TRUSTNET

PREAMBLE

This declaration is prepared following the entering into legal application of the new Data Protection Act (nLDP) as of 1 September 2023.

This data Privacy Policy (hereinafter referred to as ‘Privacy Policy’) is a separate provision of the mandate contract. Clients of our company are made aware that it is a unilateral declaration without any contractual scope.

PRIVACY POLICY

1. The company Trustnet SA, with registered office at Corso Elvezia 16, 6900 Lugano, is responsible for the processing of personal data in accordance with this Privacy Policy.

2. We process personal data (i.e. data enabling the direct or indirect identification of natural persons) that we collect ourselves or receive from customers or third parties within the scope of the mandate we have been given. Some personal data are provided to us by customers or third parties in the course of correspondence, telephone or e-mail contacts with which our services are requested. This may be their name, contact details or information on their personal, family, assets and/or employment situation. During the execution of the mandate, we also process the personal data we collect by corresponding with customers and also with third parties (in particular counterparties, administrative offices, authorities, correspondents, their respective employees or other contact persons). Furthermore, we collect certain personal data ourselves by taking them from public registers, databases or websites.

3. The processing by us of the types of personal data described is aimed in particular at the due diligence, performance, documentation and invoicing of our services.

4. To achieve these objectives, it may be necessary to transmit personal data to the following categories of recipients: external service providers (including IT maintenance services), counterparties and their legal representatives, business partners or others with whom we may need to coordinate services, as well as administrative offices, banks and authorities.

5. We retain personal data for as long as necessary to carry out the mandate, but in any case during the period of retention or reporting required by law, or as long as there is an overriding public or private interest. We take appropriate and proportionate measures to protect personal data against loss, unauthorised modification or unlawful access by third parties. If customers provide us with personal data via third parties (e.g. their employees or other contact persons), it is up to them to inform us comprehensively about the data processing carried out by our company and other service providers or external parties (e.g. in a data protection declaration for their employees).

6. We would like to emphasise that we use external IT service providers and cloud service providers with servers in Switzerland to execute the mandate. In these cases, we use certain IT services or means of communication that may involve data security risks (e.g. e-mail and video conferencing). If customers wish us to take special security measures, please let us know.

7. The above-mentioned objectives are based on a legitimate interest in the processing of personal data. Some processing is also necessary to fulfil our contractual obligations towards customers. The same applies to legal obligations to which we are subject, e.g. the obligation to retain documents.

8. Customers have, in particular, the right to obtain information on their personal data recorded, to know the purpose for which they are stored, to rectify them, to delete them, to restrict their processing, to object to their processing, and to appeal to a supervisory authority. Customers also have a right to the transmission or portability of data. Note, however, that these rights are subject to conditions and exceptions. To the extent that the law permits or requires it, certain requests may be refused. Therefore, we may or may have to retain personal data or continue to process them otherwise for legal reasons, despite a request for deletion or restriction of data processing.

9. This declaration does not require the formal consent of customers, their employees or other contact persons. This declaration only constitutes information on the nature, scope and purpose of the data processed by Trustnet SA.

10. Trustnet SA reserves the right to unilaterally change the content of this declaration at any time and without prior notice. We therefore advise customers to regularly consult the data protection declaration on our website at trust-net.ch.

COOKIES

The web pages use cookies. They serve to make the service simpler and more user-friendly. We only use ‘language session cookies‘ (essential) . They are deleted automatically after the visit.

When you access the private area, several cookies are also set to save your login information and screen choices. Login cookies last for two days, while screen option cookies last for one year. If you log out of your account, your login cookies will be removed.

ANALITYCS

Our site does not store any statistics cookies and does not retain any specific information about the user (users profile, IP address, pages visited, etc.).

Data Security

We take appropriate technical and organisational security measures to protect your personal data from misuse and unlawful access, such as the dissemination of directives, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and data transmissions.

Google Maps

Our site does NOT use Google Maps (API) from Google Inc. but only an embedded map for the purpose of displaying geographical information. Through this service, we can show you where we are and make it easier for you to find your way around. This is done regardless of whether Google provides a user account, to which you have logged in, or whether there is no such account. If you are logged into Google, your data is assigned directly to your account. If you want to avoid this allocation to your Google profile, you must log out before activating the button. Google stores your data (even if you are not logged in as a user) as user profiles and analyses them.

Responsible entity and contact

If customers, their employees or other contact persons have questions or wish to assert their data protection rights or those of the persons concerned, they can contact us at contact@trust-net.ch or write to us at the company address:

Trustnet SA

Corso Elvezia 16
CH – 6900, Lugano