BG Valeur SA, Via Nassa 3, 6900 Lugano, Switzerland (the “Company”), collect Personal Data (as defined below) in compliance with the applicable law and regulations, in particular the Swiss Federal Act on Data Protection (“FADP“). BG Valeur is not offering any service in the EU as well as monitoring any behaviour through its webpage, therefore the General Data Protection Regulation (EU/2016/679) (“GDPR“) shall not be considered as applicable. However, knowing the importance of data protection, the Company is not only applying the FADP, but also the GDPR principles on a free will basis. Therefore BG Valeur is already applying the FADP as much as possible in a GDPR compliant way, already implementing the value of the revised FADP, which is not in force yet.
Pursuant to the FDAP, the following capital terms shall have the meaning indicated here below:
“Personal Data” means any information relating to an identified or identifiable natural or legal person;
“Processing” means any operation or set of operations, performed whether or not by automated means which are applied to Personal Data or sets of Personal Data, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Navigation data” means any data which computer systems and procedures software preceded to the operation of this site, acquire, during their normal exercise, some personal data whose transmission is implicit using Internet communication protocols. This category includes: IP addresses, URI/URL (Uniform Resource Identifier/Locator), time of request, type of request, outgoing packet size, server status of response (received, error, etc…) and other parameters related to the operating system.
The Data Controller is BG Valeur SA, Via Nassa 3, 6900 Lugano, Switzerland. Due to its activity, which do not include any processing of Personal Data if not limited to Navigation Data or data required by law, the Company has not appointed any Data Protection Officer.
Purposes, legal basis & data retention
The purpose of collection of Personal Data is limited to the website browsing and contact form. The legal basis for this Processing is the private legitimate interest of the Company, provided that the Company’s interest is limited to the activities strictly necessary for site operation and platform browsing services and therefore not overriding the interests of the data subject taking into consideration his reasonable expectations based on the relationship with the Company. The data retention will last the amount of time required for the navigation on the website, but in any case not more than one year.
What types of personal information do we collect?
We collect different information depending on how you use the site and how you interact with us.
The Company collects personal data on different ways:
- By visiting the web site we collect data which include:
- Technical data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the site.
- By requesting a contact with us, we ask you to provide data which include:
- Identity information, such as name, mail, title;
- Contact data, such as address and email.
Our site is not intended for monitoring any Personal Data or storing any ‘special categories’ of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information.
How we collect personal data
Different personal data is collected in different ways.
a) Personal data you provide to us
- When you ask us to contact you through our webpage, you will provide us with the information required. This data is collected via direct solicitation.
- You will also provide us with personal data when you correspond with us, and if you apply for a position with the firm.
- When you sign up to one of our mailing lists, you will provide us with your contact information, IP address, and your marketing and communications preferences.
b) Personal data we collect automatically
- As you use the site, we will collect certain technical data including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet. We do not use any tracking cookie and we are not monitoring your behaviour within our web side.
Who the collected data will be communicated to?
We will only disclose your personal data where we are required to do so to comply with our legal or regulatory obligations; where we need to do so for business management or administration purposes; or because you have asked us to. This is likely to include:
- within the Company;
- to third parties who process your personal data on our behalf (such as IT systems providers and other service providers);
- to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation.
Does the Company transfer data to a third country and/or to international organisations?
Should we transfer your data outside Switzerland or the European economic Area to a country which Switzerland or the European Commission does not deem to have adequate data privacy laws, we will ensure that such transfer(s) are in accordance with applicable data privacy laws.
How we protect your personal data
The safety of your Personal Data is important to us, and we use various technical and organization measures to ensure that your data is secure.
We are committed to safeguarding and protecting Personal Data and maintain appropriate technical and organizational measures to protect any Personal Data provided to us from accidental or unlawful destruction, loss, alteration, or unauthorized disclosure.
7. Data subject rights
Under Data Protection Law, data subjects have a number of rights with regard to their personal data. They have the right to request from us access to and rectification or erasure of their personal data, the right to restrict or object to processing, as well as in certain circumstances the right to data portability.
If a data subject has provided consent for the processing of their data, he or she has the right (in certain circumstances) to withdraw that consent at any time.
Any data subject wishing to exercise any of the above rights should email us at: firstname.lastname@example.org
We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests. We also reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning access to personal data, and for any additional copies of the personal data requested from us.