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Privacy Notice

Status as at 28 October 2026

Draft · For legal review

1) Responsibility for your information and privacy contacts

This draft describes information handling on the Banque Pérenne & Cie SA public preview and its interactive dashboard prototype. The name is the proposed project identity; it does not identify a verified incorporated data controller. The legal entity, registered address, responsible individuals and applicable jurisdictions must be confirmed before launch.

The dashboard is a simulation, with sample accounts, portfolios, market prices, payments and correspondence. It does not hold or transfer real money. The separate existing client application and its authentication or account services are outside this document’s scope and require their own verified privacy information.

Information about another person can include a beneficiary, family member, representative, employee, beneficial owner or other person connected with you. Do not put real information about these people into the prototype. Any future collection of information about related persons would require an appropriate purpose, authority and notice.

Responsible organisation

Proposed project: Banque Pérenne & Cie SA. Incorporated controller, commercial registration and registered office: To be confirmed. The draft Legal Notice records the current publication status.

Privacy enquiries

Dedicated privacy email, postal address and operational request channel: To be confirmed. The public enquiry preview is not a working privacy-request channel and does not deliver messages. No third-party institution’s privacy address is used for this project.

Data protection officer

Appointment, identity and contact details, where required or designated: To be confirmed. No named officer or external privacy representative is claimed in this preview.

Regional representation

Relevant entities, representatives and jurisdiction-specific notices: To be confirmed. Language or region controls do not establish an office, local registration or availability of a banking service.

2) How information is handled and protected

The current preview is designed to keep its interactive examples inside the browser. Public-page assets, including fonts and icons, are served from the site. Website requests still reach the hosting infrastructure, which is necessary to provide the pages and protect availability.

The public Contact enquiry preview checks fields locally without sending or storing an enquiry. The separate Our People enquiry form saves test records in this browser’s IndexedDB so that the public page and admin preview can share them. These records are not delivered to a remote inbox or email recipient. Browser history, autofill, cache and extensions are separate from these features.

Financial examples, Operations controls, history notes and team records remain in browser-local storage across reloads. Financial records can be cleared through browser site-data settings; team enquiries, simulated bank replies and portrait overrides can also be cleared through the separate team admin preview. Temporary payment PINs are stored as salted hashes, not readable codes. The prototype blocks outbound data connections. Its passcode and simulated device list are preview features, not real account security.

The published site uses HTTPS. Access controls, staff responsibilities, processor contracts, incident procedures, monitoring and other organisational safeguards must be verified for any future operational service. Neither HTTPS nor a prototype interface is a guarantee against every risk.

Use sample details only. Do not enter actual banking passwords, identity documents, tax identifiers, confidential financial records or sensitive personal information. A Face ID preview does not capture a face or perform native biometric verification.

3) The categories of information involved

Technical website information

Page and asset requests can disclose an IP address, requested URL, request time, browser and device information, referring-page information and security-related request attributes to hosting infrastructure. The precise provider log fields, settings and retention periods remain to be verified.

Public enquiry preview

The available fields are name, email address, country, enquiry subject and message. These fields are for local validation only; the public form does not send or save an enquiry.

Interactive dashboard

The interface displays sample profile and contact details, account identifiers, balances, portfolio positions, market values, beneficiary details, payment instructions, references, purposes and messages. International Wire and Offshore Payment examples include bank country, bank name, SWIFT/BIC, IBAN or account number, fee choice and optional intermediary details. Simulated financial entries, Operations controls and history notes are kept in this browser, not in a banking service. Profile changes remain session-only.

A QR-bill image selected for the prototype is decoded locally. A pasted QR payload can contain a creditor’s name, address, account, amount and reference. The prototype’s QR importer does not upload the selected image. Preview codes, preference choices, draft messages and device-session choices remain part of the local preview.

Our People enquiry forms contain a client name, client email, country, subject, message and selected-manager label. These enquiries, routing states and simulated bank replies are stored in IndexedDB on the device, not on a banking server. The prototype admin’s Clear team test data action removes these local records and portrait overrides. Manager email addresses are not displayed.

The public manager cards contain owner-supplied names, roles, languages, enquiry coverage and portraits. The owner has confirmed that the four supplied portraits are genuine and publication is permitted. These default images are public website assets and may be cached by browsers or hosting infrastructure. Later portrait selections in the admin preview remain browser-local and require the publication checklist before appearing in that browser’s public-page preview.

Downloads can create CSV, text or draft-document files on your device. Clipboard controls can place a selected value on the device clipboard. Files you download and information you copy may remain available after the page is closed, according to your device and application settings.

Future service categories

An operational service might need identity and contact details, representative or beneficial-owner information, occupation and professional information, financial circumstances, transaction and investment records, government-issued identifiers, tax information and due-diligence results. These categories are not requested or verified by this public preview.

Call recording, premises-access records, video surveillance, special-category information and biometric processing are not introduced by this website. Any future use would need its own documented necessity, lawful arrangements and clear notice before collection.

4) Purposes of processing and applicable legal grounds

Current website and prototype purposes

Technical requests support delivery of the website and its security. Local form validation lets a visitor inspect the enquiry interface. Dashboard entries show portfolio views, payment steps, reporting, correspondence and settings without creating a banking relationship or real transaction.

The public-site code includes no advertising, marketing, visitor-analytics or newsletter-subscription integration. A preference switch in the dashboard does not subscribe you to an actual email or notification service.

Future operational purposes

If authorised services are introduced, their purposes could include onboarding, identifying clients and representatives, administering accounts or investments, carrying out instructions, handling correspondence, service quality, risk management, billing, audit and legal claims. No such operational collection is established by this draft.

Where applicable to a future service, legal and regulatory duties could involve record-keeping, financial-market requirements, tax reporting, fraud prevention, sanctions screening, and anti-money-laundering or counter-terrorist-financing controls. Whether a duty applies, what information it requires and who receives it must be established for the actual entity and service.

Legal grounds and choices

The controller and advisers must confirm the laws and grounds applicable to each activity. Depending on the jurisdiction and circumstances, an activity may rely on contractual necessity, a legal obligation, an appropriately assessed legitimate interest or valid consent. This draft does not assert that any particular ground automatically authorises future processing.

No consent to future marketing, account opening, financial advice or enquiry storage is requested by using this preview. Optional processing, if later proposed, must have the notices and choices required for that specific activity.

5) Profiling and automated decisions

The public preview does not make decisions about an individual’s creditworthiness, eligibility, investments or access to a real financial service. No real investment profile, customer-risk score or advertising profile is created by the public-site code.

The dashboard applies preview validation rules, such as checking a payment amount, comparing it with a sample balance, validating the format of an account identifier and checking a preview passcode. The resulting Pending, Accepted or Cancelled labels describe simulated data, not a bank’s decision or settlement status.

Charts and market figures are synthetic examples, not personal recommendations. A Face ID selection does not analyse biometric information. No external screening, credit bureau, market-data or payment network is contacted by the dashboard runtime.

Any future profiling or solely automated decision-making with a significant effect would require a separate assessment and explanation of the activity, its consequences and applicable safeguards or review rights. No such operational decision process is claimed here.

6) Where information comes from

Technical request information comes from your browser and the connection used to request a page or asset. Form and prototype values come from sample fixtures or from what a visitor types, selects, pastes or imports into the current page.

The project owner supplies the prototype’s example content and the public team-profile information and portraits. A locally selected QR image or pasted payment payload can provide the fields shown in an imported example. Do not use genuine customer documents or other people’s confidential information in these previews.

The public preview does not obtain personal information from credit agencies, public registers, sanctions services, social networks, financial-data subscriptions, employers or other banks. It does not perform background or reputation checks.

If a future operational service receives information from representatives, counterparties, public sources, professional advisers or specialist providers, the sources and the relevant categories must be described in the applicable notice. Receiving information indirectly does not remove the need for transparent, lawful handling.

7) Recipients and service providers

Cloudflare Pages hosts the public preview. Hosting and security infrastructure necessarily handles website requests. The contracting entity, processing roles, complete service-provider inventory, access arrangements and provider terms must be verified by the responsible controller.

The public enquiry preview has no delivery recipient. Dashboard messages, profile changes, simulated payments and QR imports are not sent to a real bank, beneficiary, email provider or payment processor by the prototype runtime. No message is delivered merely because it appears in the simulated correspondence view.

The public-site code does not sell personal information or send it to advertising or analytics integrations. Opening a different website, using another application, saving a download or using the device clipboard can involve independent processing governed by those services or your device settings.

For a future operating service, appropriately appointed technology providers, professional advisers, auditors, counterparties or competent authorities may be relevant recipients. Actual recipients, purposes, legal requirements and contractual protections must be assessed and disclosed before those arrangements begin. This is not a claim that such a provider or group network already exists.

8) International processing and transfers

Hosting infrastructure can involve processing in more than one country. This preview does not promise that technical request information stays in Switzerland, the European Economic Area, or a country selected in a language or region control.

The controller must verify the relevant processing countries, provider arrangements, sub-processors and transfer mechanisms. The final notice must identify the information required by the applicable law. Those details are currently to be confirmed.

Where a transfer requires additional protection, the responsible organisation must determine the available legal mechanism and any necessary assessment or supplementary measures. An adequacy finding, contractual safeguard or exception must not be assumed merely because a service is hosted online. No unverified transfer safeguard is claimed in this draft.

The location chosen for an International Wire or Offshore Payment example is part of the simulated instruction. It does not initiate a payment or disclose that instruction to an overseas recipient. A future operational cross-border payment service would require separate, accurate processing information.

Where applicable, information about implemented transfer safeguards can be requested through the verified privacy contact once that channel has been established.

9) Your privacy choices and rights

Your rights depend on the laws that apply to the responsible organisation and the relevant processing. They may include the following, subject to the conditions, exceptions and procedures in those laws:

  • Information about processing and access to the personal information held about you.
  • Correction of inaccurate or incomplete information.
  • Erasure of information where the applicable conditions are satisfied.
  • Restriction of processing or objection to particular uses.
  • Withdrawal of consent for processing that actually relies on consent.
  • Receipt or transfer of data in a portable format where that right applies.
  • Applicable safeguards concerning significant solely automated decisions.
  • A complaint to the competent data protection supervisory authority.

These are not unconditional promises to erase every record or disclose another person’s information. A verified controller must assess each request under the applicable law, including necessary identity checks, the rights of others and any lawful retention requirements.

The privacy contact and request procedure are not yet operational. Do not send identity documents, sensitive records or a rights request through the enquiry preview. A working request channel, responsible contact and applicable response arrangements must be published before launch.

Within the prototype, you can correct local sample balances, annotate history and cancel eligible simulated payments. Reloading preserves those financial examples and local change records. Clear them through browser site-data settings. The separate team admin preview’s Clear team test data action clears browser-local enquiries and portrait overrides; it retains the four owner-approved default portraits. These actions are not formal statutory requests, deletions of published website assets or requests concerning provider logs.

You can also manage browser history, autofill, cache, cookies, downloads and clipboard content using your own device and browser controls. The Cookie Notice provides the current public-site storage information.

10) Retention, deletion and updates to this notice

The public Contact enquiry preview does not create a stored enquiry. Financial examples and Operations records persist in this browser’s IndexedDB until browser site data is cleared; they are not real account or payment records. Our People enquiries, internal routing, simulated bank replies and selected portrait overrides persist separately until team test data or browser site data is cleared. They are not a remote banking inbox and are not shared with other visitors or devices.

Downloaded files, copied information, browser history and autofill can remain on your device independently of the page. Reloading the prototype does not delete those device-managed copies or records held by a hosting provider.

The retention periods for hosting and security logs have not been confirmed. The final schedule must identify actual purposes, provider settings and applicable obligations. No fixed deletion deadline or universal banking-record retention period is promised in this draft.

For a future operational service, retention would need to be assessed by record category, purpose and jurisdiction. Relevant obligations, a genuine legal hold or an ongoing claim may affect deletion. Records should not be retained indefinitely without an established justification. Those future arrangements must be documented before collection begins.

This draft is dated 28 October 2026. It must be reviewed when the controller is confirmed, a contact route is connected, a provider changes, or the project introduces new processing. Material changes must be communicated as required; this page is not advance consent to undisclosed future activities.