Privacy Policy
Last updated on: 28.06.2024
We place great importance on ensuring that the handling of personal data is transparent. This privacy policy provides information about what personal data we collect, for what purpose, and to whom we disclose it. To ensure high transparency, this privacy policy is regularly reviewed and updated.
1. Services we use
- Google Analytics
- Webflow
2. Contact Information
If you have any questions or concerns about our protection of your data, you can contact us at any time via email at info@cilaros.ch. The entity responsible for data processing carried out through this website is:
Cilaros Family Office
Bahnhofstrasse 44
8001 Zürich
Switzerland
Data Protection Officer:
Norbert Klein
info@cilaros.ch
3. General Principles
3.1 What data do we collect from you and from whom do we receive this data
Primarily, we process personal data that you transmit to us or that we collect when operating our website. In certain circumstances, we also receive personal data about you from third parties. These may include the following categories:
- Personal data (name, address, date of birth, etc.);
- Contact data (mobile number, email address, etc.);
- Financial data (e.g., account information);
- Online identifiers (e.g., cookie IDs, IP addresses);
- Location and traffic data;
- Audio and video recordings;
- Particularly sensitive data (e.g., biometric data or information about your health).
3.2 Under what conditions do we process your data?
We treat your data confidentially and in accordance with the purposes outlined in this privacy policy. We ensure transparent and proportionate processing.
If, in exceptional cases, we are unable to adhere to these principles, data processing may still be lawful due to a justification basis. Justification bases include:
- Your consent;
- The performance of a contract or pre-contractual measures;
- Our legitimate interests, provided your interests do not outweigh them.
3.3 How can you withdraw your consent?
If you have given us consent to process your personal data for specific purposes, we will process your data within the scope of this consent unless we have another justification basis.
You can withdraw your consent at any time by sending an email to the address provided in the imprint. Data processing that has already occurred is not affected by this.
3.4 In which cases can we disclose your data to third parties?
a. Principle
We may need to use the services of third parties or affiliated companies and commission them to process your data (so-called processors). Categories of recipients include, in particular:
- Accounting, trust, and auditing firms;
- Consulting firms (legal advice, taxes, etc.);
- IT service providers (web hosting, support, cloud services, website design, etc.);
- Payment service providers;
- Providers of tracking, conversion, and advertising services.
We ensure that these third parties and our affiliated companies comply with data protection requirements and treat your personal data confidentially.
In certain circumstances, we may also be required to disclose your personal data to authorities.
b. Visiting our social media channels
We may embed links to our social media channels on our website. This is usually indicated by corresponding symbols. If you click on these symbols, you will be redirected to our social media channels.
In this case, the social media providers will know that you are accessing their platform from our website. The social media providers may use the collected data for their own purposes. We point out that we have no knowledge of the content of the transmitted data and their use by the operators.
c. Transfer abroad
In the course of order processing, your personal data may be transmitted to companies abroad. These companies are subject to the same data protection obligations as we are. The transmission can take place worldwide.
If the level of data protection does not correspond to that of Switzerland, we carry out a prior risk assessment and contractually ensure that the same protection as in Switzerland is guaranteed (e.g., by means of the new EU Commission Standard Contractual Clauses or other legally prescribed measures). If our risk assessment is negative, we take additional technical measures to protect your data. You can access the EU Commission's Standard Contractual Clauses at the following link: https://commission.europa.eu/publications/standard-contractual-clauses-controllers-and-processors-eueea_de
3.5 How long do we retain your data?
We only store personal data for as long as it is necessary to fulfill the specific purposes for which the data was collected.
Data that we store during your visit to our website is kept for twelve months. An exception applies to analysis and tracking data, which may be retained for a longer period.
We retain contract data for a longer period because we are legally required to do so. Specifically, we must retain business communications, concluded contracts, and booking records for up to 10 years. Once we no longer need such data from you for the provision of services, the data will be locked and only used for accounting and tax purposes.
3.6 How do we protect your data?
We will keep your data secure and take all reasonable measures to protect it from loss, access, misuse, or alteration.
Our contractors and employees who have access to your data are obligated to comply with data protection regulations. In some cases, it may be necessary for us to forward your requests to affiliated companies. Even in these cases, your data will be treated confidentially.
Within our website, we use the SSL (Secure Socket Layer) protocol in connection with the highest encryption level supported by your browser.
3.7 What rights do you have?
a. Right to information
You can request information about the data we have stored about you at any time. Please send your request for information along with proof of identity to info@cilaros.ch.
You also have the right to receive your data in a commonly used file format if we process your data automatically and if:
- You have given your consent for the processing of this data; or
- You have disclosed data in connection with the conclusion or execution of a contract.
We may restrict or deny the provision of information or data release if this conflicts with our legal obligations, our legitimate own or public interests, or the interests of a third party.
The processing of your request is subject to the legal processing period of 30 days. However, we may extend this period due to high request volume, legal or technical reasons, or because we need further details from you. You will be informed of the extension of the deadline in due time, at least in text form.
b. Deletion and Correction
You can request the deletion or correction of your data at any time. We may refuse the request if legal regulations require us to retain the data for a longer period or if there is a legal basis opposing your request.
Please note that exercising your rights may conflict with contractual agreements and may have corresponding effects on contract performance (e.g., premature termination of the contract or cost implications).
c. Legal Recourse
If you are affected by the processing of personal data, you have the right to enforce your rights through the courts or to file a complaint with the competent supervisory authority. The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch
3.8 Changes to the Privacy Policy
We may change this privacy policy at any time. The changes will be published on https://www.cilaros.ch, and you will not be separately informed.
4. Individual Data Processing Operations
4.1 Provision of the Website and Creation of Log Files
What information do we receive and how do we use it?
By visiting https://www.cilaros.ch, certain data is automatically stored on our servers or on the servers of services and products that we use and/or have installed, for the purposes of system administration, statistical analysis, security, or tracking. This data includes:
- The name of your internet service provider;
- Your IP address (if applicable);
- The version of your browser software;
- The operating system of the computer used to access the URL;
- The date and time of access;
- The website from which you accessed the URL;
- The search terms you used to find the URL.
Why are we allowed to process this data?
This data cannot be associated with any specific person and is not combined with other data sources. The storage of log files is to ensure the functionality of the website and to ensure the security of our information technology systems. This constitutes our legitimate interest.
How can you prevent data collection?
The data is stored only as long as necessary to achieve the purpose for which it was collected. Accordingly, the data is deleted after the end of each session. The storage of log files is essential for the operation of the website; therefore, you have no option to object to this.
4.2 Google Analytics
We use Google Analytics on our website, a web analytics service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site.
The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is activated on this website, your IP address will be truncated beforehand by Google within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage.
The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
You can prevent the storage of cookies by adjusting your browser software settings accordingly; however, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google's collection and use of data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout.
4.3 Webflow
We use services from Webflow on our website, a web design tool and hosting service provided by Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA. Webflow allows us to create and host an appealing and user-friendly design for our website.
When you visit our website hosted via Webflow, various data may be collected, including your IP address, date and time of access, browser type, operating system, and information about the pages and content you access. This data is primarily used for statistical purposes and to optimize the user experience.
Webflow may place cookies on your device to store your preferences and interactions with our website. This helps facilitate navigation and ensure a consistent user experience.
The main purpose of data processing by Webflow is to provide and optimize our website to present relevant content in an appealing design.