OUR COMMITMENT TO PRIVACY
PrivIntelligent Solutions LLC is a company incorporated under the laws of Switzerland and seated at Via Emilio Bossi 6| P.C. 6900 | Lugano |Switzerland| email: info@privintelligent.com | Web: www.privintelligent.com/ (hereinafter “PrivIntelligent”, “we”, “our” or “us”).
PrivIntelligent is active in the field of Data Privacy, providing a full array of data protection services to companies in order to find optimal solutions about data privacy and data protection. PrivIntelligent is fully committed to protecting the privacy of personal data related to all individuals with whom we interact – including the visitors and users of our website (hereinafter “Users”, “you” or “your”), clients, staff, associates, business partners, job applicants, third party service providers or others inside or outside the company.
In order to achieve this goal, our website (http://www.privintelligent.com) fully complies with the provisions of national and European legislation regarding the protection of personal data, including the Federal Act on Data Protection (“FDPA”), as applicable.
INTRODUCTION
This Privacy Policy (the “Policy”) sets out how PrivIntelligent collects, processes and safeguards the personal data of the individuals with whom we interact. PrivIntelligent is responsible as the “data controller” for deciding how we collect, hold and use personal information about you. References to “processing” contained within this Policy can mean any operations performed on personal data, for example collection, storage, recording, alteration, retrieval, restriction or erasure.
This Policy is designed to assist you in making informed decisions when using our website or otherwise interacting with us.
Please read carefully and make sure you understand the terms of processing of your personal data set forth in this Policy before disclosing any personal data and/or filling in any electronic contact form made available on this website. By visiting our website or by providing us your personal data, you acknowledge to the collection, use and disclosure of your personal information as outlined in this Policy.
SCOPE OF THIS POLICY
This Policy aims, as already mentioned above, to provide you with detailed information on how we collect and process your personal data (as defined below) while using our Website, including any data you may provide us through this website or due to our Website’s interaction with other websites as well as through our general interactions with our clients and customers.
For the purpose of this Policy “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data does not include data which has been anonymized, but does include pseudonymized data.
DATA PROTECTION PRINCIPLES
We take all commercially reasonable efforts to ensure that personal data we hold about you are:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you, and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only for as long as necessary for the purposes we have told you about; and
- Kept securely.
We do everything possible to implement the above data protection principles at all stages of interaction with you and to comply with applicable data protection laws and regulations.
POLICY AND OTHER PRIVACY NOTICES/DOCUMENTATION
This website has been designed with the main function of providing to the public general information in relation to PrivIntelligent’s corporate profile, services and clients and to share news and updates on related events and activities organized or sponsored by PrivIntelligent. Therefore, in most cases, the collection of the Users’ personal data will not be required. Please note that PrivIntelligent does not collect any personal data of the Website’s Users in an automatic way, except of those that the Website Users shall provide, using the electronic contact form of the Website. In these cases, the provision of your contact details is optional; if you do not provide your personal information and contact details we will not be able to follow up with you to provide you with the requested information or to handle any enquiry appropriately.
WAYS OF OBTAINING PERSONAL DATA
In most cases, PrivIntelligent will collect data directly from you, although sometimes we will obtain data about you from public or third-party data sources, including but not limited to:
- From business cards;
- From attendance at seminars and/or events organized or hosted by us;
- When we contract with suppliers or service providers for the provision of services to us; and
- Through third party agencies, or information available in the public domain.
Whilst you are free to decide whether to provide us with your personal data, please note, that if you choose not to provide such data, we may not be able to provide you with any requested data protection services, as this is strictly necessary to provide you with the requested data protection services.
PERSONAL DATA WE COLLECT
We may collect and process the following personal data about you, including but not limited to:
Performance of data protection services
The types of personal data we collect in the course of and in connection with the provision of legal services may include:
- Your name, address and contact details, including personal and business email addresses and telephone numbers;
- Identification documents (which may include information relating to your date and place of birth) and/or other governmental identification numbers for the purposes of complying with regulatory or legislative requirements;
- Details of your current and previous employment, directorships and shareholdings; and
- Details of your bank account for the purposes of billing and collections.
- Any other information including personal information strictly necessary to provide the requested services.
Recruitment
In addition to the above, if you apply to work for PrivIntelligent we may collect the information set out below:
- Details of your qualifications and skills;
- Previous employment history, references, and information about your remuneration;
- Details of your bank account, national insurance number or other governmental identification numbers, tax code and your right to work;
- Information about medical or health records; and
- Other personal data we may require complying with the national legislative and/or regulatory requirements.
Events
From time to time, we may have agencies responsible to take photographs or make video recordings of our events; where this is the case, we will notify you in advance. If you do not wish to be photographed or video recorded, please inform the organisers and they will lead you to an area where not photographs or video recordings take place.
Visiting PrivIntelligent offices
When attending our offices, you may be asked to provide identification documents to satisfy security requirements of the building. This information is not collected or processed by PrivIntelligent.
COOKIES USED IN THIS WEBSITE
In order to make this website function properly, our website places small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. There are various types of cookies serving different purposes related to the efficiency of the website, the improvement of the Users’ browsing experience and the functionality of the website.
Our website uses only strictly necessary cookies, which are strictly necessary for the proper operation of our Website. The cookies we use allow Users to browse our Website and make use of its features without identifying the Users as individuals. The data we collect is anonymized and not able to identify the Users directly, unless they provide us with personal information by completing the online contact form or through another feature offered on the Website. Where personal information is collected by us, such collection is covered by our Privacy Policy.
Here is a list of the strictly necessary cookies used by our Website:
| Controller | CookieName | Type/Category | Purpose | Retention Period |
| PrivIntelligent Solutions LLC | CookieConsent | Necessary functional cookie/ First – party/Session cookie |
Stores the user’s cookie consent state for the current domain | 1 year |
PURPOSES OF PROCESSING PERSONAL DATA
PrivIntelligent will process your personal data only for purposes permitted by applicable laws and on the terms set forth in this Policy. The purposes of the data processing activities may include:
- Providing data protection services to our clients;
- Maintaining and developing our relationships with clients and third parties;
- Improving our Website functions in order to ensure that content from our Website is presented in the most effective manner for you and for your device.
- Facilitating our internal business operations including accounting, billing, collections, and payments;
- Complying with our legal, regulatory and professional obligations;
- Sending invitations for corporate hospitality and other events;
- Placing and maintaining our insurances; and
- Processing professional data to assess the individual suitability for job openings at PrivIntelligent when recruiting.
This is not intended to be an exhaustive list and we may use personal data provided to us for further related and/or ancillary purposes, where this is permitted by law or when need to do so to comply with our legal and regulatory obligations.
LEGAL BASIS OF PROCESSING
Our legal basis for the processing of personal data is our legitimate business interests, although we will also rely on contract, legal obligations and consent for specific uses of personal data.
We will rely on contract if we are negotiating or have entered into a business contract or an engagement for data protection services with you, your organization or an affiliated legal entity.
We will rely on legal obligations if we are legally required to hold information on you to fulfil our legal or regulatory obligations.
In addition to the above, we may use your personal data where you have provided your consent to such use or we are otherwise we have a legitimate interest to do so, to the extent that the rights and freedoms of individuals do not prevail.
Change of purpose
We will use your personal data only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an additional purpose, we will notify you in advance of any processing and we will explain the legal basis which allows us to do so.
SPECIAL CATEGORIES OF DATA
In addition to the above, where PrivIntelligent processes special categories of data about individuals (information about individuals’ health, ethnicity, religion, etc.) – we only do so for limited purposes (e.g. to comply with labour and social security law obligations) and in accordance with applicable laws and regulations. For such processing PrivIntelligent relies on the following conditions:
- Where individuals provide explicit consent;
- Where required for rights and obligations related to employment;
- Where required for vital interests of any individual; and
- Where processing is necessary for the purposes of provision of advisory or legal services, pursuant to a contract.
WITH WHOM WE SHARE YOUR PERSONAL DATA
We may share your personal data with:
- Internally to authorized individuals who are bound by confidentiality obligations or are under a statutory duty of confidentiality e.g. legal privilege.
- Legal Counsel, correspondent law firms, other legal specialists, consultants or experts (including arbitrators/mediators and notaries);
- Our Accountants or Auditors for auditing and accounting purposes;
- Regulators, courts and law enforcement agencies as necessary;
- Third party service providers, such as website administrators and IS support and maintenance service providers; and in doing so, we will keep the systems and processes of third party service providers under review to monitor the confidentiality, integrity and security of your personal data is maintained when being handled by any such service provider; and
- Other third parties where we have your express consent to do so.
REDIRECT TO OTHER WEBSITES
From this Website, you can connect through special hyperlinks to other websites of third parties. PrivIntelligent does not endorse or recommend these websites’ content or services and assumes no responsibility regarding the processing activities of personal data or any activity by or content on third-party sites to which our Website provides hyperlinks. We encourage you to read and be aware of the privacy policy, and all other policies, of each website you visit. Remember, the statements in this Policy apply solely to information collected by PrivIntelligent.
WHICH COUNTRIES WE TRANSFER YOUR PERSONAL DATA TO
The personal data that we collect from you shall not be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or Switzerland. If we transfer your personal data to a location outside the EEA, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection legislation.
DISCLOSURE OF PERSONAL DATA
Personal data are not disseminated to unspecified recipients. PrivIntelligent discloses your personal data to third party recipients on a controlled and need to know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal data will be disclosed only in accordance with applicable laws, and appropriate safeguards, such as the execution of contractual agreements (EU Standard Contractual Clauses pursuant to art. 46 GDPR), will be established to protect your personal data.
In order to conduct PrivIntelligent’s business, PrivIntelligent may also disclose personal data to third parties such as public/regulatory authorities/governmental bodies, third parties that provide services to PrivIntelligent (such as but not limited to service providers, conducting audits, providing IT services, hosting service providers, event management agencies, banks, insurance companies and other support and administrative service providers that deliver support services to us), business partners and associates.
SECURITY AND DATA RETENTION
PrivIntelligent takes the security of your personal data seriously. PrivIntelligent has internal policies and controls in place to try to ensure that your personal data is not lost, accidentally destroyed, misused or disclosed. We will take reasonable steps to ensure that the information that we hold about you is kept confidential and secure.
Where PrivIntelligent engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of personal data.
We have put in place procedures to deal with any suspected personal data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal data for as long as it is strictly necessary to achieve the purposes for which the data were collected and any other permitted associated purpose. Data may be retained for a longer duration where applicable laws or regulations require, or allow PrivIntelligent to do so. When your data is no longer needed it will be securely destroyed.
AUTOMATED DECISION MAKING
PrivIntelligent does not undertake through its website or in general decisions based solely on automated processing, including profiling, of an individual unless we inform you otherwise.
YOUR DATA PROTECTION RIGHTS
Under applicable laws and subject to any legal restrictions, you may have the right to request us to:
- Provide you with further details on the processing of your personal information;
- Provide you access to your personal data that we hold about you;
- Update any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;
- Delete any personal information that we no longer have a lawful basis to use (PrivIntelligent can refuse to delete your personal data if in its view it requires the information for defense of legal claims against it or its group entities);
- Provide you or a third party, with a copy of your data in a digital format (data portability);
- Stop a particular processing when you withdraw your consent. Please note that withdrawal of previously given consent will have effect for the future and will not affect the lawfulness of processing based on consent until the time of such withdrawal. Moreover, even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations ;
- Object to the processing of your personal data. Your objection could mean that we are unable to perform the actions necessary to achieve the purposes set out in this Policy.; and
- Restrict certain aspects of the processing of your information.
You can exercise any of the above rights and also submit any data protection related requests or enquiries by contacting us by email at: privacy@privintelligent.com.
POLICY UPDATING
PrivIntelligent reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and PrivIntelligent’s business practices, subject to applicable laws. If PrivIntelligent changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.
CONTACT INFORMATION
If you have any questions in relation to this Policy, or you want to obtain more information about PrivIntelligent’s privacy practices, please contact us by email at: privacy@privintelligent.com.
Last revised: 26th May 2020.