PRIVACY POLICY
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Scope of Application
STUDIO FIDUCIARIO PAGANI SA (“SFP” or the “Company” or “we” or the “Data Controller”) operates under and is subject to Swiss data protection law, more specifically the Federal Data Protection Law (“LPD”) and the relevant regulations (OLPG and OCPD), as well as the General Data Protection Regulation (EU) 2016/679 ("GDPR"), when this latter is directly applicable.
SFP attaches great importance to the protection of personal data and people's privacy and undertakes to fully comply with the applicable laws and regulations.
This privacy policy is presented to those who, like you, visit our website www.studiopagani.ch (“You” or “User”) pursuant to articles 4, 5, 7, 8, 9, 10, 13 and 17 of the LPD, as well as articles 13 and 14 of the GDPR, to provide information on the processing of personal data by SFP.
Personal Data Controller
The Data Controller is Studio Fiduciario Pagani SA, A Swiss company having its registered offices in Corso E. Pestalozzi 3, CH 6900 Lugano.
Source and Categories of Personal Data processed
We primarily process personal data that we receive or collect from website visitors, as well as, at a later stage, from our prospects, customers and business partners, more specifically:
(i) personal identification and contact data, such as name, family name, nationality, date of birth, other identification data, such as social security numbers and tax codes, e-mail address, telephone and postal numbers;
(ii) banking and financial data, referrable to natural persons, only when necessary (for example with relation to payment activities and other banking activities;
(iii) other data and information deriving from contacts from You, correspondence, and other exchanges with us.
Furthermore, we may also process personal data that we have obtained from free-access sources (for example, websites or public registers such as the commercial register, etc.).
Purpose and Legal Basis of the Data Processing
We process your personal data, pursuant to Articles 6 GDPR and 31 LPD, to facilitate navigation of our website and provide you with information, more specifically, for the following purposes:
• to communicate with you, in particular to provide you with information about our services (including by sending a newsletter), or to process your requests
• to produce contents for our website, our social platforms and our services available to you, to evaluate and improve them
• to organize courses, seminars, events and webinars and report them or make them available on our website or social platforms
• for the implementation (including administrative tasks) of our contractual relationships.
We process your personal data for the purposes indicated above, depending on the situation, without limitation, upon the following legal bases:
• the processing of Personal data is necessary for the implementation of an agreement with you
• You have given your consent to the processing of your personal data
• the processing of personal data is necessary for compliance with a legal obligation
• the processing of personal data is necessary to protect the vital interests of the data subject (you) or of another natural person, including SFP - or
• we have a legitimate interest in processing personal data
Visiting our Websites, Receiving the Newsletter or Requesting a Demo
When You, as a User, access our website, our server collects information, IP address, date and time of access, name and URL of the downloaded file, type of browser used and other information from the operating system, a series of information about the user, stored in server log files, without leading to the identification of the you as User as a natural person. The collection of this information or data is technically necessary to display our websites and to ensure their stability and security. This information is also collected to improve the website and to analyze its use. The legal basis for the temporary storage of information and log files is our legitimate interest in increasing the functionality of our website. For further, information you can consult our cookie policy.
In addition, we collect the necessary information when you register on the website to receive our newsletters or to book a free demo. The legal basis for sending our newsletter or booking a free demo is your consent.
Processing of Personal Data by SFP
Your personal data is processed (i) directly by SFP employees, with manual and/or computerized means, according to instructions aimed at ensuring compliance with the applicable data privacy legal provisions; (ii) with relation to specific operations, externally, by third parties appointed as data controllers or, in any case, adequately instructed by SFP.
Communication of Personal Data to Third Parties
In addition to data transfers to recipients expressly mentioned in this privacy policy, we may - to the extent permitted and in accordance with the applicable data privacy legal provisions - disclose personal data to the following categories of recipients:
• Vendors to whom we have outsourced certain services (for example, IT and hosting providers, payment service providers, debt collection service providers, risk and compliance management providers, marketing and communications service providers, etc;)
• Service providers, subcontractors and other business partners
• Banks and insurance companies
• Tax consultants, auditors, lawyers, notaries and other SFP external professional consultants
• Administrative and judicial authorities
Transfer of Personal Data Abroad
Your personal data may be processed within Switzerland, the European Union or the European Economic Area (hereinafter "EU/EEA"), but may also be processed and transferred to a country outside Switzerland, the EU/EEA, for example in China, Panama, Hong Kong and the United States.
When we transfer data to third parties in a country without an adequate level of data protection, in accordance with Swiss privacy legislation, we guarantee an adequate level of protection through the use of corresponding contracts (e.g. with the use of so-called contractual clauses standards of the European Commission) or we rely on the legal justifications mentioned above.
Data Subject’s Rights
You, as a data subject, have the following rights under the DPA and the GDPR:
• the right to access your personal data (Art. 15 GDPR, Art. 8 LPD);
• the right to rectify your personal data (Art. 16 GDPR, Art. 5 LPD);
• the right to delete your personal data (Art. 17 GDPR, Art. 5 LPD);
• the right to object to the processing of your personal data (Art. 21 GDPR, Art. 4 LPD);
• the right to portability of your personal data (Art. 20 GDPR).
We can adopt legal restrictions available to us, for example if we are obliged to store or process certain data, if there is an overriding interest on our part, or if we need the data to assert our rights.
If the data processing is based on your consent, after having given it, you can revoke it at any time with future effect. However, this does not affect the lawfulness of the processing carried out on the basis of your consent before your revocation.
The exercise of these rights generally requires the data subject to clearly demonstrate his or her identity (for example, by means of a copy of an identity document).
Furthermore, every data subject has the right to assert his or her rights in court or to lodge a complaint with the competent data protection authority.
Security of Personal Data
We adopt appropriate security measures to maintain the necessary security of your personal data and ensure its confidentiality, integrity and availability, and to protect it from unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, disclosure or access unauthorized.
Personal Data Retention Period
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless retention for a longer period is required under applicable law or an applicable contractual obligation.
Changes to this Privacy Policy
The Data Controller reserves the right to modify this privacy policy at any time and to inform users of the website through publication on the website or through other means.
To exercise your rights or to obtain information on the protection of personal data, please contact us exclusively at the address specified below.
STUDIO FIDUCIARIO PAGANI SA
Corso E. Pestalozzi 3
6900 Lugano