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Privacy Policy

This is a courtesy translation of the Italian privacy policy. In case of any discrepancy, the Italian version prevails.

PRIVACY NOTICE

Dear Data Subject, Aurum Advisoring Snc has great respect for the privacy of Users. Any data provided by the User through the Site will be processed with the utmost care and with all the tools needed to guarantee its security, in full compliance with the legislation in force on the protection of data confidentiality.

Data Controller

The Data Controller is Aurum Advisoring Snc, Via San Gottardo 91, CH-6900 Lugano-Massagno.

Email address: aurumadv.ch@gmail.com

The data will be processed for the following purposes and services:

  • Contacting the User
    • Mailing list or newsletter and Contact form. Personal Data: surname; email; first name
    • Contact by phone. Personal Data: phone number
  • Management of User databases
    • HubSpot CRM. Personal Data: email; phone number; various types of Data as specified in the privacy policy of the service
  • Tag management
    • Google Tag Manager. Personal Data: Usage Data
  • Heat mapping and session recording
    • Hotjar Heat Maps and Recordings. Personal Data: Usage Data; Tracking Tools; various types of Data as specified in the privacy policy of the service
  • SPAM protection
    • Google reCAPTCHA. Personal Data: Cookies; Usage Data
  • Collection of privacy-related preferences
    • Cookie Solution by Usercentrics. Personal Data: Tracking Tools
  • Analytics
    • Personal Data: Cookies; Usage Data
    • Google Analytics. Personal Data: Tracking Tools
  • Displaying content from external platforms
    • Google Fonts. Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Methods and types of data collected

Data collected automatically. The computer systems and applications dedicated to the operation of this website acquire, during their normal operation, certain data (whose transmission is implicit in the use of Internet communication protocols) potentially associated with identifiable users. The data collected includes the IP addresses and domain names of the computers used by the users who connect to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system, the browser and the IT environment used by the user, the name of the internet service provider (ISP), the date and time of the visit, and the web page the visitor came from (referral) and left to.

Data provided voluntarily by the user. The voluntary and explicit sending of email to the addresses indicated in the various access channels of this site does not involve a request for consent and entails the acquisition of the sender’s address and data, which are needed to reply to requests, as well as any other personal data included in the message. Such data is understood to be voluntarily provided by the user at the time the service is requested. By entering a comment or other information, the user expressly accepts the privacy notice, and in particular agrees that the content entered may be freely disclosed to third parties as well. Conversely, specific summary notices will be shown or displayed on the pages of the site set up for particular services on request (forms). The user must therefore explicitly consent to the use of the data entered in these forms in order to send the request.

Place of storage: The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section containing details on the processing of Personal Data.

Retention period: Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period because of legal obligations or on the basis of the Users’ consent.

Cookies

The site uses cookies. The data collected through cookies may be used to access parts of the site, for statistical purposes, or to make the browsing experience more pleasant and more efficient in the future, by seeking to assess users’ behaviour and to adapt the content offered according to that behaviour. A dedicated cookie policy is available for further information.

Plug-ins

The site does not incorporate plug-ins and/or buttons for social networks intended to allow easy sharing of content on your favourite social networks. Such plug-ins are programmed so as not to set any cookies when the page is accessed, in order to safeguard users’ privacy. Cookies are set, if the social networks so provide, only when the user makes actual and voluntary use of the plug-in. Please note that if the user browses while logged in to the social network, they have already consented to the use of the cookies conveyed through this site when registering with the social network. The collection and use of the information obtained through the plug-in are governed by the respective privacy notices of the social networks, to which please refer.

Further information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and other information about Personal Data can be found in the section entitled “Methods and types of data collected” within this document.

The rights of users under the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their data within the limits of the law, including the following:

  • the right of access to Personal Data;
  • the right to object to the processing of their Personal Data (which also allows Users to request that the processing of Personal Data be restricted, that Personal Data be erased or destroyed, and that the disclosure of Personal Data to third parties be prohibited);
  • the right to receive their Personal Data and to transfer it to another data controller (data portability);
  • the right to request the rectification of incorrect Personal Data.

How to exercise these rights

Any request to exercise the User’s rights can be addressed to the Data Controller using the contact details provided in this document. Such requests are free of charge and the Data Controller will reply as soon as possible, providing Users with the information required by law.

Further information on processing

Legal action

The User’s Personal Data may be used by the Data Controller in legal proceedings, or in the stages leading up to possible legal action, to defend against abuse by the User in the use of this Website or of the related Services.
The User declares to be aware that the Data Controller may be required to disclose the Data by order of the public authorities.

Specific notices

At the User’s request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual notices concerning specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services it uses may collect system logs, that is, files that record interactions and that may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information on the processing of Personal Data may be requested from the Data Controller at any time using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website and also, where technically and legally feasible, by sending a notice to Users through one of the contact details in its possession. Please therefore consult this page frequently, referring to the date of last modification indicated at the bottom.

Should the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, where necessary.

Further information for users in the European Union

This section applies to all users in the European Union, in accordance with the “European Regulation 2016/679 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (GDPR)”  and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data are available in the section “Detailed information on the processing of Personal Data” within this document. Therefore, pursuant to Article 13 of the GDPR, we inform you of the following

Legal basis of processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

  • the User has given consent for one or more specific purposes.
  • the processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
  • the processing is necessary to comply with a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

It is in any case always possible to ask the Data Controller to clarify the actual legal basis of each processing operation and, in particular, to specify whether the processing is based on the law, provided for by a contract or necessary to enter into a contract.

Further information on the retention period

Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period because of legal obligations or on the basis of the Users’ consent.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract has been completed.
  • Personal Data collected for purposes relating to the legitimate interest of the Data Controller will be retained until that interest has been satisfied. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User’s consent, the Data Controller may retain the Personal Data for longer, until that consent is withdrawn. In addition, the Data Controller may be required to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period the Personal Data will be deleted. Therefore, once that period has expired, the right of access, erasure and rectification and the right to Data portability can no longer be exercised.

Rights of the User under the General Data Protection Regulation (GDPR)

Users may exercise certain rights with regard to the Data processed by the Data Controller.

In particular, within the limits provided by law, the User has the right to:

  • withdraw consent at any time. The User may withdraw consent previously given to the processing of their Personal Data.
  • object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent.
  • access their Data. The User has the right to obtain information about the Data processed by the Data Controller and about certain aspects of the processing, and to receive a copy of the Data processed.
  • verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.
  • obtain the restriction of processing. The User may request that the processing of their Data be restricted. In that case the Data Controller will not process the Data for any purpose other than storing it.
  • obtain the erasure or removal of their Personal Data. The User may request that the Data Controller erase their Data.
  • receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller.
  • lodge a complaint. The User may lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Users have the right to obtain information about the legal basis for the transfer of Data abroad, including to any international organisation governed by international law or set up by two or more countries, such as the UN, as well as about the security measures adopted by the Data Controller to protect their Data.

Details of the right to object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing at any time, free of charge and without giving any reason. If Users object to processing for direct marketing purposes, the Personal Data is no longer processed for those purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise these rights

Any request to exercise the User’s rights can be addressed to the Data Controller using the contact details provided in this document. The request is free of charge and the Data Controller will reply as soon as possible, and in any case within one month, providing the User with all the information required by law. Any rectification, erasure or restriction of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of those recipients if the User so requests.