PRIVACY POLICY FOR WEBSITE

The website https://www.logikarealestate.ch/ (‘Site’) is owned by Studio Immobiliare Ticino Sagl, Via P. Lucchini 2, 6900 Lugano, Switzerland, e-mail: info@sitimmobiliare.ch, tel. +41 (0) 91 922 93 33 (‘Company’ or ‘we’).

The processing of personal data applies to those who interact with the Company’s web services, which can be accessed electronically from the address of our Site, corresponding to the Site’s home page. This Policy applies exclusively to the Site owned by the Company and not to other, different websites outside the Company that the User may visit via links and/or links from our Site.

Please read the following carefully.

1. Website – Users
This Policy covers the data subjects (‘Data Subject’, ‘you’, ‘User’) whose personal data is collected by us when you act as a User of our Site or provide your information as explained below.

This Privacy Policy is based on the Swiss Federal Data Protection Act (‘DPA’) of 25 September 2020 (as amended on 1 September 2023) as amended from time to time

https://www.fedlex.admin.ch/eli/cc/2022/491/en

The Company is authorised to process and process personal data pursuant to this law and regulations of the Federal Data Protection and Transparency Commissioner

https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

2. Personal data
Under the DPA, personal data are defined as ‘any information relating to an identified or identifiable natural person’.

According to the DPA, the data controller is the entity that decides on the purpose and content of a data file. The Company is the data controller (‘Data Controller’).

3. Personal data we collect with your consent and browsing data
Personal data is information that you have made public or that you provide to us by filling in forms in writing, by e-mail, through our websites, by registering for our events. This includes information provided when filling in our contact form on our website, to participate in our events, to receive newsletters, to request materials or information, or to request services.

We collect the following categories of information:

• first name(s), surname(s), address(es), e-mail, telephone number(s);
• information on our relationship with you, correspondence.

If you contact us, we may keep a record of such correspondence.

Browsing data are acquired by the computer systems and procedural software used for the operation of this Website during normal operation. These are personal data whose transmission is implicit in the use of Internet communication protocols. This category includes IP addresses, addresses in URI/URL (Uniform Resource Identifier/Locator) notation, the time of the request, the type of request, the size of the outgoing packet, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment. This is information that is not collected in order to be associated with identified individuals, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning. The data could be used to ascertain liability in the event of hypothetical computer crimes against the site only at the request of the relevant supervisory bodies.

The Site collects, in particular, the following navigation data:

• IP anonymised;
• Date and time of access;
• Place of access.

4. How we collect personal data
Personal data is collected directly from you in various ways:

• you provide us with;
• you have made public; and
• which we collect automatically through sharing with other parties where necessary.

The personal data you provide us with may be collected in different ways. These include:

• directly via our Website;
• sending your CV by e-mail to our team or via our e-mail messages;
• through the online form as part of our website or a form provided to us in paper or electronic form or when registering for our events or newsletters;
• contacting us with requests for information or comments by phone, e-mail or paper mail.

The consent given for the data provided voluntarily by the User may be revoked at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.

5. How we use personal data
We will process your personal data, in accordance with our obligations under the DPA, for the following reasons:

• provide you with the services you have requested and fulfil contractual obligations (legal basis for processing is the performance of a contract);
• to comply with DPA or other regulations, e.g. AML/CFT or tax/accounting (legal basis for processing is the need to fulfil a legal obligation);
• implement administrative purposes (the legal basis for the processing is the legitimate interest of the Controller);
• assessing your requests for information (the legal basis for processing is your consent);
• provide information about us and our services (the legal basis for the processing is the User’s consent);
• send newsletters (the legal basis for the processing is the consent of the User);
• responding to the sending of the contact form for information request (legal basis of the processing is the consent of the User);
• perform statistics with anonymised IP (Google Analytics) (legal basis for processing is the user’s consent).

The Data Controller makes it known that failure to provide, or incorrect communication of, any of the mandatory information may result in the Data Controller being unable to guarantee the appropriateness of the processing.

If, at any time, you do not wish to receive further information about us and our services, please contact us by e-mail.

Other personal information, such as, for example, that relating to the use of the Website (in particular: IP address of the user’s device, unique identifiers of the user’s mobile device, length of stay on the Website, services used, links and messages activated, etc.) is analysed, in an automated and anonymised manner, exclusively to assess the introduction of new functionalities, to improve the quality of the services offered and to optimise the usability of the Website. The website does not process or transmit content or advertisements designed on the basis of online behaviour, nor does it profile users or monitor the use of web resources or e-mail. The Website does not sell, rent, exchange and/or lend Personal Data to third parties.

The User’s personal data may be used by the Data Controller in legal proceedings or in the preparatory stages of such proceedings to defend against abuses committed by the User in the use of this Site and the services connected to it. The User declares that he is aware that the Controller may be obliged to disclose personal data by order of the Public Authorities.

6. Sharing your personal data
We may disclose your personal information to third parties to fulfil a legal or contractual obligation, when the disclosure is necessary to administer the relationship, to enforce or apply agreements and contracts, or to protect the rights, property or safety of the Company or other individuals. This includes the exchange of information with:

• other companies and organisations for the purposes of running this website (web-design, maintenance and hosting), safeguarding or other legal regulations we have to comply with;
• persons authorised to process data who perform work for the Controller (employees, collaborators, partners);
• subjects appointed as external data processors;
• consultants and freelancers working on behalf of the Controller (accountants, IT service providers);
• all those to whom the data shall be communicated for the proper fulfilment of the purposes specified above and the activities connected or related thereto.

7. Websites
Our website may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to one of these websites, please note that these websites have their own privacy policies and that we accept no responsibility for these policies. Please check these policies before sending personal data to such websites.

8. Automated Decision-Making Processes
The Controller does not carry out any processing consisting of automated decision-making processes.

9. Social Network Plug-In
The site also incorporates plug-ins that enable easy sharing of content on social networks.
By clicking on the corresponding plug-in of the Social Network, a connection is established between your browser and the servers of the Social Network itself, which will be able to track your visit to our Site and, where appropriate, associate you with your Social Network account, particularly if you are logged in at the time of your visit.
If you do not want the Social Network to record data relating to your visit to our Site, you must log out of your Social Network account and delete the cookies that the Social Network has installed in your browser.
The collection and use of information by Social Networks is governed by their respective privacy policy to which please refer.

• Facebook: https://it-it.facebook.com/
• LinkedIn: https://www.linkedin.com/
• Instagram: https://help.instagram.com/

10. Protection of your personal data
The data collected from you will be processed on our servers in Switzerland. They may also be processed by organisations operating in the EEA mandated by the Company and with which data processing agreements have been concluded. If we send personal data to a country that does not have adequate data protection legislation, nor is considered an adequate country on the basis of an adequacy assessment by Switzerland or the European Commission, we will ensure an adequate level of protection by employing contracts accordingly, or we will act on the basis of legal requirements, consent, contract performance, enforcement or enforcement of legal claims, in accordance with the requirements of the DPA. We may also use binding corporate rules, standard contractual clauses or ad hoc contractual clauses stating that data will be processed in accordance with the DPA.

11. Security of your information
To protect the privacy of the data and personally identifiable information you transmit through your use of our Website, we take physical, technical and administrative security measures. We update and test our security technology as required by law. We restrict access to your personal data to employees who need to know them in order to provide you with services. We also train our employees on the importance of confidentiality and respect for the privacy and security of your data.

12. How long do we keep data
We retain your personal data in accordance with our internal data retention policy. This policy is reviewed and updated internally to ensure that data is not kept longer than necessary. In general, the personal data collected will be deleted once 10 years have passed since the requested service was provided. Data provided for sales promotion activities will be stored until the user revokes consent and, in any case, for a period not exceeding two years.

We also check how and where to store data to ensure compliance with the obligation of secure data storage. We process and store personal data to the extent that this is necessary to fulfil our contractual and legal obligations or for the purposes pursued by the processing, which means, for example, for the entire duration of the business relationship (from the initiation and execution of a contract to its conclusion) and beyond, in accordance with legal retention and documentation obligations.

13. Disclaimer
Data published on our website, of whatever kind, are never binding. We reserve the right to change or update the information contained on the Site at any time and without notice. Our company is not liable for Internet malfunctions, damage caused by third parties, data imports of any kind (viruses, worms, Trojan horses) or links from or to other sites on the web. We have no control over the content and form of external web pages. We cannot guarantee the perfect functioning of hardware and software. In no event shall our Company be liable to you or any third party for any direct, indirect, special or consequential damages of any kind arising out of your use of the Website or any other site linked to it. Any liability for loss of income, business interruption, loss of programmes or other data in your computer systems is also excluded. The transmission of communications, documents and other information by e-mail is considered less reliable, secure and confidential than by letter. Against viruses and spam we use modern identification technologies. However, we also recommend the use of an anti-virus software and disclaim liability for any damage resulting from e-mails or their loss. We reserve the right to reject e-mails with potentially dangerous attachments.

14. Communications by e-mail
The User is aware that (i) the use of electronic mail does not guarantee the confidentiality and integrity of data in transit, (ii) many e-mail service providers are located or hold their data in countries that do not guarantee adequate data protection, (iii) use of the e-mail service may result in data being transferred to and stored in a country that does not guarantee adequate data protection. The User authorises the Company to transmit by ordinary (unprotected) electronic mail documents and/or information, including those containing personal and/or confidential data, using the e-mail address provided by the User in response to User requests received by telephone or e-mail. The User, aware of the above risks, releases the Company from any liability in the event of unauthorised access by third parties to personal and/or confidential documents and/or information transmitted or received by e-mail by the Company.

15. Changes to the privacy policy
The Company reserves the right to change this Policy from time to time. Such changes shall enter into force upon publication on our Website. Subsequent use of our Website or submission of personal information to the Company shall be deemed to constitute acceptance of the Privacy Policy and its variations.

16. Complaints, objections
Pursuant to the DPA, you have the following rights as a data subject:

• be informed if your personal data are being processed;
• revoke the consent to data processing you have previously given;
• obtain rectification of inaccurate or outdated personal data:
• prevent the disclosure to third parties of personal data worthy of special protection;
• request that data processing be stopped, that disclosure to third parties be prevented, or that personal data be corrected or destroyed.

If you feel that we are not processing your personal data in accordance with this Privacy Policy and the DPA, please contact us by e-mail. We will respond within 30 days as required by law.

You can also contact

https://www.edoeb.admin.ch/

Federal Data Protection and Transparency Commissioner, Feldeggweg 1 CH – 3003 Bern.

Last updated: 05.17.2024