General privacy policy of St.Galler Kantonalbank AG

1. What is this privacy policy about?

St.Galler Kantonalbank AG (hereinafter "SGKB" or "we") obtains and processes personal data relating to you or other persons (referred to as "third parties").

We use the term "data" in our General Privacy Policy synonymously with "personal data" or "personal information". In this Privacy Policy, we describe how we process your data when you visit our website (, subscribe to a newsletter, obtain our services or products, otherwise interact with us under a contract, communicate with us (including through Microsoft Teams) or otherwise deal with us. We also inform you separately about specific data processing, e.g. in specific data protection statements, terms of use, declarations of consent, forms and notices. For the following groups of persons and data processing, you will find a summary of the most important information at

  • Clients and persons associated with them
  • Interested parties and potential clients
  • Shareholders
  • Users of our website and our newsletter
  • Suppliers and partners

If you provide us with data about other people (e.g. family members, authorised representatives), we assume that you are authorised to do so and that these data are correct. By submitting data via third parties, you confirm this. Please ensure that these third parties have been informed of this privacy policy.

This Privacy Policy is designed to comply with the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA") and the revised Swiss Data Protection Act ("revDPA"). However, whether and to what extent these laws are applicable depends on the individual case.

2. Who is responsible for processing your data?

St.Galler Kantonalbank AG (CHE-105.845.146) is responsible for the data processing described in this data protection declaration, unless otherwise communicated in individual cases.

You can contact us for your data protection concerns and to exercise your rights under section 14 as follows:

St.Galler Kantonalbank AG
Data Protection Office
St. Leonhardstrasse 25
9001 St. Gallen

3. What data do we process?

We process different categories of data about you depending on the situation and purpose and based on the products and services you use. The main categories are as follows:

  • Master data: We define master data as the basic data that we need, along with other data, for the processing of our contractual and other business relationships or for marketing and advertising purposes, such as name, contact details and information about your role and function, for example. We process your master data if you are a client or other business contact or work for one (e.g. as a contact person of the business partner), or because we want to address you for our own purposes or the purposes of a contractual partner (e.g. as part of marketing and advertising, with invitations to events, with newsletters, etc.). We receive master data from you yourself (e.g. as part of the business relationship), from bodies for which you work or from third parties such as our contractual partners, associations and address dealers and from publicly accessible sources such as public registers or the Internet (websites, social media, etc.). We may also process health data and information about third parties as part of master data. We can also collect master data from our shareholders and investors. We generally keep these data for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer insofar as this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. For pure marketing and advertising contacts, the period is usually much shorter, usually no more than 2 years since the last contact.
  • Contract data: This is data that arises in connection with the conclusion or processing of a contract, e.g. information about contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing, and information about reactions (e.g. complaints or information on satisfaction, etc.). This also includes health data and information about third parties. We generally collect these data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third party sources (e.g. credit agencies) and from publicly accessible sources (e.g. a commercial register). We generally keep these data for 10 years from the last contract activity, or from the end of the contract. This period may be longer insofar as this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.
  • Behavioural and preference data: Depending on the relationship we have with you, we try to get to know you and better tailor our products, services and offers to your needs. To do this, we collect and use data about your behaviour and preferences. We do this by analysing information about your behaviour in our area, and we may also supplement this information with information from third parties, including publicly available sources. Based on this, we can calculate, for example, the probability that you will use certain services or behave in a certain way. The data processed for this purpose is partly already known to us (e.g. when you use our services) or we obtain these data by recording your behaviour (e.g. how you navigate our website or use our apps). We anonymise or delete these data when they are no longer meaningful for the purposes pursued, which may be after four years (for product and service preferences) depending on the nature of the data. This period may be longer insofar as this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. We describe how tracking works on our website in Section 12.
  • Communication data: If you are in contact with us using the contact form, by email, telephone or chat, by letter or by any other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, e.g. for training and quality assurance purposes, we will specifically draw your attention to this unless the recording is required to comply with legal requirements. Such records may only be made and used in accordance with our internal guidelines. If we want or need to establish your identity, e.g. in the case of a request for information submitted by you, a request for media access, etc., we collect data to identify you (e.g. a copy of an ID). We usually keep these data for 24 months from the last communication with you. This period may be longer insofar as this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years. Records of chats are usually kept for 24 months.
  • Technical data: When you use our electronic offers (e.g. e-banking, mobile banking) or our website, we collect the IP address of your terminal device and other technical data to ensure the functionality and security of these offers. These data also include logs recording the use of our systems. We usually keep technical data for 24 to 48 months. To ensure the functionality of these offers, we may also assign an individual code to you or your end device (e.g. in the form of a cookie, see section 12). Technical data as such do not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they may be linked to other categories of data (and thus possibly to your person).
  • Registration data: Certain offers, e.g. of competitions and services (e.g. login areas of our website, newsletter dispatch etc.) can only be used with a user account or registration, which can be completed directly with us or using our external login service providers. In doing so, you must provide us with certain data and we collect data about the use of the offer or service. Access controls to certain facilities may generate registration data; depending on the control system, biometric data may also be generated. We generally retain registration data for 12 months after the end of the use of the service or the termination of the user account.
  • Other data: We also collect data from you in other situations. In connection with official or judicial proceedings, for example, data are generated (such as files, evidence, etc.) that may also relate to you. We may also collect data for health protection reasons (e.g. within the framework of protection concepts). We may receive or produce photographs, videos and audio recordings in which you may be identifiable (e.g. at events, by security cameras etc.). We may also collect data on who enters certain buildings and when, or has access rights to certain buildings (including access control, registration data, visitor lists, etc.), who participates in events or activities (e.g., events in the city), and who participates in events or activities (e.g. competitions) or who uses our infrastructure and systems and when. Finally, we collect and process data on our shareholders and other investors; in addition to master data, these include information for the relevant registers, regarding the exercise of their rights and the holding of events (e.g. general meetings). The retention period for these data depends on the purpose and is limited to what is necessary. This ranges from a few weeks for security cameras to reports on occasions with images that can be kept for a few years or longer. Data about you as a shareholder or other investor will be kept in accordance with company law, but in any case for as long as you are invested.

4. Where do your data come from?

You provide us with much of the data mentioned in section 3 yourself (e.g. via forms, in the course of communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, except in individual cases, e.g. within the framework of binding protection concepts (legal obligations). If you wish to conclude contracts with us or claim services, you must also provide us with data, in particular, master data, contract data and registration data, as part of your contractual obligation under the relevant contract or on the basis of statutory provisions which the Bank must observe. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you will need to provide us with registration details. However, in the case of behavioural and preference data, you generally have the option of objecting or not giving consent.

Insofar as this is not inadmissible, we also extract data from publicly accessible sources (e.g. enforced payment collection registers, land registry, commercial registers, sanctions and embargo lists, the media or the internet including social media) or receive data from other companies within our group, from authorities and from other third parties (e.g. credit agencies, address dealers, associations, contractual partners, internet analysis services, etc.).

5. For what purposes do we process your data?

We process your data for the purposes we explain below. Further instructions for the online area can be found in Sections 12 and 13.

  • Establishment, management and settlement of business or contractual relationships: We process your data for the purpose of establishing, managing, processing and terminating business or contractual relationships. The type of data processed varies according to the type and scope of the relationship and the nature of the products and services used and may include, in particular, master data, contract data, communication data and registration data.
  • Adherence to laws, directives and recommendations of authorities as well as internal regulations ("Compliance"): We further process your data to comply with laws, directives and recommendations from authorities and internal regulations ("Compliance"). Processed data include, in particular, your master data, contract data, communication data and behavioural data.
  • Risk management and prudent corporate governance: We also process your data for the purposes of our risk management, fraud prevention and as part of prudent business management, including operational organisation and business development. The data processed include, in particular, master data, contract data, communication data, behavioural data and registration data, but also technical data.
  • Marketing activities and relationship building: We process data for marketing purposes and to maintain relationships, e.g. in order to provide our clients and other contractual partners with personalised recommendations and offers for products and services from us and from third parties (e.g. cooperation partners). This may be, for example, in the form of newsletters and other regular contacts (electronically, by post, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, competitions, etc.) and sponsoring. You can refuse such contacts at any time or refuse or revoke consent to be contacted for advertising purposes. The data processed include in particular master data, contract data, behavioural data and preference data.
  • Market research, improvement of services and operations, and product development: We continue to process your data for market research, to improve our services and operations and for product development. The data processed include in particular master data, contract data, behavioural data and preference data, as well as information from customer surveys, polls and studies.
  • Security purposes and access control: We then also process your data for security and access control purposes. The data processed include master data, registration data, behavioural data, technical data and other data.
  • Communication: We also process your data in connection with communication with you, in particular to answer enquiries and assert your rights (section 14) and to contact you in the event of queries. For this purpose, we use in particular communication and master data and, in connection with offers and services used by you, also registration data. We retain these data to document our communication with you, for training purposes, quality assurance and for future reference.
  • Other purposes: We may process your data for other purposes, e.g. as part of our internal processes and administration or for training and quality assurance purposes.

6. On what basis do we process your data?

If we ask you for your consent for certain processing, we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time with future effect by notifying us in writing (by post) or, where not otherwise stated or agreed, by e-mail; you will find our contact details in section 2. Once we have received notification of the withdrawal of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Where we do not ask for your consent for processing, we base the processing of your personal data on the fact that the processing is necessary for the initiation or execution of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, so in particular to pursue the purposes and related objectives described above under section 5 and to be able to implement appropriate measures. Our legitimate interests also include compliance with legal regulations, insofar as these are not already recognised as a legal basis by the respective applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and Switzerland). But this also includes the marketing of our products and services, the interest in better understanding our markets and in managing and developing our business, including operations, safely and efficiently.

When we receive sensitive data (e.g. health data, information on political, religious or ideological views or biometric data for identification purposes), we may also process your data on the basis of other legal grounds, e.g. in the event of disputes due to the necessity of processing for a possible lawsuit or the enforcement or defence of legal claims. In individual cases, other legal grounds may come into play, which we will communicate to you separately where necessary.

7. What applies to profiling and automated individual decisions?

We may automatically evaluate ("profile") certain of your personal characteristics for the purposes mentioned in section 4 using your data (section 3), if we want to determine preference data, but also to determine risks of abuse and security, to carry out statistical evaluations or for operational planning purposes. For the same purposes, we may also create profiles, i.e. we may combine behavioural and preference data, but also master and contract data and technical data assigned to you, in order to better understand you as a person with your different interests and other characteristics.

In certain situations, it may be necessary for reasons of efficiency and consistency of decision-making processes that we automate discretionary decisions affecting you with legal effects or possibly significant disadvantages ("automated individual decisions"). We will inform you accordingly in this case and provide for the measures required under applicable law.

8. Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes listed in Section 5, we also transfer your personal data to third parties, in particular, to the following categories of recipients:

  • Service provider: We work with service providers in Germany and abroad who process data about you on our behalf or in joint responsibility with us or who receive data about you from us in their own responsibility (e.g. IT providers, shipping companies, advertising service providers, security companies, banks, insurance companies, debt collection companies, credit agencies or address checkers).
  • Contractual partners as well as bodies and persons involved: We will also share your information with people acting on your behalf (e.g. agents, external asset managers) or who are otherwise involved in the settlement of a contract. If you work for one of our contractual partners (e.g. a client or supplier), we may also transfer data about you to them.
  • Partners: We pass on your data to our partners if we provide you with products and services or if the contractual relationship includes bonus programmes or other third-party services. These third parties may process the transferred data jointly with us or as independent data controllers for their own legitimate interests or for the provision of services. The third parties provide information about their independent data processing in their own data protection statements.
  • Authorities and other official bodies: We may disclose personal data to offices, courts and other authorities, as well as other official bodies (e.g. the Swiss Banking Ombudsman) in Switzerland and abroad if we are legally obliged or entitled to do so, or if this appears necessary to protect our interests.
  • Other persons: We may also disclose personal data to other recipients if we are obliged or entitled to do so.

All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).

9. Does your personal data also end up abroad?

As explained in Section 8, we also disclose data to other bodies. These data are not located solely in Switzerland. Your data may therefore be processed worldwide, including outside the European Union (EU) or the European Economic Area (EEA). If a recipient is located in a country without adequate data protection legislation, we contractually oblige the recipient to comply with the applicable data protection legislation, usually by entering into recognised standard contractual clauses. This may be waived if the recipient is already subject to a legally recognised set of rules to ensure data protection, or if we can rely on an exemption clause. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the execution of a contract requires such disclosure (e.g. for the processing of payments and securities transactions), if you have given your consent (e.g. requests for information from foreign financial market supervisory authorities and securities issuers) or if it is a matter of data that you have made generally accessible and you have not objected to its processing.

Please also note that data exchanged via the internet is often routed through third countries. Your data can therefore end up abroad even if the sender and recipient are in the same country.

10. How long do we process your data for?

We process your data for as long as required for our processing purposes, to comply with statutory retention periods and our legitimate interests in processing for documentation and evidence purposes, or as long as storage is technically necessary. Further information on the respective storage and processing period can be found in the individual data categories in Section 3 or in the cookie categories in Section 12. In the absence of any legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our normal processes.

11. How do we protect your data?

We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect against the risks of loss, accidental alteration, unauthorised disclosure or access.

12. Do we use online tracking?

On our website, in e-banking and in the mobile app (mobile banking), we use various technologies that enable us to recognise you when you use them and, in some circumstances, to track you across multiple visits. In this section we inform you about it.

In essence, it is about us being able to differentiate access by you (via your system) from access by other users, so that we can ensure the functionality of the website, in e-banking and in the mobile app and can carry out evaluations and personalisation. The technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of third parties) assigning you or your browser a specific recognition number (referred to collectively as "cookies").

We use such techniques on our website, in e-banking and in the mobile app. However, depending on the purpose of these techniques, we ask for your consent before they are used. You can configure the settings of your browser to block or reject certain cookies or to delete existing cookies. You can also enhance your browser with software that blocks tracking by certain third parties. You will find further information on this on the help pages of your browser (usually under the keyword "Data protection").

A distinction is made between the following cookies (techniques with comparable functions such as fingerprinting are included here):

  • Necessary cookies: Some cookies are necessary for the functioning of the website as such or certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also make sure you stay logged in. These cookies only exist temporarily ("session cookies"). If you block them, the website may not work. Other cookies are necessary to allow the server to save decisions or entries you made in a session (i.e. a visit to the website) if you request this function (e.g. language selected, consent given, the automatic login feature, etc.). These cookies have different expiry dates.
  • Analytics cookies: To optimise our website and corresponding offers and to better adapt them to the needs of the users, we use cookies to record and analyse the use of our website, possibly also beyond the session. You can revoke this at any time by deleting the session cookie (_cfy_cc) in your browser.

13. What data do we process on our social media pages?

We may operate pages and other websites ("fan pages," "channels," "profiles," etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive these data from you and the platforms when you come into contact with us through our website (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our websites and link these data with other data about you known to the platforms (e.g. on your behaviour and preferences). They also process these data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalise advertising) and to control their platforms (e.g. which content they show you).

We process these data for the purposes described in Section 5, in particular, for communication, marketing and market research purposes. Content you have published yourself (e.g. comments on an announcement) we may disseminate ourselves (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or to you in accordance with the usage guidelines (e.g. inappropriate comments).

Further information on the processing by the operators of the platforms can be found in the privacy policies of the platforms There you will also find out in which countries they process your data, which rights of access, deletion and other data subjects you have and how you can exercise these or obtain further information.

14. What rights do you have?

To help you control the processing of your personal data, you have the following rights in connection with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and which data we are processing;
  • the right to have us rectify data if it is inaccurate;
  • the right to request the erasure of data;
  • the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • the right to withdraw consent insofar as our processing is based on your consent;
  • the right to obtain, on request, further information necessary in order to exercise these rights;
  • the right to express your point of view in the case of automated individual decisions (Section 6) and to request that the decision be reviewed by a natural person.

Applicable data protection law grants you the right to object to the processing of your data in certain circumstances, in particular for direct marketing, direct marketing profiling and other legitimate processing interests.

Please note that these rights are subject to conditions, exceptions or limitations under applicable data protection laws (e.g. to protect third parties or trade secrets). We will inform you accordingly if necessary.

If you wish to exercise any of the above rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; you will find our contact details in Section 2. In order for us to be able to rule out misuse, we must identify you (e.g. with a copy of your ID card, if this is not possible in any other way).

If SGKB does not meet your expectations with regard to the processing of your personal data, please inform us or our data protection officers (Section 2) in a meaningful communication. This gives us the opportunity to consider your request.

If you believe that SGKB has not dealt with your enquiry or concern to your satisfaction, or if you believe that SGKB is not processing your personal data in accordance with data protection law, you can contact the data protection supervisory authority in your country. You can reach the Swiss supervisory authority here: You can find a list of authorities in the EEA here:

15. Can this privacy policy be changed?

We can change this privacy policy at any time. The version published on our website ( is the current version.

Last updated: September 2023