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Data Protection

Information on data protection

This disclosure indicates the nature, scope and purpose of the collection and use of personal data by Capital Trustees SA (hereafter “Capital”) within the framework of its professional activity and, in particular, with regard to services and offers of Capital through its website. Capital complies with the provisions of the Federal Data Protection Act of 19 June 1992 (“LPD”) and, where applicable, of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, as well as the free movement of such data.

Right to information

Anyone has the right to request information, to correct incorrect data, to block or delete data concerning him, if there are no legal obligations to keep the data or if these are not necessary for the execution of the contract. Visitors to the www.capitaltrustees.ch site, as well as candidates who will forward their personal data through the site, have the right to withdraw their consent, as well as the right of appeal. In case of questions, modifications, revocation or cancellation, please contact our data protection officer directly:

Capital Trustees SA
Security Officer
Via Somaini 10
6900 Lugano
info[at]capitaltrustees.ch

Personal data

The term “personal data” refers to all information relating to an identified or identifiable person (Article 3 LPD).

User data, cookies, Google tools, links, social plugins

“User data” is that personal data that Capital requires in order to ensure access to its site or to sections thereof; they vary depending on the service used. In particular, Capital withdraws the user data at the time of registration (for clear identification) for electronic services (usually surname, name, address, email), and during each access to the www.capitaltrustees.ch site or an electronic service of Capital (generally the name of the site consulted, the file, the date and time, the volume of data transmitted, the success of the consultation, the type and version of the browser, the URL of reference, the IP address and the requesting provider). User data is processed, stored and used by Capital, to the extent necessary for the use of any services provided electronically. During the use of the services, the access data (date / time) and the associated user data are recorded in a file. Capital reserves the right to verify the user data retrospectively if, on the basis of specific indications, illegal use is suspected.

Purpose and methods of treatment

Capital processes personal data that users provide via the site in accordance with the rules of the European Data Protection General Regulation (GDPR) and the Federal Data Protection Act (LPD), for the following purposes:

  1. For the provision of electronic services, for sending newsletters, or for marketing activities, based on your consent. The consent can be revoked at any time. A revocation of consent does not affect the lawfulness of the processing of data in the period prior to the revocation.

2.To meet contractual obligations (Article 6 paragraph 1b of the GDPR)

The data are processed to provide services, including electronic, in the context of the execution of specific contracts with users. Further details about the purposes of data processing are available in the relevant documents and contractual conditions.

To satisfy legitimate interests (Article 6 paragraph 1f GDPR)

Capital may process user data for the purpose of pursuing legitimate own or third party interests. For example, for the assessment of legal claims and defense in legal disputes; IT security guarantee; crime prevention, etc.

  1. On the basis of the provisions of law (Article 6 paragraph 1c of the GDPR) or in the public interest (Article 6 paragraph 1e GDPR)

Capital, by virtue of its business, is subject to various legal obligations and regulatory requirements (eg under the Federal Act on the fight against money laundering and the financing of terrorism in the financial sector). The purposes of the processing can therefore include controls on identity and age, the prevention of fraud and money laundering and the fulfillment of the control and information obligations under the tax laws.

Transmission.
Capital transmits data internally to comply with its contractual and legal obligations. All employees who have access to confidential data or information are subject to the obligation of secrecy: in this case it is professional secrecy depending on the sector of activity (eg banking secrecy according to Article 321 CP) or a written confidentiality agreement regarding personal data and information. Service providers appointed by Capital may also have access to the data for the purposes indicated, if they guarantee an adequate level of confidentiality. Regarding the transfer of user data to recipients outside of Capital, it is necessary to observe Capital can ‘transmit personal information only if the legal provisions require it, if there is a specific contractual provision, or if the user has provided appropriate consent. The transfer of data to institutions or states outside Switzerland and the European Union (known as third countries) takes place to the extent that this is necessary to comply with contractual or legal obligations, or if the user has given his consent . In the event that the provisions relating to data protection of the cds. third countries are not equivalent to Swiss and / or European standards, Capital concludes an “agreement on data processing” with the recipient of the data.

Storage.
Capital keeps all personal data electronically on its servers located in Switzerland. User data is kept only for the time necessary to satisfy the offers of electronic services, that is, until the moment when the user expresses his will to renounce the use of electronic offers. As a rule, Capital does not retain user data for visitors to www.capitaltrustees.ch.

Cookies.
When a user visits www.capitaltrustees.ch and the online offers contained therein, one or more cookies are installed on his computer. The cookie is a text file that is installed on the user’s computer in order to allow an analysis of the use of the site. Generally, the information obtained from the cookie about the use of this website (including the IP address) is transferred to a server and stored there.
Capital uses cookies to improve the comfort and quality of online offers, e.g. recording user parameters. The use of electronic offers can also be done without cookies. You can disable the registration of cookies on the browser, limit them to certain websites or set the browser to be notified before a cookie is registered. Cookies can be deleted from the hard disk of the computer to your liking, by selecting the parameters of the data protection function of the browser. In this case, the functions and ease of use of electronic offers may be limited.

Integration of links and third-party services.

Among the electronic offers Capital offers third-party services such as, for example, videos on YouTube, Google Maps or charts. This assumes that these providers receive the user’s IP address.

Capital endeavors to use only services offered by providers that use the IP address solely for the delivery of content. Capital declines all responsibility for the collection and processing of personal data by third parties. Any link to third party services involves the application of the data protection provisions of such third parties.

Google Analytics
Capital uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies and typically stores them outside the EU / EFTA area. Google uses this information to evaluate the use of the website on behalf of Capital and to draw up reports on website traffic and internet usage. In addition, Google may transmit such information to third parties, where required by law or when such third parties process data on behalf of Google. The IP address transmitted by the browser in the framework of Google Analytics will not be associated with other data held by Google. The user can refuse to register cookies (see “cookies” above), and prevent the transmission to Google of data recovered from cookies (including the IP address) during his visit to the website and also the processing of such data from Google by downloading and installing the browser plugin from the following link: https://tools.google.com/dlpage/gaoptout?hl=de

Social plugins

The social network plugins, managed exclusively by Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) and Twitter (Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA), are marked with the corresponding social network logo. When a user accesses a website containing one or more plugins, the user’s browser creates a direct connection with the social network servers. The content of the plugin is transmitted directly from the social networks to the user’s browser and is also subsequently integrated into the website. Thanks to the integration of the plugin, social networks receive the information that the user has consulted on the corresponding page of the website. If at the time of consultation of the site the user is connected to a social network, the latter can attribute the visit to his / her profile. When the user clicks on a button, his browser directly transmits the information corresponding to the social network, which stores it. Regarding the purpose, the scope of data collection, the processing and additional use of data by social networks, as well as the user’s rights in this regard and the possibilities of setting up to protect his privacy, Please consult the data protection provisions of Facebook and Twitter. To avoid that social networks collect data concerning him on the websites visited, the user must log out (logout) from social networks before visiting the site.

Opposition right
For reasons related to your particular situation, every user has the right to oppose at any time the processing of their personal data. In the event of opposition, the user’s personal data will no longer be processed, unless Capital proves legitimate reasons or interests for the processing that exceed the interests, rights and freedoms of the user. In such cases, Capital will not be able to provide services and maintain a business relationship with the user. The opposition must not be carried out in a specific form and should preferably be addressed to:

Capital Trustees SA
Security Officer
Via Somaini 10
6900 Lugano