Protection of your privacy and the security of your personal data are very important to Trusted Talent Management Sagl.
By using our website, providing personal information and/or using any of our services, you agree that:
- if you have provided personal information to us relating to any other person, you:
(a) have a right to provide that information
(c) each such person has agreed to those terms.
Information about the collection of personal data
When we talk about your information, we are referring to your “personal data” as defined by the GDPR and this includes information that can identify you as a living individual, whether by itself or when used in conjunction with other information which we hold. Examples include, but are not limited to, your name, your telephone number, your email address, your place and date of birth.
Please find below information about the collection of personal data concerning your personal data when using our website. The “responsible person” as per the GDPR and other national data protection laws and provisions, which are key for the purpose and means of processing personal data, is:
Alessandro Alunni Bravi / Via Aprica 18A, 6900 Lugano, Switzerland
When you contact us by e-mail, the personal data you provide is saved by us so that we can answer your questions. We shall delete the data received in this situation once it is no longer required to store the data, or restrict the processing if legal storage obligations exist.If we commission service providers with individual functions of our offer, or want to use your data for advertising purposes, we will notify you below in detail about the respective processes. We also state the specified criteria for the duration of storage there.
Legal basis for the processing of data
We always ensure we respect your privacy rights. This means we can only collect your personal data if we have lawful grounds for doing so. Therefore, we fundamentally only process your personal data if this is necessary to provide a functioning website and for our content and services. The processing of your personal data is only done regularly once your consent has been obtained. There is an exception to this in cases where obtaining your consent in advance is not possible due to practical reasons, and the processing of the data is permitted by legal provisions.
Other reasons we may process your information include:
- providing you with information about us;
- management of enquiries and complaints;
- if you have applied for a job with us, so we can consider you for employment;
- if you are attending one of our events.
If we obtain your consent for the processing of your personal data, Art. 6, paragraph 1a GDPR serves as the legal basis for the processing. If the processing is necessary to protect a justified interest of our company, and if the afore-mentioned interest does not outweigh your interests, basic rights and freedom, then Art. 6, paragraph 1f GDPR serves as the legal basis for the processing.
Your information may be used:
- to verify your identity when you are dealing with us, so we may satisfy our obligations with respect to any relevant legal or regulatory obligations we may be subject to;
- to provide you with the information that you have requested from us;
- to ensure that content from our website is presented in the most effective manner for you and for your device(s); and/or
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, or otherwise as part of our efforts to keep our website safe and secure.
Your information may also be used to provide you with information about us and our range of products and/or services. To this end, we may use your information:
- to allow you to participate in interactive features of our services, when you choose to do so;
- to inform you about and manage your involvement with our services and events, including educational or corporate hospitality events
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, including making suggestions and recommendations to you and other users of our website about goods or services that may interest you or them; and/or
- to provide you, with news bulletins, newsletters, brochures, or general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, or otherwise feel may be of interest to you (unless you have opted-out of receiving such information).
In circumstances where you arean existing client or we otherwise have an existing relationship with you we will rely on our legitimate interests as the lawful ground for processing your personal data for direct marketing purposes. To this end, it may be necessary to process your personal data so we can directly market in our legitimate interest. In addition, we consider it reasonable for you to expect you may receive marketing material from us in the same methods we normally communicate with you (e.g. via email) and that there is no disproportionate impact to your individual privacy rights in this case.
In circumstances where you are not a client or we do not otherwise have an existing relationship with you, marketing our materials, events and services (or those of others) to you shall be subject to your consent which shall be requested at the latest on our first communication to you, where you will be given the option to elect to receive such information (known as ‘opting-in’) by checking the appropriate boxes on the forms we use to collect your data or in links provided within our email communications.
On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.
If you wish to be removed, we will retain your details in our marketing database(s) specifically for the purposes of suppressing your details from inclusion in all future marketing campaigns. These database(s) are restricted for access only by members of our marketing team. Your unsubscription request will only affect these database(s) and will not change any existing information on our other databases that you have provided to us or we have otherwise obtained for the purposes of providing our products and/or services to you or for any other lawful purposes.
Your rights when using our website
As from the “GDPR” gives data subjects (like you) more rights in relation to their personal data. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
If you are a natural person (in other words, a human being and not a company) you have the right to:
- information about the processing of your personal data (and if you did not give it to us, information as to the source);
- obtain access to the personal data held about you;
- ask for incorrect, inaccurate or incomplete personal data to be corrected;
- request, in certain cases, that personal data be erased when it’s no longer needed or if processing it is unlawful;
- object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation;
- request the restriction of the processing of your personal data in specific cases;
- receive your personal data in a structured, commonly used and machine-readable format, or ask us to send it to another person (“data portability”); and
- request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision.
Please note these rights may only apply in certain cases. For example, some rights only apply where our lawful ground of processing is your consent.
You also have a right to lodge a complaint with the appropriate data protection authority whose details are provided below, and in certain cases may receive compensation from us, as data controller, for any damage you suffer.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by contacting us on the details below. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
You can enforce the rights described above by means of a written request to us at the contact details below. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity and completion of a form so that we can better understand the nature of your request and the information you are after. You will need to provide information to confirm your identity so we are sure it is actually you requesting your data. We must respond to your requests without undue delay and at the latest within 1 month.
There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know why we cannot comply with your request.
In addition, you can enforce your right to object to direct marketing as described in the section above.
Even if you do not request access to and/or correct your personal information held by us, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.
Collection of personal data when visiting our website
If you merely use the website for informational purposes, i.e. if you do not register or transfer us information in any other way, we will only collect the personal data that is transferred by your browser to our server. If you want to view our website, our system collects the following data, which is technically necessary for us to show you our website and ensure stability and safety:
– Your IP address (last 3 digits are masked)
– Date and time of the request
– Time zone difference to Greenwich Mean Time (GMT)
– Content of the request (specific page)
– Access status/HTTP status code
– The data volume transferred
– The website where the request comes from
– Operating system and its interface
– Language and version of the browser software
– Your general interaction with our website
The data is also saved in the log files of our system. This data is not saved together with other personal data. The legal basis for the collection and temporary saving of the data is Art. 6, paragraph 1 (1f) GDPR. As the recording of data is mandatory for us to provide the website, and the saving of data in log files is mandatory for the operation of the website, there is no right of objection.
In addition, we may be required by law or by a court to disclose certain information about you or any contract we may have with you to relevant regulatory, law enforcement and/or other competent authorities, unless such information is protected by duties of confidentiality owed to our partners or to other persons. We may also need to share your information in order to enforce or apply our legal rights.
In connection with the provision of our services and/or products, personal data may also be transferred to countries or territories outside Switzerland where necessary, in which case we will arrange for contractual safeguards where such territories do not offer an adequate level of personal data protection similar to the one applied in Switzerland or in the European Economic Area (EEA).
We may also rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we may collect and transfer your personal data outside Switzerland: with your consent; to perform a contract with you; or to fulfil a compelling legitimate interest we may have in a manner that does not outweigh your rights and freedoms.
We use reasonable physical, electronic, and procedural safeguards to protect the personal data that we obtain from you from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Please note that we are not responsible for the security of any data you are transmitting over the Internet, or any data you are storing, posting, or providing directly to a third party’s website, which is governed by that party’s policies. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure and we cannot ensure or warrant the security of any information you transmit to us. Transfer of your data via these means is therefore at your own risk.
A loss of personal data is known as a data breach. The GDPR imposes requirements on businesses to identify, assess and report breaches in a timely manner (within 72 hours). We undertake to inform you if your personal data is compromised and there is a risk to your rights and freedoms as a result.
Cookies are a feature of web browser software that
allows web servers to recognize the computer or device used to access a
website. A cookie is a small text file that a website saves on your computer or
mobile device when you visit the site. It enables the website to remember your
actions and preferences (such as login, language, font size and other display
preferences) over a period of time, so you don’t have to keep re-entering them
whenever you come back to the site or browse from one page to another. They
serve to make our website more user-friendly and effective in general. Most
internet browsers accept cookies automatically. You can, however, configure
your browser settings according to your preferences and, for example, reject
the acceptance of third-party cookies or all cookies. We would like to point
out, however, that in these cases you may not be able to use all the functions
of this website.
This website uses the following session cookies:
Session cookies save a so-called session ID which allows various requests of your browser to be allocated to a common session, and are deleted automatically when you close your browser. Session cookies allow your computer to recognize when you return to our website.
This website uses the following persistent cookies:
Persistent cookies are automatically deleted after a specified period of time, which can vary depending on the cookie. You can delete the cookies in the safety settings of your browser at any time.
The legal basis for the processing of personal data using cookies is Art. 6, paragraph 1 f, GDPR.
The use of Google Analytics
Only in exceptions is the full IP address transferred to a server of Google in the USA and abbreviated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports about the website activities and to perform services associated with the use of the website and the internet for the website operator.
The IP address transferred by your browser due to Google Analytics is not compiled with other data from Google.
You can prevent the saving of cookies by making a corresponding setting in your browser software; we would like to point out, however, that in this case you may not be able to use all of the functions of this website. Furthermore, you can prevent the collection of the data generated by the cookies and related to your use of the website (incl. your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
We use Google Analytics to analyse the use of our website and to regularly improve it. Using the statistics we obtain, we are able to improve our website and design it to be more interesting for you as a user. In exceptions where your personal data is transferred to the USA, Google is subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
This website also uses Google Analytics to analyse the cross-device flow
of visitors, which is done based on a user ID. You can deactivate the
cross-device analysis of your use in your customer account under “My Data”,
The legal basis for the processing of personal data by using cookies from Google Analytics is Art. 6, paragraph 1 f, GDPR. We have concluded an agreement with Google and implement the strict provisions of GDPR in full when using Google Analytics.
Governing Law and Jurisdiction