PRIVACY POLICY FOR WEBSITE

The website https://www.fiduciariaortelli.ch/en (“Website”) is the exclusive property of FIDUCIARIA ORTELLI, 2 Greina Street, CH - 6900 Lugano (“Firm” or “we”).

This Website Privacy Policy, together with any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully.

1. Website Users

This document concerns data subjects ("Data Subject", "you", "user") whose personal data we collect when you act as a user of our websites or provide your information as explained below.

This Privacy Policy is based on the Swiss Federal Act on Data Protection ("FADP") of 25 September 2020 (Status as of 1 September 2023), as amended.

https://www.fedlex.admin.ch/eli/cc/2022/491/en

The Company is authorised to process personal data in accordance with this law and the regulations of the Federal Data Protection and Information Commissioner.

https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

2. Personal data

Under the FADP, personal data is defined as "any information relating to an identified or identifiable natural person".

Under the FADP, the data controller is the entity that decides on the purpose and content of a data file. The Firm is the data controller ("Data Controller").

3. Personal data that we collect with your consent

Personal data is information that you have made public or that you provide to us by filling in forms in writing, by email, through our websites, by registering for our events. This includes information provided when filling out our contact form on our website, to participate in our events, to receive newsletters, to request materials or information or to request services.

We collect the following categories of information:

• name(s), surname(s), address(es), email, telephone number(s);
• information about our relationship with you, correspondence.

If you contact us, we may keep a record of that correspondence.

Browsing data is acquired by the computer systems and procedural software used to operate this Website during normal operation. This is personal data whose transmission is implicit in the use of Internet communication protocols. This category includes IP addresses, URI/URL (Uniform Resource Identifier/Locator) addresses, the time of the request, the type of request, the size of the outgoing packet, the status of the response provided by the server (received, error, etc.) and other parameters relating to the operating system.

4. How we collect personal data

Personal data is collected directly from you in a number of ways:

• that you provide to us;
• that you have made public; and
• that we collect automatically by sharing with other parties where necessary.

The personal data you provide to us may be collected in a number of ways. These include:

• directly through our Website;
• by emailing your CV to our team or through our emails;
• through the online form as part of our Website or a form provided to us in paper or electronic form or when registering for our events or newsletters; and
• by contacting us with enquiries or comments by telephone, email or post.

5. How we use personal data

We will process your personal data, in accordance with our obligations under the FAPD, for the following reasons:

• to provide you with the services you have requested;
• to comply with the FAPD or other regulations, for example on AML/CFT;
• for administrative purposes;
• to assess requests for information; and
• to provide information about us and our services.

If, at any time, you do not wish to receive further information about us and our services, please contact us by email privacy@fiduciariaortelli.ch.

Other personal information, such as, for example, information relating to the use of the Website (in particular: IP address of the user's device, unique identifiers of the user's mobile device, length of stay on the Site, services used, links and messages activated, etc.) are analyzed, in an automated and anonymous manner, exclusively to evaluate the introduction of new features, to improve the quality of the services offered and to optimize the usability of the Site. The Website does not process or transmit content or advertisements based on online behavior, nor profiles users or monitors the use of web resources or email. The Website does not sell, rent, exchange and/or lend Personal Data to third parties.

6. Sharing your personal data

We may disclose your personal information to third parties to comply with a legal or contractual obligation, or to enforce or apply agreements and contracts, or to protect the rights, property or safety of the Firm or others. This includes exchanging information with other companies and organisations for the purposes of operating this Website (web-design, maintenance and hosting), safeguarding or other legal requirements that we must comply with.

7. Websites

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. Protection of your personal data

The data collected from you will be processed on our servers in Switzerland. It may also be processed by organizations operating in the EEA engaged by the Firm and with which we have entered into data processing agreements. If we send personal data to a country that does not have adequate data protection legislation, nor it is considered an adequate country according to the adequacy assessment of Switzerland or the European Commission, we will ensure an adequate level of protection by using contracts accordingly, or we will act on the basis of the requirements of law, consent, performance of the contract, enforcement or application of legal claims, in accordance with the requirements imposed by the FADP. We may also use binding corporate rules, standard contractual clauses or ad hoc contractual clauses that establish that the data will be processed in accordance with the FADP.

9. Security of your information

To protect the privacy of the data and personally identifiable information transmitted by you through the use of our Website, we take physical, technical and administrative security measures. We update and test our security technology as required by law. We limit access to your personal data to employees who need to know it to provide services to you. We also train our employees on the importance of confidentiality and respect for the privacy and security of your data.

10. How long do we keep data

We keep your personal data in accordance with our internal data retention policy and, in general, according to the time periods required by law, i.e. ten years. This policy is reviewed and updated internally to ensure that data is not kept longer than necessary. We also check how and where to store data to ensure compliance with the obligation to store data securely. We process and store personal data to the extent that this is necessary to fulfill our contractual and legal obligations or for the purposes pursued by the processing, which means, for example, for the entire duration of the business relationship (from the initiation and execution of a contract to its termination) and even beyond, in accordance with legal obligations for record-keeping.

11. Disclaimer

The data published on our Website, of any kind, are never binding. We reserve the right to modify or update the information contained on the Website at any time and without notice. Our Firm is not responsible for Internet malfunctions, damage caused by third parties, data imports of any kind (viruses, worms, Trojan horses) or links to or from other websites. We have no control over the content and form of external web pages. We cannot guarantee the perfect functioning of hardware and software. In no event will our Firm be liable to you or any third party for direct, indirect, special or consequential damages of any kind arising from the use of the Website or any other website linked to it. Any liability for loss of income, interruption of business, loss of programs or other data in your computer systems is also excluded. The transmission of communications, documents and other information via e-mail is considered less reliable, safe and confidential than that via letter. We use modern identification technologies to combat viruses and spam. However, we recommend that you also use an antivirus and we decline all responsibility for any damage resulting from emails or their loss. We reserve the right to refuse emails with potentially dangerous attachments.

12. Communications by e-mail

The user is aware that (i) the use of e-mail does not guarantee the confidentiality and integrity of data in transit, (ii) many e-mail service providers are located or hold their data in countries that do not guarantee adequate protection of personal data, (iii) the use of the e-mail service may involve the transfer and storage of data in a country that does not guarantee adequate data protection. The user authorizes the Firm to transmit via ordinary (unprotected) e-mail documents and/or information, including those containing personal and/or confidential data, using the e-mail address provided by the user in response to requests from the user received by telephone or e-mail. The user, aware of the above risks, releases the Firm from any liability in the event of unauthorized access by third parties to documents and/or personal and/or confidential information transmitted or received by e-mail from the Firm.

13. Changes to the Privacy Policy

The Firm reserves the right to change this Policy from time to time. Such changes are effective upon posting on our Website. Your continued use of our Website or submission of personal information to the Firm will be deemed to constitute acceptance of the Privacy Policy and its changes.

14. Complaints, disputes

Pursuant to the FADP, as a data subject you have the following rights:

• to be informed if your personal data is being processed;
• to withdraw consent to the processing of data that you have previously given;
• to obtain the rectification of inaccurate or outdated personal data;
• to prevent the communication to third parties of personal data worthy of special protection;
• to request that the processing of data be blocked, that its communication to third parties be prevented or that the personal data be rectified or destroyed.

If you believe that we are not processing your personal data in accordance with this Privacy Policy and the FADP, please contact us at privacy@fiduciariaortelli.ch. We will respond within 30 days as required by law.

You can also contact

https://www.edoeb.admin.ch/edoeb/it/home/deredoeb/kontakt/anzeigeformular_betroffene.html

Federal Data Protection and Information Commissioner, Feldeggweg 1 CH - 3003 Bern.

Cookie Policy

What are cookies and how are they managed

Cookies are temporary markers, i.e. small text files that can be recorded on the hard disk of the computer and that can be used to determine whether a connection has already been made between the user's computer and the pages of the site.

The data obtained from navigation can be used, after specific and explicit consent of the user, also to read his/her preferences and to carry out web analytics activities in order to understand the behavior of the users and constantly improve the available services, as well as offer more appropriate content and in line with the interests of the public.

Cookies can be deleted at any time by changing the browser settings. Please note that this deactivation may slow down or prevent or limit access to certain services.

To learn more, visit, for example, the site allaboutcookies.org.

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Cookies used by this site

Technical cookies

Cookies necessary for the correct functioning of the site. They allow navigation of the pages, sharing of published content, memorization of the user's access credentials to make login to the site faster and to keep their preferences and credentials active while browsing.

Statistical and performance cookies

These cookies allow us to know how visitors navigate the site, which are the most and least visited pages, the time spent on the site by the average user, the number of visitors, the methods of arrival on the pages of the site. In this way, it is possible to evaluate and improve the functioning of the site and promote the production of content that best meets the needs of users. All information collected by these cookies is anonymous and not linked to the user's personal data.

Third-party cookies

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