Privacy Statement of Swiss International Advisory Group AG
Valid from: May 2020
1. General
2. Collection of personal data
3. Legal bases
4. Use of data
5. Disclosure of data to third parties
6. Cookies and Google Analytics
7. Use of plugins
8. Your data protection rights
9. Protection of personal data and transmission of data on the internet
10. Retention period for personal data
11. Ongoing adaptation of the Privacy Statement
1. General
The provisions of Swiss data protection law are strictly complied with. Any data of yours that are provided to us are handled in the strictest confidence and protected against unauthorised third party access. We take it as a matter of course that your data should be handled responsibly and that your privacy should be protected. Where we collect data from users in the European Union, these personal data are stored and processed in accordance with the EU General Data Protection Regulation.
This Privacy Statement explains to you which data are collected, how this occurs and for which purposes as well as the rights available to you in this regard.
2. Collection of personal data
The data that we receive are stored after anonymisation and used in order to carry out particular assessments, such as for example generating visitor statistics. This helps us to improve our website and our service range.
Whenever our website is visited, data and information from the accessing computer are automatically stored in our system's log files or with a third party. The information includes in particular the following:
- information concerning the browser type used;
- the user's operating system and the IP address of the accessing computer;
- the date and time of access;
- the name and URL of any downloaded file;
- the address of the referring page.
3. Legal bases
This Privacy Statement is governed by Swiss law, including in particular the provisions of the Swiss Data Protection Act (DPA). Where applicable, it also takes account of the provisions of the EU General Data Protection Regulation (GDPR).
4. Use of data
Data are stored and processed in order to be able to perform our contracts concluded with customers. The purpose of such processing depends primarily on the type of service that we provide to the customer. We use any data that we store in relation to your visit to the website in order to optimise our online presence.
5. Disclosure of data to third parties
In some situations, we pass on personal data to trusted third parties where this helps to ensure the provision of more efficient and higher value products and services and is in the interest of the data subject. Recipients of data are obliged under contract to protect the data entrusted to them.
Data may be passed on to third parties in particular in the following circumstances:
- third parties that provide support to us in relation to the provision of products and services or that offer their own services on a professional basis (e.g. lawyers, tax advisors, telecommunication services providers, insurers);
- enforcement authorities or other governmental and supervisory authorities (e.g. FAOA, FINMA) and other third parties, where necessary to ensure compliance with applicable laws and regulations.
6. Cookies and Google Analytics
Our website uses cookies, unless you have disabled this function within your browser or email program. As a result, we automatically collect certain types of information whenever you visit our website. Cookies are simple text files that are stored on your computer and that make it more pleasant for you to use our services. These data enable us to make our website even more user friendly and effective. Unless you have objected to the usage of cookies, we automatically receive information concerning your browsing patterns on the website.
This website uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer and make it possible to analyse what you do on the website. The information stored by the cookie concerning browsing patterns is normally transferred to one of Google's servers in the USA and stored there. The IP address transmitted from your browser in connection with Google Analytics is not combined with other data held by Google. In addition, we have expanded Google Analytics on this website by adding the code "anonymizeIP". This guarantees that your IP address is masked so that all data are collected anonymously. Only in exceptional cases will the full IP address be transferred to one of Google's servers in the USA and abbreviated there.
Google will use this information on behalf of the operator of this website to analyse your use of the website in order to compile website activity reports and provide additional services associated with website use and Internet use to the website operator. You can prevent cookies from being stored by configuring your browser software accordingly; please note, however, that if you do this, you may not be able to use all of this website's features to the fullest extent.
Furthermore, you can prevent the data generated by the cookie and related to your use of the website (including your IP address) from being collected and processed by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. An opt-out cookie will then be stored, which prevents the future collection of your data when visiting this website. The opt-out cookie only applies in this browser and only to our website and is stored on your device. If you delete the cookies in this browser, you must store the opt-out cookie again.
We also utilise Google Analytics to analyse data in DoubleClick cookies and AdWords for statistical purposes. If you do not wish this to occur, you can disable this feature via the Ads Settings manager (http://www.google.com/settings/ads/onweb/?hl=en).
We utilise Google Analytics, including the functions of Universal Analytics. Universal Analytics enables us to analyse the activities on our web pages across multiple devices (e.g., in case of access via laptop and later via a tablet). This is made possible by assigning a pseudonym to each user. This type of assignment takes place, for instance, if you register for a customer account or log into your customer account. However, no personal data are passed on to Google; even if Universal Analytics adds more functions to Google Analytics, this does not mean that it involves any restriction to data protection measures, such as IP masking or the browser add-on.
7. Use of plugins
We use so-called plugins on our website from social networks such as LinkedIn and YouTube. These can be recognised by the corresponding symbols used. These plugins enable us to offer specific functions from the relevant provider or to make them readily accessible to you. If you enable these plugins by clicking on them, the operator may register the fact that you are on our website and can use this information for its own purposes.
Our website uses functions from the network LinkedIn. The provider is the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access one of the pages on our website containing LinkedIn functions, a connection to LinkedIn’s servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click on LinkedIn's "Recommend” button and you are logged in to your LinkedIn account, LinkedIn is able to associate your visit to our website with you and your user account. Please note that as the provider of these web pages, we have no knowledge of the content of the data transferred or of how they are used by LinkedIn.
More information on this topic is available in LinkedIn’s Privacy Policy at: https://www.linkedin.com/legal/privacy-policy
Our website uses plugins from the website YouTube, which is operated by Google. The operator of the site is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit a page featuring a YouTube plugin, a connection is established with the YouTube servers. As a result, the YouTube server is informed which of our pages you have visited.
If you are also logged into your YouTube account, you enable YouTube to associate your surfing behaviour directly with your personal profile. You can prevent this from happening by logging out of your YouTube account.
Further information on how user data are used can be found in the YouTube Privacy Policy at:
https://www.youtube.com/intl/en-GB/about/policies
8. Your data protection rights
You have the following rights according to law. If you ask to exercise any of your rights, please provide evidence of your identity with appropriate official identification in order to ensure that we do not issue data to unauthorised persons.
Please submit your requests in writing to the following address:
Swiss International Advisory Group AG
Data Protection Officer
Matthofstrand 8
6005 Lucerne
Access
You can ask whether, to what extent and for what purpose we are collecting or processing personal data relating to you. In particular, you have the right to access the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, and – at least in those cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Rectification
You can obtain from us the rectification of your data if you consider that the data are either incorrect or incomplete.
Erasure
Subject to the prerequisites set forth below, you can obtain from us the erasure of your data without undue delay, unless we are obliged by law to retain the data:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw your consent on which processing was based and there is no other legal basis for processing;
- you object to processing and there are no overriding, legitimate grounds for processing.
- the personal data have been processed unlawfully.
Restriction of processing
Where (any of) the following prerequisites are met, you may obtain the restriction of processing of personal data relating to you:
- you contest the accuracy of the personal data relating to you, for a period enabling the controller to verify the accuracy of the personal data;
- processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- we no longer need the personal data for the purposes of the processing, but the data are required by you for the establishment, exercise or defence of legal claims;
- you have objected to processing, pending the verification whether the legitimate grounds of the controller override those of your own.
Data portability
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another person, where
- the processing is based on consent or on another contract and
- the processing is carried out by automated means.
Automated individual decision making
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you.
Right to withdraw consent
You have the right to withdraw consent previously provided by you to the processing of your personal data for any specific purpose(s). Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
9. Protection of personal data and transmission of data on the internet
We implement appropriate technical and organisational measures to protect your data against accidental or intentional interference, full or partial loss, destruction, unauthorised processing or unauthorised third party access. Our security measures are regularly reviewed, continuously enhanced in line with technological development and adjusted in line with general legislative requirements.
Any persons who have access to your data are obliged to treat this information in confidence. In order ensure enhanced protection for personal data, we may use processes such as pseudonymisation, redaction and anonymisation.
For security reasons and in order to protect transfers of confidential data, such as for example enquiries submitted by you to us as the website operator, our website uses SSL encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and from the padlock symbol in your browser line.
If SSL encryption has been enabled, the data that you transmit to us cannot be intercepted by third parties.
Please note in relation to data security that confidentiality cannot be guaranteed in the event of unencrypted email communication. There is a risk that third parties may be able to intercept the content of unencrypted emails and the files thereby sent. If we receive any unencrypted emails, we shall construe this as consent to contacting you also in this manner.
Please also note that the internet is an open network accessible to any person, and is thus not in principle a secure environment. Although individual data packages are generally speaking transmitted in encrypted form, this does not apply to the sender and the recipient. In addition, it is possible that data may be transferred to a foreign country, and thus also to a country with a lower level of data protection that Switzerland, even if the sender and the recipient are situated in Switzerland. All liability is declined in relation to data security during transmission over the internet.
10. Retention period for personal data
Your personal data will be retained by us for as long as necessary to provide our service (such as for example for special offers), to fulfil contractual claims and/or to comply with a statutory duty. This includes in particular the duration of the overall active business relationship. In addition, your data are stored in accordance with statutory retention and documentation duties. Specifically, data are retained in order to be able to defend against any claims brought against our company (during the limitation period). As soon as the retention of your personal data is no longer necessary, they will in principle be erased or anonymised as far as possible.
11. Ongoing adaptation of the Privacy Statement
It may be necessary to amend this Privacy Statement as a result of the further development of our website and our range of services, any adjustment to our internal data protection rules or any changes in statutory or administrative data protection requirements. The relevant up-to-date Privacy Statement may be downloaded from our website and printed out at any time.