US Privacy notice addendum

Last modified October 16, 2026

This US Privacy Notice Addendum (“US Addendum”) supplements the Avaloq Website Privacy Notice (“Website Notice”) and the Avaloq Privacy Notice for Clients, Suppliers and Partners (“General Notice”). It applies solely to residents of states with comprehensive consumer privacy laws, including but not limited to California, Virginia, Colorado, Connecticut, Utah, Texas, and Florida (“US Consumers”). Any terms defined in regional frameworks hold the same meaning when used here.

1. Information We Collect and Disclose

We may collect and process the following information (including personal information) about you:

Information that you give us:

• This includes information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card (or similar), or corresponding with us by telephone, post, email or other means.
• It may include, for example, your name, address, email address, work telephone number, mobile telephone number, information about your business relationship with us, information about you necessary to complete anti-money laundering checks in order to comply with requirements relating to anti-money laundering and other legislation applicable to us; and information about your professional role, background and interests.

Information that our website and other systems collect about you:

• If you visit our website, it will automatically collect certain information about you and your visit, such as your browser type and version. You may find information about such information collection in Section 8 (“How we may use cookies and similar technologies”) of our Website Notice.  
• If you email, telephone, write, or exchange other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations and exchanges, sometimes including their content.
• Some of our premises have closed-circuit TV systems which may record you if you visit our premises, for security and safety purposes.

Other information: We may also collect some information from other sources. For example:

• If we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you, such as your contact details or details of your role in the organization that you represent.
• We sometimes collect information from other third parties, which can include third-party data providers, or from publicly available sources for anti-money-laundering, background checking and similar purposes, to protect our business and to comply with our legal and regulatory obligations.

Within the preceding 12 months, Avaloq has collected the following categories of personal information through its online platform, mapped to statutory definitions, and disclosed them for business purposes to the entities listed below:

We generally do not collect sensitive personal information through our online platform. In limited circumstances where sensitive personal information is provided to us or collected as part of a specific business interaction, we will process such information only as permitted by applicable law and for the purposes for which it was provided.

2. Business and commercial purposes for collection

We utilize the categories of information above to maintain our business operations as specified in Section 4 of our Website Notice and Section 4 of our General Notice as applicable, including:

• Initiation and performance of the contractual relationship with you and/or your employer, communication purposes,  
• Delivering requested services and offerings, webinars, and managing platform account registrations.
• Developing, testing, auditing, and optimizing our web presence via session metrics.
• Tailoring marketing communication, B2B sales outreach, and cross-site behavioral advertising campaigns.

3. Sales, sharing, and targeted advertising disclosures

While our Website Notice states that we do not rent or trade personal data, certain US state laws broadly define the "Sale" or "Sharing" of data to encompass the use of third-party targeting cookies, tracking pixels, and behavioral ad technologies. Avaloq does not currently sell personal information for monetary or other valuable consideration. However, the definitions of “sale,” “sharing,” and “targeted advertising” vary under applicable U.S. state privacy laws.

• Targeted Advertising / "Sharing": By deploying third-party cookies (such as Google Ads, Facebook Pixel, LinkedIn Insight Tag, and Microsoft Bing), Avaloq may "sell" or "share" your Identifiers, commercial information, and network activity to advertising networks for cross-context behavioral marketing.
• Opt-Out Right: To the extent that an activity described in this Notice is treated as a sale, sharing, or targeted advertising under applicable law, you may exercise available privacy choices through our “Cookie Settings” page. That page explains the cookie controls, browser-based privacy signals, and preference-management options available on our websites. Please note that by default Avaloq does not enable any such cookies automatically unless you actively opt-in.

4. Your US privacy rights

Depending on your place of residence and the privacy laws that apply, you may have some or all of the rights described below. These rights may be subject to limitations and exceptions under applicable law:

• Right to know and access. You may have the right to confirm whether we process your personal information and to request access to the personal information we maintain about you. You may also have the right to receive information about the categories of personal information we collect, the purposes for which we use it, the categories of sources from which it is collected, and the categories of third parties to which it is disclosed.
• Right to data portability. You may have the right to receive certain personal information in a portable and, where technically feasible, readily usable format.
• Right to correction. You may have the right to request correction of inaccurate personal information that we maintain about you.
• Right to deletion. You may have the right to request deletion of personal information that we maintain about you, subject to applicable exceptions.
• Rights relating to sensitive personal information. You may have the right to limit certain uses or disclosures of sensitive personal information or to withdraw consent to its processing. Where applicable law requires consent before we process sensitive personal information, we will request that consent.
• Right to opt out. You may have the right to opt out of the sale of personal information, the sharing of personal information for cross-context behavioral advertising, the processing of personal information for targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to information about third parties. Where required by applicable law, you may have the right to request a list of specific third parties to which we have disclosed personal information or other information concerning those disclosures.
• Right to appeal. If we decline to act on your request, you may have the right to appeal our decision.
• Right to non-discrimination. You have the right not to receive unlawful discriminatory treatment for exercising a privacy right.

These rights are not absolute, and certain jurisdictions may provide additional rights or impose different requirements. Where applicable law provides a right or protection that is not expressly described in this Notice, Avaloq will honor that right or protection as required by law. Additionally, a right may not apply to you or to particular information, and we may decline or limit a request where permitted by applicable law. If we deny a request, we will provide the information required by applicable law, which may include the basis for the denial and instructions for submitting an appeal.  

5. How to exercise your rights

In connection with our online platform, we may ask you specifically whether you have objections to a certain kind of data use or disclosure. If you opt out under such circumstances, we will respect your decision. To opt out of the "Sale" or "Sharing" of your data via targeting cookies, navigate to our website footer “Cookies” and select the "Cookie Settings" link to disable Category 4 Targeting Cookies.

To exercise any other rights as described in this Notice, please submit a verifiable request by contacting our Data Protection Officer at dataprotection@avaloq.com. Please describe your request and provide the information reasonably necessary for us to identify the personal information to which the request relates.

We will respond within the period required by applicable law. If permitted, we may extend the response period and will notify you of the extension and the reason for it.

We may take reasonable steps to verify your identity before processing a request to access, correct, delete, or obtain a copy of personal information. The verification information we request will depend on the nature of the request and the sensitivity of the information involved. We will use personal information provided for verification only to verify and process the request, prevent fraud, or as otherwise permitted by law.

We will not require you to verify your identity to a degree that is disproportionate to the nature of an opt-out request. We may request information that is reasonably necessary to identify the browser, device, account, transaction, or processing activity to which the opt-out applies.

Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf. We may request evidence that you authorized the agent to act for you and may take reasonable steps to verify your identity or confirm the authorization directly with you. We will not require direct confirmation where applicable law provides otherwise.

If we cannot verify your identity or authority to the degree required for the applicable request, we may be unable to fulfill all or part of the request. We will notify you of our inability to fulfill any such request as required by applicable law. You may have the right to appeal requests that have been denied by contacting us through our Contact Us form. Please identify the original request and explain the basis for your appeal. We will review and respond to the appeal within the period required by applicable law and will provide any additional information required by law.

We will not restrict or deny you access to our services because of choices and requests you make in connection with your personal information.

Global Privacy Control (GPC): Our platform is configured to recognize Global Privacy Control (GPC) opt-out signals sent via your browser. If our systems detect a GPC signal, we automatically treat it as a valid directive to block targeting cookies on that browser.

6. California-specific disclosures

If you are a California resident, you are entitled, once a year and free of charge, to request information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. Note: Avaloq does not sell or share personal information with third parties for their own direct marketing purposes, as those terms are defined by the statute, without your consent or providing the option to opt out.