Privacy Policy

1 Scope

This Privacy Policy informs you how and for what purposes Fidigit (Switzerland) Ltd, Swiss company of the Fidinam Group, and its Swiss subsidiaries (hereinafter "We" or "Fidigit") process your personal data (hereinafter "You").

List of the Swiss branch of Fidigit (Schweiz) AG:

Fidigit (Switzerland) AG Bern branch;
Fidigit (Switzerland) AG Basel branch;
Fidigit (Switzerland) AG Lucerne branch

"Personal data" means any data and information relating to an identified or identifiable natural person. This includes, for example, name, address, telephone number or e-mail address. This term does not include anonymised data or information whose content does not reveal the identity or essential circumstances of an identifiable person, such as the number of visitors to a website.

There are also so-called special categories of data ("sensitive data"). This includes data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic and biometric data for your unique identification, health data or data concerning your sex life or sexual orientation. We will only process such data - if at all - with your explicit consent, unless another legal basis requires such data processing.

We process personal data in accordance with the applicable data protection laws.

This Privacy Policy is intended to provide you with comprehensive information about the data processing we carry out and applies to all data processing by Fidigit, regardless of whether we receive your personal data online or offline, and regardless of the communication channel (such as company website, other company websites on the Internet, by telephone, e-mail, post or personal contact).

Depending on the type of data processing, Fidigit may be the data controller or may also assume the role of data processor.

The contact person for all questions relating to data protection is

Fidinam & Partners
Isabel Costa
Via Maggio 1
6900 Lugano

Phone: +41 91 973 17 31

E-mail: privacy@fidinam.ch

2 Data origin and data categories

We primarily process personal data that we receive or collect from our customers (including their employees, shareholders, directors, etc.), website visitors, service providers, banks and other business partners in the course of our business activities. In addition, we may also process personal data that we have obtained from publicly accessible sources (e.g. websites or public registers such as the commercial register, etc.). Finally, we may also have received your personal data from your family members, from our business partners, from official bodies and authorities or from other third parties.

The personal data we process includes, in particular, name and contact details (e.g. address, telephone number and e-mail address), identification and background information (e.g. passport number, ID number, language, date of birth, nationality, gender, religious denomination), political data, job title and business relationship, country of residence, geographical location, data relating to origin, family situation (e.g. marital status, number of children), usage data for payment purposes family situation (e.g. marital status, number of children), usage data for payment purposes (e.g. marital status, number of children), data on criminal proceedings, financial information for payment purposes (e.g. bank details), transaction data (e.g. payment instructions, investment instructions), user information such as login data, customer number, information on the use of our websites and information of any kind from correspondence, contacts and interactions (e.g. photos, videos and voice recordings) with us.

3 Purpose and legal basis of the processing

The content and information presented on our website is intended to provide you with general information about us as a company and about our services. However, it is also possible that your personal data may be disclosed by you when you use our website or collected by us for specific purposes. In addition, we as a company process data that you provide or transmit to us in other ways, e.g. by post, e-mail, telephone, as part of a business transaction or through personal contact.

Our data processing includes, for example, the collection, storage, transmission, deletion and other processing of your data. Only data that is necessary and appropriate for the intended purpose is processed.

Below we inform you about the purpose of our data processing:

3.1 In connection with our business activities

We process your personal data primarily in order to provide our services in connection with our business activities. In particular, we process your personal data for the following purposes:

to communicate with you, in particular to provide you with information or to process your requests. If you contact us by e-mail/contact form, you authorise us to reply to you via the same channel. Please note that unencrypted e-mails are transmitted via the open Internet, which is why it cannot be ruled out that they can be viewed, accessed and manipulated by third parties. We therefore ask you not to send us any confidential information by e-mail. We exclude - to the extent permitted by law - any liability that you may incur, in particular due to incorrect transmission, falsification of content or disruption of the network (interruption, overloading, unlawful interference, blocking);
to provide you with our services and our website and to evaluate and improve them;
organise and report on events and webinars or make them available on our website and social media (e.g. in the form of texts, photos, videos and voice recordings);
for the conclusion, administration and performance of our contractual relationships;
to maintain and manage the business relationship with you (including issuing invoices);
to inform you about current updates or to send you other information about our services;
to promote our services;
for statistical purposes;
for reasons of IT and building security (e.g. access controls, visitor lists, network and mail scanners, telephone recordings) and risk control;
for the assertion of legal claims and defence in connection with legal disputes and proceedings before authorities;
to fulfil our legal obligations at national and international level.

We process your personal data for the above-mentioned purposes, depending on the situation, in particular on the following legal bases:

the processing of personal data is necessary for the fulfilment of a contract 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; or
we have a legitimate interest in the processing of personal data.

3.2 When you visit our website, receive our newsletter or book a free demo

Each time a user accesses our website, our server collects a range of user information that is stored in the server's log files. The information collected includes the IP address, the date and time of access, the time zone difference compared to GMT, the name and URL of the downloaded file, the website from which the access is made, the browser used and the operating system used.

The use of this general data and information does not result in the identification of a specific person. The collection of this information or data is technically necessary in order to display our web pages to you and to ensure their stability and security. This information is also collected in order to improve the website and analyse its use. The legal basis for the temporary storage of information and log files is our legitimate interest in being able to offer you our websites in sufficient quality and to continuously improve them.

In addition, we collect the necessary data when you register on the website to receive our newsletter or book a free demo. The legal basis for sending our newsletter or booking a free demo is your consent. There is a link at the end of each newsletter that you can use to unsubscribe at any time. Your possible request to unsubscribe from our newsletter does not result in the deletion of the above-mentioned personal profile from CRM, unless you exercise your right to cancellation in the manner provided for in the "Your rights" section of this policy.

3.3 When you attend a Fidigit event

If you take part in an event organised by us or in collaboration with our partner Abacus, we collect personal data in order to organise and run the event and, if necessary, to send you additional information afterwards. We also use your data to inform you about other events. You may be photographed or filmed by us at these events and we may publish these recordings internally or externally. The data collected includes contact information (e.g. surname, first name, address, telephone number and email address), personal information (e.g. profession, function, title, employer), images or videos, payment information (e.g. bank details).

The legal basis for the processing of this personal data is the fulfilment of a contractual obligation with or for the benefit of the data subject, including the initiation of contact and possible enforcement (enabling participation in the event), the protection of our legitimate interests (e.g. holding events, disseminating information about our event, providing services and efficient organisation) or your consent (e.g. for sending marketing information or creating image material).

3.4 When we communicate with you or you visit us

You can contact us via the contact form or via the e-mail addresses and telephone numbers provided on our website. The personal data that you send us will be stored and processed by us for the purpose of processing your enquiry. The legal basis for this processing of personal data is your consent and our legitimate interest in processing your enquiry.

We also process your personal data when you visit our office. In this case, you may be asked to leave your contact information before your visit or at reception. We keep this personal data for a limited time to protect our infrastructure and information.

We use the "Zoom" or "Microsoft Teams" service to organise telephone conferences, online meetings, video conferences and/or webinars ("online meetings"). For this service, we process and store information that you upload, provide or create while using the video conferencing service, as well as metadata used to maintain the service offered. Further information on the processing of personal data by "Zoom" or "Microsoft Teams" can be found in the privacy policies of these services. The legal basis for this processing of personal data is the fulfilment of an agreement with you, including the preparation of the agreement and its possible execution.

3.5 If you use Fidigit support

Within the framework of existing contractual relationships, you can contact Fidigit Support if you require assistance. There are various contact options, such as contact by telephone, e-mail, ticketing system and TeamViewer. You can download the TeamViewer software and access the service session after authentication with the corresponding access data. You are responsible for the security of your access data and must not pass it on to unauthorised third parties. We use TeamViewer from TeamViewer Germany GmbH, Jahnstr. 30, 73037 Göppingen, Germany. If we need support in using the TeamViewer software, TeamViewer Germany GmbH can access our system. It is possible that some of your personal data will be displayed.

The legal basis for the processing of your data is your consent by accessing a support session or using a support tool in order to provide our customers with the desired support based on our legitimate interests and to ensure the proper fulfilment of contractual relationships. Further information on TeamViewer's privacy policy and terms of use can be found at the following link https://www.teamviewer.com/de/datenschutzinformation/

3.6 Cookies/Tools

Our website may use so-called cookies or other technologies/tools such as pixels, tags or external services (hereinafter referred to as "cookies" or "tools"). Cookies are text files that are stored in or by the Internet browser on the user's computer system or mobile device. The cookie contains a characteristic string of characters that enables the browser or mobile device to be uniquely identified when the website or app is called up again.

The purpose of using cookies is, on the one hand, to enable and simplify the use of our websites for users. Some functions of the websites cannot be offered without the use of cookies (so-called technically necessary cookies). On the other hand, we also use cookies/tools to analyse user behaviour on our websites, namely for reach measurement and marketing purposes.

3.6.1 Technically necessary cookies

Technically necessary cookies are required for the functioning of our websites. Therefore, these cookies cannot be deactivated in our systems. These cookies usually record important actions, such as the number of enquiries, the processing of your data protection settings or the completion of forms. Although you can block these cookies in your browser, some parts of our websites may then no longer work.

The legal basis for data processing when using technically necessary cookies is our legitimate interest, which lies primarily in ensuring the functionality and improvement of our websites.

Name	Description of the	Duration	Typology	Provider	Part
__hs_cookie _cat_pref	Use to save the cookie usage settings specified by the user	6 months	Required	Cloudflare	Primary page
__cfruid	Cloudflare sets this cookie to identify trusted web traffic.	Meeting	Required	Cloudflare	Primary page
__cf_bm	Cloudflare sets the cookie to support Cloudflare Bot Management.	30 minutes	Required	Cloudflare	Primary page

3.5.2 Analytical and marketing cookies

Analytical cookies allow us to analyse visitor behaviour and traffic sources so that we can measure the performance of our websites and improve the user experience. They help us to recognise which pages are popular and how visitors move around our websites. The information collected is aggregated and anonymous.

Marketing cookies allow us to deliver adverts that are relevant to you. These cookies can remember that you have visited our websites and share this information with other companies, including other advertisers.

When we use cookies for analysis and marketing purposes, we obtain your consent to do so. The processing of data for analysis and marketing purposes is therefore based on your consent. If you give us your consent, you can revoke it at any time with effect for the future. However, this does not affect the lawfulness of the processing carried out on the basis of your consent until you withdraw it. You can express your revocation at any time by adjusting the cookie settings.

You can object to the use of cookies by, for example, (i) making the appropriate settings in your browser or (ii) using appropriate cookie blocker software (e.g. Ghostery etc.).

Name	Description of the	Duration	Typology	Provider	Part
__hstc	This is the most important cookie for tracking visitors. It contains the domain, utk, the start timestamp (first visit), the last timestamp (last visit), the current timestamp (this visit) and the session number (incremented for each subsequent session).	6 months	Analytics	Hubspot	Primary page
hubspotutk	This cookie is used to track the identity of a visitor. This cookie is passed to HubSpot when a form is submitted and is used when deduplicating contacts.	6 months	Analytics	Hubspot	Primary page
__hssc	This cookie tracks the sessions. It is used to determine whether HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each PageView in a session) and the session start timestamp.	30 minutes	Analytics	Hubspot	Primary page
__hssrc	Whenever HubSpot changes the session cookie, this cookie is also set to determine whether the visitor has restarted their browser. If this cookie is not present when HubSpot manages cookies, it is considered a new session.	Meeting	Analytics	Hubspot	Primary page
_ga*	The _ga cookie, which is installed by Google Analytics, calculates visitor, session and campaign data and also tracks website usage for the website's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.	1 year 1 month 4 days	Analytics	Google	Third part
_gid	The _gid cookie installed by Google Analytics stores information about how visitors use a website and creates an analytics report about the website's performance. The data collected includes the number of visitors, their source and the pages they visit anonymously.	1 day	Analytics	Google	Third part
_gat	used by Google Analytics to throttle the request rate, which means that the collection of data on high-traffic websites is limited	1 day	Analytics	Google	Third part

3.6 Google Tag Manager

We may use Google Tag Manager from Google on our websites. Google Tag Manager is a solution that enables us to manage website tags via a single interface. The tool itself is a cookie-free domain and, according to Google, does not collect any personal data. The tool triggers other tags, which in turn may collect personal data. Google Tag Manager has no access to this data. If a deactivation has been made at domain or cookie level, this remains in place for all tracking tags implemented by Google Tag Manager. You can prevent the setting of tags at any time.

The legal basis for this is your consent and our legitimate interests.

3.7 YouTube videos

We can embed videos from the YouTube platform on our website so that they can be played directly from our website. The YouTube videos are all embedded in "extended data protection mode", which means that no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos will data about you be transmitted.

The legal basis for the processing of your data is your consent. Further information about the processing of personal data by Google Ireland Limited in connection with the playing of YouTube videos can be found at https://policies.google.com/privacy?hl=en&gl=de.

3.8 Plug-ins for social media

We may use the social media plug-ins listed in the following table on our website. We use the so-called two-click solution, i.e. when you visit our website, no personal data is passed on to the providers of the plug-ins. Only when you click on the selected plug-in field and activate the plug-in will the provider be informed that you have visited our website. In addition, the data specified in section 3.2 of this privacy policy will be transmitted. The legal basis for the processing of your data in connection with the social media plug-ins is our legitimate interest in enabling our users to use the social media plug-ins.

We have no control over the data collected and data processing operations of the plug-in providers. These are subject to the respective data protection provisions of the third-party providers. Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers listed below.

3.9 Newsletter tracking

We use the HubSpot software to send our newsletters. This software can be used to send and analyse newsletters. We collect device and access data for this analysis. The newsletter contains a pixel to collect this data. The newsletter or the websites accessible from this newsletter are also tracked using cookies. A pixel is an image file that is stored on the recipient's device.

With the help of these technologies, we receive information about whether the newsletter has been received, whether it has been opened and what content has been clicked on. We use this information to improve our newsletter and our offers. The setting of a pixel can be prevented by deactivating HTML in the mail programme (varies depending on the mail programme).

The legal basis for this (sending the newsletter and the associated performance measurement) is your consent when registering for the newsletter.

3.10 Links to other websites

Our website may link to external websites of other companies outside Fidigit. This privacy policy does not extend to the websites of these other companies. When using these websites, the data protection guidelines of these companies must be observed as far as their data processing is concerned. If you have any indications of possible legal violations on the websites linked by us, please let us know so that we can prevent any linking.

If you click on one of these links, your data may be transferred to companies in countries outside Switzerland, the EU and the EEA that do not guarantee an adequate level of protection for the processing of personal data. Please bear this in mind before clicking on a link and thereby triggering a possible transfer of your data.

3.11 Applications

You can submit your application for a position with us by post or via the e-mail addresses provided on our website. Your application documents and all personal data that you send us will be treated in strict confidence, will not be passed on to third parties and will only be processed for the purpose of processing your application for a position with us. Unless you have given your consent to the contrary, your application file will either be returned to you or deleted/destroyed after completion of the application process, unless it is subject to a statutory retention obligation. The legal basis for the processing of your data is your consent, the fulfilment of the contract with you and our legitimate interests.

4 Transfer of personal data to recipients and abroad

4.1 Disclosure of personal data to recipients

We will only pass on your personal data to third parties if this is necessary for the provision of our services, if these third parties provide a service for us, if we are obliged to do so by law or by the authorities or if we have an overriding interest in passing on the personal data. We also pass on personal data to third parties if you have consented to this or have asked us to do so.

In addition to the transfer of data to the recipients expressly named in this privacy policy, we may - to the extent permitted - transfer personal data to the following categories of recipients:

Other companies that belong to Fidinam;
Providers to whom we have outsourced certain services (e.g. HR service providers, payment service providers, debt collection service providers, risk management and compliance providers, etc.);
service providers, subcontractors and other business partners;
Banks and insurance companies;
Fidinam's tax consultants, auditors, lawyers, notaries and other external professional advisors;
Counterparties;
National and foreign authorities, institutions and courts .

4.2 Disclosure of personal data abroad

Your personal data may be processed in Switzerland, the European Union or the European Economic Area (hereinafter "EU/EEA"), but may also be processed in and transferred to a country outside Switzerland, the EU or the EEA.

If we transfer data to a country without adequate legal data protection, we ensure an appropriate level of protection within the framework of the legal provisions by means of appropriate contracts (namely on the basis of the so-called standard contractual clauses of the European Commission) or we rely on the legal exceptions of consent, contract fulfilment, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal data or because it is necessary to protect the integrity of the data subjects. We would like to point out that data transmitted abroad is no longer protected by Swiss law and that foreign laws and official orders may require the disclosure of this data to authorities and other third parties.

5 duration of storage

We only process and store your personal data for as long as required for the respective processing purpose or if there is another legal basis for doing so (e.g. statutory retention periods). We retain personal data that we have stored on the basis of a contractual relationship with you for at least the duration of this contractual relationship and the statutory limitation periods for possible claims or on the basis of contractual retention obligations. As soon as your personal data is no longer required for the aforementioned purposes, it will be inactivated, deleted or anonymised as far as possible.

6 your rights

According to the data protection law applicable to you, you have the right to information, correction, deletion, the right to restrict data processing and other rights to object to our data processing as well as the right to have certain personal data transferred to another location (so-called data portability). Please note, however, that we reserve the right to assert the legal restrictions on our part, e.g. if we are obliged to retain or process certain data, if we have an overriding interest in doing so (insofar as we are entitled to invoke this) or if we need the data to assert claims. If you incur costs as a result, we will inform you in advance.

If the data processing is based on your consent, you can withdraw your consent at any time with effect for the future. However, this does not affect the lawfulness of the processing that was carried out on the basis of your consent prior to the withdrawal of consent.

The exercise of these rights generally requires that you clearly prove your identity (e.g. by providing a copy of an identity document if your identity is otherwise unclear or cannot be verified). To exercise your rights, you can contact us at the address given in section 1 of this privacy policy.

In addition, every data subject has the right to assert their rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority may vary depending on your place of residence or the place where the alleged breach of applicable data protection law takes place.

7 security of the data

We take appropriate security measures to ensure the necessary security of your personal data and to ensure its confidentiality, integrity and availability, to protect it from unauthorised or unlawful processing and to mitigate the risk of loss, accidental alteration, unauthorised disclosure or access.

8 changes to this privacy policy

We expressly reserve the right to amend this privacy policy at any time. In the event of such a change, we will immediately publish the amended privacy policy on our websites. The privacy policy published on our websites shall apply in its currently valid version.

Last update : May 2023