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General Privacy Policy

Consent

By accessing the official website of Gamma Financials AG, you consent to the collection and processing of your personal data as described in this privacy policy. If you do not agree, please refrain from accessing our entire website. This privacy policy may be updated at any time, and the updates are binding. By continuing to use the website and our services, we assume that you are aware of these changes.

The following information also applies, by analogy, to all other information you receive, for example, in the form of our newsletter.

 

General Information

In this privacy policy, we, Gamma Financials AG (hereinafter referred to as the company, we, or us), describe how we collect and process personal data. This privacy policy may not necessarily provide a comprehensive description of our data processing. Other privacy policies, general terms and conditions, participation terms, or similar documents may apply to specific circumstances.

The term "personal data" in this privacy policy refers to all information that identifies or could reasonably be used to identify a specific or determinable natural person (data subject).

If you provide us with personal data of other individuals (e.g., family members, colleagues), please ensure that these individuals are aware of this privacy policy, and only provide us with their data if you are authorized to do so and the personal data is accurate.

This privacy policy complies with the EU General Data Protection Regulation ("GDPR") and the Swiss Data Protection Act ("DSG"). However, the application of these laws depends on the specific circumstances.

 

A. Responsible Data Controller

The "Data Controller" for data processing, as described in this privacy policy (i.e., the responsible person), is:

Gamma Financials AG
Bahnhofplatz
6300 Zug
info@gammafinancials.ch
www.gammafinancials.ch

 

If you have any questions about the processing of your personal data or other data protection concerns, you can contact us using the provided contact details.

 

B. Purpose of Data Processing and Legal Basis

We primarily use the collected data for the conclusion and fulfillment of contracts with our customers and business partners, especially in connection with the provision of financial services and the procurement of products and services from our suppliers and subcontractors, as well as to comply with domestic and foreign legal obligations.

Furthermore, in accordance with applicable law and, where appropriate, in the legitimate interests of a third party, we may process personal data for the following purposes, such as:

  • • Providing and developing our products, services, and websites, apps, and other platforms on which we operate; • Communicating with third parties and processing their requests (e.g., applications, media inquiries);
  • • Advertising and marketing (including event organization), unless you have objected to the use of your data for this purpose (if you are part of our customer base and receive advertising, you can object at any time, and we will add you to the list of individuals who do not wish to receive further advertising materials);
  • • Asserting legal claims and defense in legal disputes and administrative proceedings;
  • • Prevention and investigation of crimes and other misconduct;
  • • Ensuring our operations, including our IT, websites, apps, and other applications;
  • • Acquisition and divestment of business units, companies, or parts of companies, and other corporate transactions, including the transfer of personal data, as well as measures for corporate governance and compliance with legal and regulatory obligations and internal company regulations.

If you have given us your consent to process your personal data for specific purposes (e.g., when signing up to receive newsletters), we will process your personal data within the scope and on the basis of this consent unless we have another legal basis if required. Consent given can be revoked at any time, but this will not affect the processing of data carried out before the revocation.

 

C. Collection and Processing of Personal Data

We primarily process personal data that we receive from our customers and other business partners, as well as from other individuals in the course of our business relationships with them, or that we collect from users while operating our websites, apps, and other applications.

To the extent permitted by law, we obtain certain personal data from publicly accessible sources (e.g., debtor registers, land registers, commercial registers, press, internet), or we receive such information from affiliated companies, authorities, or other third parties (such as distribution partners, depositary banks). In addition to the data you have directly provided to us, the categories of data we receive from third parties about you include, but are not limited to, information from public registers, data we receive in connection with administrative or court proceedings, information related to your professional role and activities (e.g., for the conclusion and execution of contracts with your employer), information about you in correspondence and conversations with third parties, information about you provided by individuals connected to you (family members, advisors, legal representatives, etc.) for the conclusion or execution of contracts with you or with your involvement (e.g., powers of attorney), information related to legal requirements such as anti-money laundering, banking data, information about you found in the media or on the internet (as specified on a case-by-case basis, e.g., in relation to applications, media reports, marketing/sales, etc.), your address and any other socio-demographic data (for marketing purposes), data related to your use of our websites (e.g., IP address, MAC address of your smartphone or computer, information about your device and settings, cookies, date and time of your visit, accessed pages and content, used applications, referring website, localization data).

In principle, we store this data for 12 months after the purpose of processing has ended. This period may be longer if required for evidentiary reasons or to fulfill legal or contractual requirements.

 

 

D. Cookies / Tracking and Other Relevant Information About the Use of Our Website

Technical Data

When you visit our website, user-specific data (e.g., IP address, web browser, operating system) and technical data (e.g., URLs of accessed pages, execution of search queries) are collected and analyzed in an anonymized form.

The mentioned data is collected and processed for the purposes of system security and stability, error and performance analysis, as well as for internal statistical purposes. It enables us to optimize our website.

When subscribing to our content or submitting a contact form/customer login, we process the data necessary to provide the requested service. Depending on the service, the following data may be processed: email address, first name, last name, salutation, complete address, subject, and message.

If you have given us your consent to process your personal data for specific purposes (e.g., when subscribing to a newsletter or making an inquiry), we will process your personal data within the scope and on the basis of this consent unless we have another legal basis if required. A given consent can be revoked at any time, but this does not affect the data processed until the revocation.

In general, we store technical data for 6 months.

 

Communication Data

When you contact us via the contact form, email, telephone, chat, letter, or any other means of communication, we collect the data exchanged between you and us, including your contact information and the metadata of the communication. If we record or monitor phone calls or video conferences, such as for training and quality assurance purposes, we will notify you. Such recordings may only be made and used in accordance with our internal policies and legal regulations.

In general, we store this data for 12 months from the last interaction with you. This period may be longer if required for evidentiary reasons, to fulfill legal or contractual requirements, or for technical reasons. Emails in personal mailboxes and written correspondence are typically retained for at least 10 years. Recordings of (video) conferences are typically kept for 24 months. Chat records are typically retained for 2 years.

 

Cookies and Their Use

In some cases, we use "cookies" to tailor our offerings as closely as possible to your needs. Cookies are small files that, by themselves, cannot perform any actions and are stored on your computer or mobile device when you visit or use one of our websites. Cookies store specific settings through your browser and data related to the interaction with the website through your browser. When a cookie is active, it can be assigned an identification number that identifies your browser and allows the use of the information contained in the cookie.

There are generally two different types of cookies: temporary cookies and permanent cookies. We use temporary cookies, which are automatically deleted from your mobile device or computer after the end of the browser session. We also use permanent cookies to store user settings (e.g., language, auto-login), to understand how you use our services and content, and to show you customized offers and advertisements (which may also occur on websites of other companies; if we know your identity, these companies do not learn your identity from us; they only know that the same user who visited their website previously visited a certain website). These cookies remain stored on your computer or mobile device even after the browser session and are automatically deactivated after a certain period of time.

Nonetheless, you can configure your browser to reject cookies, store them only for a session, or delete them prematurely. Most browsers are preset to accept cookies. If you block cookies, certain functions (such as language settings, shopping carts, and the order process) may no longer be available to you.

Gamma Financials AG allows partner companies that provide services to Gamma Financials AG or are integrated into our website to store cookies, as long as it is technically necessary and the use of cookies is proportionate. Gamma Financials AG has no control over how cookies are used outside of our website.

By continuing to use our website and/or consenting to this privacy policy, you agree that we may store cookies and collect, store, and use personal usage data even after the end of the browser session ("persistent cookies"). You can object to this at any time by changing your browser's default settings to reject third-party cookies.

 

 

Google Analytics and Similar Services

With the aim and intention of tailoring our website to meet your needs and continuously optimize it, we may use Google Analytics or similar services on our website. These are third-party services that may be located in any country worldwide (in the case of Google Analytics, Google Ireland Ltd. based in Ireland, Google Ireland utilizes Google LLC based in the USA as a subcontractor, both referred to as "Google," www.google.com). They enable us to measure and evaluate the usage of our website (on an anonymized basis). For this purpose, persistent cookies are used, set by the service provider. We have configured the service to truncate the IP addresses of visitors from Google in Europe before they are transmitted to the USA, making them untraceable. We have turned off the "Data Sharing" and "Signals" options. While we may reasonably assume that the information we provide to Google is not personal data for Google, it is possible that Google could draw conclusions about the identity of visitors, create personal profiles, and link this data with the Google accounts of these individuals for their own purposes. If you have registered with the service provider, the service provider also knows your identity. In this case, the processing of your personal data by the service provider is in accordance with their privacy policy. The service provider only provides us with data on the usage of the respective website (but not personal information about you).

As part of the use of our internet pages, pseudonymous usage profiles are created, and, as mentioned in Section 5 above, small text files stored on your computer are used. The information generated by such cookies about your use of this website is transmitted to the servers of the providers of these services, stored there, and processed for us. In addition to the data mentioned in Section 4 above, this provides us with the following information:

  • Navigation Path: The sequence of pages and actions a visitor takes on the website, showing the path they follow during their visit.

  • Duration of Visit: The amount of time a visitor spends on the website or on specific pages or subpages.

  • Exit Page: The specific page from which a visitor leaves the website.

  • Geographic Location: The country, region, or city from which the access to the website originates.

  • Device Information: Details about the visitor's device, including type, version, color depth, resolution, and the width and height of the browser window.

  • Visitor Type: Whether the visitor is a returning user or a new user.

 

Among the tools, programs, and instruments we use as part of web behavior analysis is Google reCAPTCHA.

The information generated by cookies regarding your use of this website (including your IP address) is typically transmitted to and stored on a Google server in the United States. Google will use this information to evaluate website usage, compile reports on website activities for us as the website operator, and provide other services related to website usage and internet usage. Google may also transmit this information to third parties if required by law or if third parties process this data on behalf of Google. Google will never associate your IP address with other data from Google. You can prevent the installation of cookies by changing your browser settings. However, if you do so, you may not be able to use all functions of the website to their full extent. By using this website, you consent to Google processing the data collected about you in the manner and for the purposes described above.

 

Social Media Plug-ins

In addition, we use social network plugins such as Facebook, Twitter, Youtube, Pinterest, or Instagram on our website. These are typically visible to you through their respective icons. We have configured these elements to be deactivated by default. If you activate them (by clicking), the operators of the respective social networks may collect information that you are on our website, the page from which you accessed it, and may use this information for their own purposes. The processing of your personal data in this regard is the responsibility of the respective operator and is carried out in accordance with their privacy policies. We do not receive any information about you from the respective operators.

 

E. Data Sharing with Third Parties

As part of our business operations and in accordance with the purposes of data processing mentioned earlier, we may transmit data to third parties to the extent that such transmission is permissible and we deem it appropriate for them to process the data on our behalf or, where applicable, for their own purposes. In particular, the following categories of recipients may be involved:

  • Our service providers (e.g., risk management and compliance, IT providers, host providers, auditors)
  • Domestic and foreign authorities, official bodies, and courts
  • Other parties involved in potential or actual legal proceedings

Some recipients are located in Switzerland, while others may be located in any country worldwide. In particular, you should be aware that your data may be transferred to any country where our service providers are located (such as Microsoft).

If a recipient is located in a country without adequate legal data protection, we obligate the recipient to comply with data protection (we use the revised standard contractual clauses of the European Commission, which you can access here: Link to Standard Contractual Clauses), unless the recipient is subject to a legally recognized framework for ensuring data protection and we cannot rely on an exception. An exception may apply, for example, in the case of foreign legal proceedings or in cases where there is an overriding public interest, the fulfillment of a contract requires disclosure, you have provided the data generally and have not objected to its processing, or you have given your consent.

 

 

F. Duration of Data Storage

Your data, including personal data, will only be processed and stored for as long as necessary to fulfill our contractual and legal obligations or the purposes pursued with the processing, potentially for the entire duration of the business relationship and beyond due to legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company and to the extent we are otherwise legally obligated to do so or if legitimate business interests require it (e.g., for evidentiary and documentation purposes). Once your personal data is no longer needed for the aforementioned purposes, it will be deleted or anonymized to the extent possible. Operational data (e.g., system logs) are subject to shorter retention periods of 30 days or less.

 

G. Data Security

We have implemented appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse. These measures include providing instructions, training, IT and network security solutions, access controls and restrictions, password encryption, data storage and transmission encryption, pseudonymization, and controls.

Please note that despite these security measures, absolute security on the internet cannot be guaranteed. It is advisable to take suitable steps to protect your personal data, including using secure passwords and regularly updating your access credentials.

 

 

H. Your Rights

You have the right, in accordance with applicable law, to access, correct, and delete your personal data. You also have the right to restrict processing or object to our data processing, particularly for purposes of direct marketing, profiling for direct marketing, and other legitimate interests in processing. Furthermore, you have the right to receive certain personal data for transmission to another controller (data portability). Please note, however, that we reserve the right to assert legal restrictions on our part, for example, if we are obligated to retain or process certain data, have a prevailing interest (to the extent we can rely on such interests), or need the data to assert claims.

We have already informed you of the possibility of withdrawing your consent or objecting at any time. Please also note that exercising these rights may conflict with your contractual obligations and may have consequences such as early contract termination and associated costs. If this is the case, we will inform you in advance, unless it has already been contractually agreed upon.

 

In general, the exercise of these rights requires that you can prove your identity (e.g., by providing a copy of identification documents if your identity is not otherwise evident or verifiable). To assert these rights, please contact us using the contact details provided above.

 

Furthermore, every data subject has the right to enforce their rights in court or lodge a complaint with the relevant data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).

 

I. Profiling 

We may partially process your personal data automatically to evaluate certain personal aspects (profiling). Profiling allows us, in particular, to better inform and advise you about products that may be relevant to you. For this purpose, we may use evaluation tools that enable us to communicate with you and, if necessary, to market to you, including market and opinion research.

 

J. Changes to this Privacy Policy

We may change this privacy policy at any time without prior notice. The most current version will always be published on our website. If the privacy policy is part of an agreement with you, we will notify you of any changes via email or through other appropriate means.

 

 

K. Contact

Regarding personal data matters, you can always contact us at the following email address: info@gammafinancials.ch.