Privacy Policy Spalluto Comunicazione Sagl

This privacy policy sets out how Spalluto Comunicazione Sagl (“Spalluto Comunicazione”, “us”), based in Besazio, Switzerland, uses and protects personal data provided when using this website or filling a form. 

Spalluto Comunicazione undertakes to guarantee the protection of the privacy of its users. If you are asked to provide information that could allow user identification as a result of the use of this website, we guarantee that these will be processed and used in accordance with this privacy policy.

Spalluto Comunicazione reserves the right to change this privacy policy from time to time. We recommend that users regularly check this page to ensure that they are always up-to-date in regards to data processing performed by Spalluto Comunicazione.

Who is the data controller?

Spalluto Comunicazione Sagl
Via alla Cava 3
6863 Besazio
Switzerland

e-mail: info@spalluto.ch

What data does Spalluto Comunicazione collect?

We can collect the following information about the user, which is usually provided by the user:

• name and professional title
• contacts including home, professional and e-mail address
• other information provided by the user when using our website or services (including information provided using any contact form made available on our website)

What does Spalluto Comunicazione do with the information collected?

Specifically, we process users’ personal data for the following purposes:

• Providing the service requested by the user, in particular in relation to the subscription to newsletters. 
• Providing users with information about the activities of Spalluto Comunicazione, new and existing services, participation to events and other news that may be of interests to the users. Providing such updates as well as information on the availability of new services is part of the service we provide. We also believe that it is in the legitimate interest of Spalluto Comunicazione to offer to our users news and services that may be of interest to them. However, the user may at any time request Spalluto Comunicazione to stop receiving such communications. The user can easily forward this request to the contacts indicated above, or follow the instructions that will be included in every communication sent to the user.

Who has access to and receives user data?

Within Spalluto Comunicazione, employees who need user data to fulfill our contractual and legal obligations will have access to them. 

Spalluto Comunicazione does not sell, distribute or otherwise make available to third parties (for the pursuit of their own purposes) personal data of users except with express consent of the user, or in case there is a legal obligation to communicate them.

Are user data transferred abroad?

As part of our relationship with you, we may disclose, transfer and/or store personal data abroad (i) to conclude or execute contracts directly or indirectly related to our business relationship with you, (ii) when communication is necessary to safeguard a prevailing public interest, or (iii) in exceptional cases provided for by applicable laws.

Data transfer abroad may include transfer to jurisdictions that i) ensure an adequate level of data protection for the rights and freedom of the subjects in relation to data processing, ii) benefit from adequacy decisions related to their level of protection (i.e. adequacy decisions by the European Commission or the Swiss Federal Data Protection and Information Commissioner) or iii) do not benefit from such adequacy decisions, and do not provide an adequate level of data protection. In the latter case, Spalluto Comunicazione ensures that adequate safeguard measures are in place, for example using data protection standard contractual clauses established by the European Commission.

For more information on international transfers or appropriate guarantees, you can of course contact us ([info@spalluto.ch]).

Are the data processed securely?

We are committed to ensuring the security of the data we process. In order to prevent unauthorized access or disclosure, we have put in place adequate physical, electronic and managerial procedures to safeguard and protect the information collected.

How are cookies and Google Analytics used?

Our website may use technical cookies. A cookie is a small file that asks permission to be placed on the hard drive of the user’s computer. Unless this function is deactivated on the user’s browser, the file will be added and the cookie will help analyze web traffic, and let us know when you visit a specific website.

The cookies in use on our website allow web applications to respond to the user as an individual. The web application can offer customized services depending on the user’s needs and tastes, collecting and storing information about his/her preferences.

Overall, cookies help us provide a better website, allowing us to monitor which pages users find useful, and which they do not. Cookies do not give us access to computers, or provide information about users, besides the data that users choose to share with us.

You can choose to accept or decline cookies. Most browsers automatically accept cookies, but usually everyone can change their browser settings to refuse cookies if they prefer so. However, this could prevent you from taking full advantage of the website and its functions.

This website uses Google Analytics, a web-analysing service by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (“Google”). Google Analytics uses cookies. The information created by this cookie regarding the usage of this website (including the IP addresses) is sent to, and saved onto, a Google server in the USA. If you activate IP-anonymity on this website, within Member States of the European Union or the European Economic Area or in Switzerland, your IP address will be shortened by Google beforehand. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. Google will use this information to analyse the usage of the website, compile reports on the web traffic for the website owners and provide other services related to the usage of the website and the Internet. Furthermore, Google will send this information to third parties only if required by law or if third parties will process this information on behalf of Google. The IP address disclosed by the user’s web browser in the context of Google Analytics will not be merged with all the other data compiled by Google. By using this website, you agree to the processing of your data collected by Google in the manner described above and for the aforementioned purpose.

Is there any use of links to other websites or to external services?

Our website may include materials and information from third-party suppliers, such as advertising material, news, social media interfaces, etc. This content and all related functionalities are not controlled by us, and we are not responsible for how third-party suppliers might use personal data collected during user visits to materials and information provided by said third-party suppliers. Users must refer to information on the privacy policy of the relevant third-party supplier.

Our website contains in particular links to our pages and/or publications on Facebook, Twitter, Instagram, Linkedin, youtube. Please be aware that, when the user follows said links and leaves our site, we have no control over the data processing performed on such other websites. Therefore, we cannot be held responsible for the protection and privacy of the information provided during the visit of these sites or for the personal data collection performed by means of tracking tools used on such websites. The data processing on such websites is not governed by this privacy statement, but by the privacy policy applicable to the relevant website.

Furthermore, in the case of user contributions on the Spalluto Comunicazione pages of social media sites such as, but not limited to, Facebook and LinkedIn, Spalluto Comunicazione is not responsible for the processing of personal data by these sites. Any information that the user provides through the use of these features is governed by the appropriate privacy policy of the relevant third-party supplier, and not by this document. We have no control over this, and we are not responsible for how third-party suppliers might use information provided through this functionality.

What are the rights of users regarding their personal data?

Each user has the following rights:

• the right to access personal data and to receive a copy;
• the right to rectify incorrect personal data;
• the right to erase data in the event that they are no longer necessary in relation to the purposes for which they were collected or processed, or when their processing is no longer lawful for other reasons (in this case, this right is however limited by the duration of data retention mentioned in the following chapter);
• the right to request processing limitation (pursuant to the conditions provided for by data protection regulations);
• the right to object to data processing. Despite the user’s opposition, Spalluto Comunicazione may nevertheless continue to process the data if the processing (i) is imposed by a legal obligation, (ii) is necessary to fulfill the contractual obligations with the user or (iii) is necessary to pursue the legitimate interests of Spalluto Comunicazione (i.e. preparing a legal dispute). On the other hand, the right to object is not limited if the user objects to receiving communications from Spalluto Comunicazione relating to products and services;
• where applicable, the right to data portability, i.e. the right to request that personal data be transferred to the customer or other data controller in electronic format.

Where applicable, individual users also have the right to lodge a complaint with a competent authority for data protection.

The user can finally withdraw consent to the processing of personal data granted to Spalluto Comunicazione at any time. Please note that the revocation of consent will have no effect on the validity of data processing prior to revocation.

The aforementioned rights may be exercised by e-mail (to [info@spalluto.ch])or by letter.

What is the duration of data retention?

We will process and store the personal data of users for as long as necessary in order to comply with our contractual and legal obligations. We will delete or make personal data anonymous once they are no longer necessary to achieve the aforementioned purposes, unless (i) any applicable legal or regulatory provision regarding the retention of personal data requires retention for a longer period or (ii) conservation is necessary to prepare, exercise or defend against actual or potential legal actions, investigations or similar procedures.

Do we use automated decision-making processes or profiling methods?

In the constitution and execution of contractual relations with the user, Spalluto Comunicazione does not use any automated decision-making process and does not use profiling methods. If in individual cases we should use these procedures, we will give you appropriate communication where required by law.