Notice on the processing of personal data carried out by Altiqa SA

Dear Customer,

With this Data Protection Notice, Altiqa SA, explains to its Clients how it processes their personal data, in accordance with the principles prescribed by the regulations applicable in the individual case, in particular with the Federal Data Protection Act of 09/25/2020 (DPA), in force as of 09/1/2023, and the European Regulation No. 2016/679 (General Data Protection Regulation or GDPR).  

Please read this Policy carefully before providing any personal data to Altiqa SA. 

If you provide any personal data of other people (such as family members, colleagues, etc.), please ensure that they are aware of this Policy and only provide their personal data if you have been authorized to do so. 

In this Notice, personal data means any information that identifies or can reasonably be used to identify a natural person concerned; processing means any operation relating to personal data, namely the collection, recording, storage, use, modification, communication, archiving, deletion, or destruction of data, whether on paper or electronically.  

WHO WE ARE - DATA CONTROLLER 

The Data Controller of your personal data is Altiqa SA (CHE-103.921.078), Via Nassa 21, CH - 6900 Lugano, tel. +41 091 911 98 20, compliance.lugano@altiqa.group (hereinafter, the Data Controller or the Company or Altiqa SA), to which you may address any questions regarding the processing of your personal data or the protection thereof.  

The updated list of Data Processors, i.e., those who process personal data on behalf of the Data Controller, is kept at the Company's registered office.  

OBJECT AND PURPOSE OF DATA PROCESSING 

In order to be able to provide and bill for its services, the Company needs to have the personal data of its Clients, as well as those of certain individuals and legal entities related to them.  In particular, the personal data that the Company processes include:  

• name/surname and contact information (e.g., address, telephone number, e-mail address, etc.) of the Client and its family members, respectively, when the Client is a legal entity, name, surname, and contact information of the Client's shareholders, directors, managers, beneficial owners, employees, etc; 
• other identifying and background information voluntarily provided or collected as part of the customer registration process, e.g. job information, nationality, denomination, etc; 
• financial information, such as bank details, salary and other income sources, etc; 
• information related to communications sent to Customers in electronic form, such as the use of advertising e-mails. 

Personal data obtained, either directly from Company’s employees or from third parties, will be used, in compliance with the applicable regulations and without prejudice to the obligations of confidentiality and professional secrecy, solely for purposes related to the diligent execution of the mandate received, thus excluding any use that is different from and in conflict with the interests of the Client.  

This data will also be processed for the purposes required under the Federal Law on Combating Money Laundering and Terrorist Financing (AMLA) and related ordinances. 

The processing of personal data is not subject to the consent of the data subject insofar as it is necessary for the performance of a contract to which the data subject is a party (e.g., as part of the proper maintenance of the Client's complete file) or for the performance of pre-contractual measures taken at the request of the data subject or to fulfil a legal obligation to which the data controller is subject. 

NEWSLETTER 

The Company may use your name and e-mail address to send you publications, notices, updates, invitations to events, and other information via e-mail; in this regard, the Company will ask for your prior consent, except where it has received your contact information as part of the provision of its services and you have not concurrently declined to receive such promotional communications. If you no longer wish to receive promotional communications from the Company, you may notify the Company at any time.

WEBSITE & COOKIES

The personal data that the company processes, when you fill out the contact form on the website are: 

• Full name; 
• Email address; 
• Postal address; 
• Phone number. 

This personal data is used only to respond to requests contained in the contact form. 

When you visit this website, the Company automatically collects and stores log data and device-specific information for a limited period, including information on website usage, IP address, dates and times of access, information on hardware and software used for access, and other similar information. The Company processes such data to the extent necessary for the operation, maintenance and improvement of the website. 

This website uses Google Analytics, a service of Google LLC, USA, which monitors and records how the website is used. Google Analytics works by placing small text files, so-called cookies, on the device with which you navigate. Cookies records information about the number of visitors of the website, the frequency of the visits and their duration. This information is processed in aggregate and anonymous form. Google Analytics integration is in principle done by anonymizing IP addresses. Google is subject to both the Swiss-US Privacy Shield and the EU-US Privacy Shield. 

You can refuse the use of cookies by selecting the appropriate setting on your Internet browser, as well as through the appropriate banner that appears on your screen when you access the website. Please note, however, that this may affect the functionality of the website. 

To obtain further information about the purposes and methods of use of cookies installed by this website, please click here. 

TO WHOM THE DATA ARE TRANSMITTED (DATA PROCESSORS)

In order to ensure the provision of its services, in some circumstances the Company may transmit your personal data to service providers used by the company to carry out their professional assignment entrusted to it or to which it has outsourced certain support services such as e.g. IT. Any data transmissions take place only to the extent of express consent or in order to comply with legal and regulatory provisions, and the data processors are contractually committed to the Company to ensure the same security standards observed by the Company. 

TRANSFER OF DATA ABROAD  

To the extent that processing under this Policy is necessary and in order to ensure the provision of its services, the Company may pass on your personal data to trusted third parties located abroad. This may also take place in countries that do not guarantee a level of data protection fully equivalent to that provided by Swiss and/or European law; nevertheless, the third-party processors have committed themselves, through private agreements signed with the Company, to ensure adequate data protection.  

DATA RETENTION TIME

La Società conserva i dati personali per il tempo necessario al conseguimento delle finalità per cui sono stati raccolti e finché sussiste un legittimo interesse privato o pubblico alla conservazione degli stessi, ad esempio ai fini dell’esecuzione del contratto, al fine di far valere in giudizio i propri diritti o per scopi di archiviazione e sicurezza informatica. La Società conserva inoltre i dati personali dei propri Clienti se e fino a quando ciò sia richiesto in virtù di un obbligo legale, ma non oltre 10 anni dalla cessazione del rapporto contrattuale.  

RIGHTS OF THE PERSON CONCERNED  

In relation to their personal data, Customers have the right to obtain confirmation from the Company that processing is taking place or not. 

In connection with the processing of personal data, insofar as this is provided for by the concretely applicable regulations, Customers have the following rights: 

• Right of access to their personal data, including information about the purposes pursued by the processing, the categories of data collected, and the persons responsible for processing them; 
• Right to update, rectify and supplement processed personal data;  
• Right to restrict the company's personal data processing activities, as well as deletion of such data in the event of opposition to processing, withdrawal of consent, unlawful processing, or if the data are no longer necessary for the purposes for which they were collected and there is no obligation to retain them; 
• right to file a petition, in accordance with applicable regulations, to the competent supervisory authority (in Switzerland the Federal Data Protection and Information Commissioner); 
• Right to the release of certain personal data for the purpose of transfer to another entity; 

If the Client decides to revoke his/her consent, the Company may still process the personal data collected up to that point, to the extent required or permitted by law.  

HOW PERSONAL DATA ARE STORED (SECURITY MEASURES)

Customers' personal data are processed with suitable and proportional technical and organizational tools in paper, electronic and/or telematic form, in such a way as to ensure their confidentiality. Specific security measures are observed to prevent loss, unlawful, unauthorized, or incorrect use of processed personal data.  

LINKS TO OTHER WEBSITES 

This website may contain links or references to other websites. Please be aware that the Company does not control the content of such websites and the processing of personal data carried out by them.