Privacy Policy
Last updated: September 25, 2026. This policy outlines how Swthe Banks and its operating subsidiaries manage, process, and safeguard institutional and personal data under Swiss and European regulatory frameworks.
1. Regulatory Scope & Applicable Law
Swthe Banks operates as a consolidated financial network comprising specialized banking divisions including Bank Svwþqh, Bank Filænks, Bank Flæmës, and Bank Ragœnks.
Data collection and processing routines across all group entities strictly adhere to the Swiss Federal Act on Data Protection (FADP), the General Data Protection Regulation (GDPR - Regulation EU 2016/679), and relevant financial market supervisory standards.
2. Categories of Information Collected
To maintain institutional custody, execute trading operations, and satisfy global compliance mandates, we process the following categories of data:
- Institutional & Client Identification Data: Full legal name, corporate registration records, tax identification numbers, proof of address, and beneficial ownership declarations.
- Financial & Transactional Data: Account numbers, custody holdings, cross-border wire histories, FX order routing logs, and credit facility agreements.
- Technical & Telemetry Data: IP addresses, session tokens, browser signatures, and encrypted audit logs collected during access to online banking panels or API endpoints.
3. Legal Basis & Purpose of Processing
Personal and corporate data is processed strictly under the following legal bases:
Contractual Necessity
Execution of private banking, custody agreements, family office mandates, and trading orders.
Regulatory Compliance
Fulfillment of Anti-Money Laundering (AML), Know Your Customer (KYC), CRS, and FATCA obligations.
4. Data Sharing & Cross-Border Transfers
Swthe Banks does not sell, lease, or monetize client data under any circumstances. Information may be shared strictly on a need-to-know basis within our internal banking subsidiaries (Bank Svwþqh, Bank Filænks, Bank Flæmës, Bank Ragœnks) for multi-jurisdictional account settlement.
External transfers occur solely to designated clearing networks, central securities depositories (CSDs), or regulatory authorities when compelled by binding judicial or statutory requirements.
5. Security Standards & Data Retention
We employ end-to-end multi-layer encryption protocols, hardware security modules (HSMs), and isolated vault storage for all digital records. Personal data is retained for the duration of the institutional relationship plus ten (10) years following account closure to satisfy statutory banking retention mandates under Swiss and EU law.
6. Data Subject Rights
Under applicable data protection laws, clients and authorized representatives hold the right to:
- Request formal confirmation and copies of personal data stored within our custody systems.
- Require rectification of inaccurate or outdated corporate records.
- Request restriction of processing or erasure of data, subject to overriding statutory financial retention obligations.
Data Protection Officer (DPO) Contact
For inquiries regarding this Privacy Policy, rights requests, or cross-border data transfer details, please direct correspondence to our compliance officer:
Swthe Banks – Legal & Compliance Office
Email: privacy@swthe.ch