Privacy policy
https://per4m.ch/ (“Website”) is solely owned by Per4m S.A., Via Maderno 6, CH-6900 Lugano, Tel. +41 (0)91 912 10 60, Switzerland, admin@per4m.ch ("Company" or “we”).
PRIVACY NOTICE FOR CLIENTS AND PROSPECTS
Notice pursuant to, and for the purposes of, the Federal Act on Data Protection (FADP) For the purposes of the above-referenced law, which sets out new provisions for the protection of “privacy” and relating to the protection and processing of personal data, please be informed that the personal data already provided by and obtained from you to date, as well as any data to be provided in the future, will be processed in accordance with the applicable regulations and the obligations of confidentiality and transparency to which the Controller is subject.
a) Controller
The Controller is PER4M SA, with registered office in Lugano at Via Carlo Maderno 6, acting in the name and on behalf of its legal representative (hereinafter, “PER4M” or the “Company”).
b) Data collected
- Identity information such as first name, surname, date of birth, address, company name, photograph, e-mail address, place of residence, identity document, proof of residence;
- Personal data for the performance of the professional engagements entrusted and the other professional services requested (e.g. identification documents, list of personal assets and income, list of personal real estate assets, banking documents, information on marital/family status or family members, etc.);
- Personal data relating to criminal or administrative proceedings (criminal record, judgments, newspaper articles, etc.).
c) Purposes of the processing
The personal data provided are necessary for identification purposes, for the preparation of forms and record-keeping; for the performance of the professional engagement and the services offered; and for compliance with anti-money laundering and counter-terrorism financing regulations or other regulations binding on the Company.
d) Disclaimer
The Company may process certain sensitive personal data, such as data concerning administrative and criminal proceedings, sanctions and proceedings, including from third-party providers or external databases, such as, for example, World Check, or from the internet and other public sources, in order to comply with and fulfil the applicable statutory and regulatory anti-money laundering and counter-terrorism financing obligations. You acknowledge that the use of e-mail does not guarantee the confidentiality and integrity of data in transit, and you authorize the Company to transmit, by ordinary (unsecured) e-mail, documents and/or information, including personal and/or confidential data, using the e-mail address provided by you. Being aware of the above risks, you release the Company from any liability in the event of unauthorized access by third parties to personal and/or confidential documents and/or information transmitted or received by e-mail or through other channels chosen by you (e.g. WhatsApp). Where, for the performance of the agreement, you provide personal data relating to members of your family or other data subjects, you assume responsibility for disclosing such data to us and confirm that you have obtained their authorization to share the data.
e) Method
of processing and retention The processing of the data provided by you is carried out in automated and/or manual form in compliance with the applicable law, by specifically appointed personnel and in accordance with the applicable requirements. Please note that, in compliance with the principles of lawfulness, purpose limitation and data minimization, your personal data will be retained for the period of time necessary to achieve the purposes for which they are collected and processed, namely:
- 10 years from the end of the engagement; or
- 3 years from the last contact, in the case of a prospect.
f) Scope of communication and disclosure
We will disclose your personal data only where we are required to do so in order to comply with our legal or regulatory obligations, for corporate, administrative or contractual reasons, or because you have instructed us to do so. This also includes disclosure:
- within the Company;
- to third parties that process personal data on our behalf (namely, providers of IT systems or management software, banks, consultants, fiduciaries, insurers, professionals and other service providers);
- where applicable, to resident agents (the so-called Registered Agent) or Trustees, including in third countries, including those that may not guarantee adequate protection of privacy, for the purpose of incorporating companies or trusts requested by you;
- to any government, authority, regulatory agency, supervisory body or court that requests it pursuant to the applicable law or regulations.
The data collected by the Company are stored in Switzerland. Should we need to transfer your data outside Switzerland, we will first ensure that the data are held in countries that guarantee adequate protection of personal data, such as the Member States of the European Economic Area. Where this is not possible, we will in any case verify that the provisions of the applicable legislation on the transfer of personal data to third countries are complied with, or we will seek your consent in this regard, or we will follow your instructions.
g) Rights of the data subject
At any time, you may exercise, pursuant to the law, the right to: 1) request confirmation as to whether or not personal data concerning you exist; 2) obtain information on the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, where possible, the retention period; 3) obtain rectification and erasure of the data; 4) obtain restriction of processing; 5) obtain data portability, i.e. to receive the data from a controller, in a structured, commonly used and machine-readable format, and to transmit them to another controller without hindrance; 6) request the controller to provide access to the personal data and rectification or erasure thereof, or restriction of the processing concerning you, or to object to their processing, in addition to the right to data portability; 7) withdraw consent at any time, without affecting the lawfulness of processing based on consent given before its withdrawal; 8) lodge a complaint with a supervisory authority.
h) Exercise of rights
The rights may be exercised by written communication sent by e-mail to the address: info@per4m.ch or by registered letter with return receipt to the address: Via Carlo Maderno 6 – Lugano – c/o PER4M SA. You may also contact the Swiss data protection authority if our response does not satisfy you: http://www.edoeb.admin.ch/ tel. +41 58 462 43 95