The collection, processing and use of personal data collected from you when using the Waller app is carried out by
Waller Swiss AG, Bahnhofstrasse 29, 6300 Zug, Switzerland (hereinafter referred to as "Waller" or "We"), e-mail: info@waller.swiss. For more information on Waller, please refer to the imprint.

This privacy policy applies only to the use of the Waller app and therefore, in particular not to:
– visiting and using the Waller website www.waller.swiss (for information on data protection in connection with the use of the Waller website, please refer to the applicable Privacy Policy on our website at https://waller.swiss/privacy_policy);
– personal information that may be collected and stored in announced records of telephone conversations with our employees to fulfil our legal and regulatory obligations or for business purposes of Waller;
– other websites to which you are directed via a link.

If you use our services for informational purposes only or without a bank account, we do not collect any personal data, except for the data transmitted by your browser or terminal device to enable your visit to our website.

Waller strives to only store so much data about you that we can offer you the full range of features at the maximum level of security possible. Waller collects, stores, processes and uses personal data so that we can offer you the usage options in accordance with the contract. Waller creates your customer profile only with your consent.

Your personal data will only be passed on to third parties if we are obliged to do so by law or if you have given your prior consent.

To log into the Waller app (after signing up via Waller), you have to enter your e-mail address and a login code.

Identification with fingerprint and face recognition. The Waller app allows you to log in using fingerprint and face recognition if the device you are using supports this feature (e.g. Touch ID or FaceID from Apple). In this context, neither Waller nor the Waller app receives your biometric data. If you would like more information on how fingerprint or face recognition identification works, please contact the provider of that feature.

Account management. The Waller app shows you your personal data such as your account details, IBAN, name, e-mail address, mobile phone number and registered residence address.

Money and card transactions. The Waller app allows you to transfer money (e.g. by in-payment slip, bank transfer, standing order, direct debit, etc.) or withdraw money, receive credits, always have an up-to-date account overview and pay with your Waller account (collectively called "transactions"). The data entered for a transaction or otherwise obtained is transmitted in encrypted form to and from Hypothekarbank Lenzburg. Waller stores the following data for the purpose of displaying the information in the Waller app and offering all Waller app features: data entered during a transaction, which varies depending on the type of transaction (your account number/IBAN/BIC, address, reference number), and other data, if applicable (collectively called "transaction data"). The Waller app provides an overview of all transactions made by you with your Waller app and the associated Waller private account at Hypothekarbank Lenzburg. In any case, Waller stores the data of all transactions in encrypted form.

Termination. If you cancel your Waller private account with Hypothekarbank Lenzburg, Waller deletes all data assignable to this bank account. As a bank, Hypothekarbank Lenzburg fulfils its supervisory and regulatory obligations and stores your data in accordance with legal requirements.

Notifications. If you use the Waller app, you will be able to activate the "Notifications" feature to be kept up to date on your account activity, including transactions (credits and debits), spend alerts and account balance updates. For you to use this feature, Waller requires the login code of your Waller private account to be stored in a secure data centre. This feature uses the Apple Push Notifications Service of Apple Inc. ("Apple"), One Infinite Loop, Cupertino, California 95014, USA or the Google Cloud Messaging Service of Google Inc. ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you would like more information about how this works, please contact the relevant provider of this feature. Waller will send you a notification about Apple's Push Notification Service or Google's Cloud Messaging Service, depending on the operating system of your device. You can also choose whether notifications should include sensitive transaction data or not. In any case, the notification will be encrypted.

b. Identification procedure

c. Customer support

Master data. For the purpose of opening a Waller private account with Hypothekarbank Lenzburg AG and using Waller's services, the following personal data is collected, used and processed during onboarding:
– first and last names,
– date of birth,
– place of birth / hometown,
– sex,
– marital status,
– e-mail address,
– citizenship,
– registered residence address,
– mobile phone number,
– beneficial ownership,
– tax domicile and US tax liability,
– identification document copy,
– type of identification document,
– date of issue,
– ID number,
– issuing authority.

When opening an account, Hypothekarbank Lenzburg is legally obliged to verify your identity by means of a valid identification document and to save certain details of the identification document. For this purpose, we offer you digital identification options in accordance with the criteria of FINMA Circular 2016/7 "Video and Online Identification" ("FINMA RS") of the Swiss Financial Market Supervisory Authority ("FINMA"). Soon Waller will offer video identification in order for the user to have a choice between online and video identification.

If you contact Waller support, only the data about your app and operating system version in conjunction with the information you provide in your request will be used. Our customer support does not have access to your bank details. Waller stores the correspondence between you and our customer support, regardless of whether we communicate by e-mail or chat. This way we can better support you in future requests. Of course, you can always ask us to delete this correspondence.

Waller can offer you a variety of additional features based on the above data. At present, these include the automatic categorisation of your transactions and sorting your account history by selected periods and recipients as well as the possibility to send money to other Waller users via the address book and messenger contacts feature.

Categories. Waller automatically categorises all of your transactions, especially expenses, for you. The Waller app automatically assigns transactions to a specific category (e.g. expenses to "restaurants", "travel"), e.g. by the account number, the reference or the name of the recipient. You have the option to re-assign transactions to another category at any time. By assigning transactions to a category, the Waller app is able to present the transactions made in a specific category as a percentage of all transactions made in a period.

Contacts. Waller allows you to make cashless payments to and receive them from other Waller users listed in the address book feature of your smartphone and Telegram messenger. To identify other Waller users, the Waller app accesses your address book and recognises them via phone number.

Usage data. Waller collects, processes and uses data that is generated as you use the Waller app in order to improve the user experience and prevent misuse. In particular, this includes the IP address, as well as information on screen resolution and operating system of the device used to access the app, the timestamp of such access, the duration of the visit and the content accessed during the visit (collectively, "usage data").

Manipulations. Waller logs the IP address of the user, the login data, a pseudonymised device identification number and an encrypted identification number of the Waller user account for the purpose of uncovering abusive or illegal activities. Waller strives to store only so much data about you that enables us to offer you the full range of features at the maximum level of security possible. Waller collects, stores, processes and uses personal data so that we can offer you the usage options in accordance with the contract. Waller creates your customer profile only with your consent.

Non-personal (anonymous) data, such as statistics about the device you are using or transaction data where all personal information has been deleted, cannot be used to identify you. We use this information to continually improve the performance and offerings of the Waller app.

Communication between Waller and Hypothekarbank Lenzburg is completely encrypted using the TLS/SSL standard protocol.

Security. All transactions are processed over an interface layer based on a secure Application Programming Interface ("Open API") of Hypothekarbank Lenzburg or Waller. All bank transaction data is stored in Swiss data centres. These are ISO27001-certified. We are subject to Swiss data protection law.

Same as banks, we are dependent on the services of third parties, such as e. g. our data centre. Your data is always protected.

Third-party provider. In order to use technical or organisational services of third parties, which we need for the fulfilment of the purposes mentioned in this Privacy Policy or our other business activities, personal data of the users can be stored in the systems of such service providers. This includes, for example, your transaction data being stored in encrypted form in an ISO27001-certified data centre in Frankfurt am Main, Germany, or your e-mail address in our support system. Our service providers are subject to the relevant data protection laws and are also contractually obliged to process personal data exclusively on our behalf and in accordance with our instructions. We also oblige our service providers to comply with technical and organisational measures that ensure the protection of personal data.

E-mails. If Waller sends you e-mails based on your consent, you can revoke this consent at any time. Every e-mail from us gives you the option of unsubscribing from further product information or e-mails.

As far as Waller transfers personal data in countries outside Switzerland when processing personal data and for the free movement of data, Waller ensures that the recipient of the data guarantees an adequate level of data protection.

Obligation to provide information. Upon request, Waller will provide you with information about any personal data stored about you, recipients or categories of recipients who have received personal data about you from us, and the purpose of such storage. If personal data stored about you is incorrect, you can contact customer support at any time and Waller will correct this data immediately. You also have the option of updating all data directly in the Waller app. Any consent given by you to use the data can be revoked at any time with effect for the future. The revocation of your consent may result in our services no longer being available to you without restriction or the user relationship being terminated. Please note that certain data collections and storage may also be based on a legal ground, regardless of whether you have given your consent. In this case, we will abort further processing and use of your personal data and delete or block it, unless we are obliged by law to further processing, in particular further storage.

Customer support. For any help regarding the Waller app use, please contact our support at info@waller.swiss any time. Should you have any general questions about this Privacy Policy or Waller's data protection, please feel free to contact us by e-mail at info@waller.swiss or by mailing Waller Swiss AG, Bahnhofstrasse 29, 6300 Zug, Switzerland.

This Privacy Policy is effective immediately. Waller reserves the right to make changes to the Privacy Policy at any time. These will be announced to the customer via email and are deemed to have been approved within 30 days without objection. If no objection is declared within this period, which begins from receipt of the message by e-mail, the amended Privacy Policy shall be deemed to have been agreed and approved. Within the framework of the notice of termination regarding the change to the Privacy Policy, Waller shall inform the customer separately of their right to object, the objection period and the meaning of their silence. For the latest version of the Privacy Policy published on our website, please visit www.waller.swiss/privacy_policy_mobile.