the ‘Policy’) describes how Elite Office SA, with registered office at 66, avenue de la Gare, 1920 Martigny (‘Elite Office’) processes the Personal Data (as defined below) of members and other beneficiaries of the occupational benefits institutions managed by Elite Office (the ‘Foundations’), its directors, suppliers and business partners, and/or any other natural person with whom Elite Office comes into contact or whose Personal Data is provided to it by one of the aforementioned persons (collectively, the ‘Data Subjects’).

 

Members and other beneficiaries of the Foundations may access the Privacy Policy of the relevant Foundation(s) via the following links:

 

 

Data Subjects who provide Elite Office Personal Data pertaining to a relative or a third party must communicate this Policy to the latter.

 

Elite Office attaches the utmost importance to the protection of Personal Data. This Policy explains what Personal Data Elite Office processes as Controller, and how it uses, and with whom it shares, your Personal Data.

 

Changes in legislation and our internal processes may require occasional amendments to this Policy. We therefore reserve the right to amend this Policy as required.

 

  1. What Personal Data is processed by Elite Office?

‘Personal Data’ within the meaning of this Policy includes any information relating to an identified or identifiable (e.g. name or social security number) natural person.

 

The Personal Data of Data Subjects that may be processed by Elite Office include, in particular, the information listed in Annex 1.

 

  1. For what purposes does Elite Office process Personal Data?

Elite Office processes Personal Data for the following purposes in particular:

 

  1. Compliance with legal requirements 

Elite Office may process Personal Data to ensure compliance with its statutory or regulatory obligations, including:

 

  • compliance with statutory requirements pertaining to occupational benefits and vested benefits;
  • co-operation in all forms with competent authorities, and the tax authorities in particular.

 

  1. Compliance with its contractual obligations

Elite Office may process Personal Data to ensure compliance with its statutory or regulatory obligations, including:

 

  • compliance with the agreement concluded with Data Subjects or their employers in the interest of the Data Subjects;
  • all transactions for the account of the Foundations, in particular relating to their administrative, technical and accounting management;
  • managing business relations and the related communications with the Foundations; and
  • sending administrative information, such as updates to this Policy.

 

  1. The pursuit by Elite Office of its legitimate interests

Elite Office may process Personal Data relating to the pursuit of its legitimate intetrests, including:

  • developing its contractual relations with the Foundations;
  • improving the internal organisation and operational activities of Elite Office;
  • managing the IT environment of Elite Office;
  • ensuring the security of Elite Office's IT systems and premises; and
  • enabling Elite Office to establish or assert a claim, to defend itself against a current, potential or future claim, or to respond to an investigation by a public authority in Switzerland or abroad.

 

  1. Consent of the Data Subject 

If Elite Office needs to process Personal Data for purposes other than those listed above, it shall inform the Data Subject, requesting their consent where required.

 

The Data Subject acknowledges that, to the extent they have authorised Elite Office to process their Personal Data for certain purposes, the processing in question is lawful based on their consent. The Data Subject may revoke such consent at any time. However, the consent remains valid for any processing of Personal Data carried out before the consent was revoked.

 

Moreover, revoking consent may prevent Elite Office from providing certain services to the Data Subject.


 

 

  1. Does Elite Office undertake profiling or automated decision-making?

Elite Office does not carry out automated processing of Personal Data for the purpose of evaluating the characteristics of Data Subjects (profiling[A1]).

 

  1. Does Elite Office communicate Personal Data to third parties?

Elite Office reserves the right to communicate or make Personal Data available to:

  • service providers in the scope of activities on behalf of the Elite Foundations (e.g. administrative support and accounting);
  • subcontractors as part of outsourcing;
  • auditors and legal advisers of Elite Office;
  • certain providers of services to Elite Office;
  • judicial and administrative authorities.

 

Elite Office undertakes not to communicate Personal Data to third parties other than those listed above, except when reported case by case to the Data Subjects, or in the event of a legal obligation, a court order, or a ruling by a government, supervisory or regulatory authority.

 

  1. Can Elite Office communicate Personal Data to recipients outside Switzerland?

Elite Office may disclose, communicate, transfer and/or store Personal Data abroad:

  • if necessary to enable Elite Office to establish or assert a claim, to defend itself against a current, potential or future claim, to enable Elite Office to respond to an investigation by a public authority in Switzerland or abroad; or
  • in exceptional cases in accordance with applicable law.

 

As part of the communication of, or access to, Personal Data outside Switzerland, Personal Data may be accessible from a country qualified as adequate under Swiss data protection law, i.e. a country listed in Annex 1 of the Data Protection Ordinance.

 

If Personal Data is communicated to a country without an adequate level of data protection, Elite Office must ensure, if required by applicable law, that appropriate contractual, organisational and technical safeguards are in place (e.g. by entering into standard data protection clauses with the recipient), and/or obtain the consent of the Data Subject.

 

Data Subjects may contact Elite Office for any additional information in this regard (see contact details in section 9 below).


 

 

  1. How long does Elite Office retain Personal Data?

How long Personal Data is retained depends on the duration of the statutory and regulatory retention period and on the purpose of the data processing (see section 3 above).

 

Elite Office usually retains Personal Data for ten years after the end of the contract with the Data Subject or, in the case of Personal Data pertaining to the members of the Foundations and other beneficiaries, for ten years after the end of entitlement to benefits.

 

A longer retention period may be justified, in particular to enable Elite Office to establish facts, assert its rights, or defend itself against a current or future claim, or to enable Elite Office to respond to an investigation by a public authority in Switzerland or abroad.

 

At the end of the retention period, Elite Office deletes or anonymises the Personal Data.

 

  1. What rights do Data Subjects have with regard to their Personal Data?

Subject to the applicable regulations, with regard to their Personal Data, Data Subjects have the right to:

  • access their Personal Data and obtain information about the processing of their Personal Data by Elite Office;
  • oppose the processing of their Personal Data;
  • demand rectification of their Personal Data if the data is inaccurate or incomplete;
  • request that processing of their Personal Data be restricted;
  • revoke their consent to the processing of Personal Data at any time where such consent is the basis for the processing of Personal Data, effective for the future; and
  • request erasure of their Personal Data if it is no longer required for the purposes for which they were collected of if the Data Subject has withdrawn their consent (in cases where the processing of the relevant Personal Data is based on the consent of the Data Subject), subject to the applicable retention periods (see section 7 above).

 

Data Subjects may obtain additional information from the contact person whose details are provided in section 9 below and, if they are not satisfied with the response provided, they may lodge a complaint with the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/fr/home.html).

 

Even if the Data Subject objects to the processing of their Personal Data, Elite Office is authorised to continue such processing, in particular if it is (i) based on a legal obligation, (ii) necessary for the performance of a contract to which the Data Subject is party, (iii) necessary for the performance of a task carried out in the public interest, or (iv) justified by a legitimate interest of Elite Office, including the establishment, exercise or defence of a legal claim.

 

For want of certain Personal Data (or in the event of a request for erasure), Elite Office may be unable to fulfil its contractual obligations towards the Data Subject.

 

  1. Who to contact about the processing of Personal Data?

Data Subjects who wish to obtain additional information about the points mentioned in this Privacy Policy may contact Elite Office at the following address: admin@elitefondations.ch 

 

Mégane Thomas, megane.thomas@elitefondations.ch, 021 623 13 07
Monique Luisier, monique.luisier@elitefondations.ch, 021 623 13 00

 

 

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Last updated: 11.2025