Data Protection Statement of the Law and Notary Firm Lawyer Niccolò Salvioni, Locarno, Canton of Ticino, Switzerland

FOREWORD

This declaration describes the terms of use and the policy regarding personal data of the website https://www.salvionilaw.ch (hereinafter referred to as “website”) of the Legal and Notarial Firm Lawyer Niccolò Salvioni (hereinafter also referred to as “Studio Salvioni”) based in Locarno, Canton Ticino, Switzerland, and its co-collaborators as well as the aspects of using the legal and notarial services offered by Studio Salvioni from a data protection perspective.

The purpose of this statement is to follow up on the legal obligation to inform the holder of personal data regarding his or her rights even when he or she enters into a contractual relationship of power of attorney and mandate even vis-à-vis a lawyer or notary public, whether within the scope of a monopoly of the profession or outside of it in the scope of simple advice. In fact, Article 19 of the Swiss Federal Data Protection Act of 2020 (DPA – SR 235.1) requires that “The data controller shall inform the data subject adequately about the collection of personal data.” Ticino’s attorney is also subject to this obligation, whether acting in the scope of monopoly activities-with the reservations specified below-or acting as a consultant.

Relationships of power of attorney and mandate, when requested and accepted by Studio Salvioni are governed in det- detail by the following forms:

• the Power of Attorney, with -when necessary- the Information and express consent to the processing of personal data, which in turn refers to this Data Protection Statement of the Law and Notary Firm Lawyer Niccolò Salvioni, Locarno, Canton Ticino, Switzerland;
• the Mandate, with its list of Parameters of Expenses.

On the basis of Article 321 of the Swiss Criminal Code (SCC), lawyers, notaries and their auxiliaries are bound to professional secrecy, which is thus fundamentally criminally protected.

For one’s activity as a lawyer registered in the register of lawyers of the Canton of Ticino, within the scope of Art. 6 para. 6 DPA (processing of personal data worthy of special protection), the principle of the express consent of the data subject to the processing of data by a lawyer’s is provided for in the following cases:

• Art. 5 lit. c DPA establishes which are “data worthy of special protection” data concerning religious, philosophical, political or trade union opinions or activities; data concerning health, intimate sphere or membership in a race or ethnic group; genetic data; biometric data that uniquely identify a natural person; data concerning administrative and criminal prosecutions and sanctions; data concerning social welfare measures, or others that have been specified by case law;
• if applicable to the case, Art. 17 DPA provides that, the consent of the data subject to the communication of data in nations that -ex art. 16 DPA- do not guarantee adequate data processing, is a valid derogation from the provisions of Art. 16 DPA, regarding the principles of data transmissions abroad;
• for activities in relation to citizens who are in the European Union ex Art. 3 para. 2 of the European Regulation 2016/679 (GDPR), Art. 6 lit. a) GDPR provides that processing is lawful as long as the data subject has given consent to it for a specific purpose or purposes, while Art. 12 provides for the duty to provide the data subject with all the information required by Art. 13 GDPR (information to be provided if the data are collected by the data subject) and Art. 14 GDPR (if the same were collected by third parties);

According to Art. 2 para. 3 DPA, this law does not apply to the lawyer in the case of processing of personal data and rights of data subjects in judicial proceedings and proceedings according to the federal procedural orders are governed by the applicable procedural law, while provisions of the DPA apply to administrative proceedings at first instance.

For his part, his activity as a Notary registered in the Notary Register of Canton Ticino, as a public official under Article 1 of the Notary Law (LN), is subject by Article 2 of the Data Protection Law of Canton Ticino (LCPD – RL 163.100), as a person under private law to whom public tasks are delegated.

Regarding the principle of express consent of the data subject to the data processing of a notary public in Canton Ticino, the following should be noted:

• Article 6 LCPD provides that the processing of data in the individual case may also be justified by the necessity for the performance of a legal task or by the consent of the data subject.
• Art. 10 lit. c) LCPD with regard to personal data may be transmitted to public bodies, provides that it is necessary that the data subject, in the individual case, has given consent or the circumstances allow for the presumption of consent; and, since it is personal data deserving special protection, the consent must be explicit.
• Article 14 lit b) LCPD provides that personal data may be transmitted abroad only if the data subject has given consent in the specific case.

So, in relation to the personal data that Studio Salvioni in Locarno, Switzerland, will come into the disponibility of because of the power of attorney and the mandate related to the legal and/or notarial practice conferred, these may fall within the scope of the applicable data protection provisions depending on the activities to be carried out in the interest of the client. 

If this is required by the laws applicable to the case, in order to be able to process the data in accordance with the mandate received, when such data fall within the category of personal data deserving -or worthy- of special protection, we will ask the client to sign the special Information and express consent to the processing of personal data. In cases where express consent is not required instead, the reference to the applicable provisions contained at the bottom of the Power of attorney form will suffice.

1. DATA PROTECTION DECLARATION: WHAT IS IT ALL ABOUT?

Studio Salvioni is a legal and notarial firm based in Locarno, canton of Ticino, Switzerland. As part of our business activities, we collect and process personal data, in particular personal data about our clients, related persons, counterparts, courts and authorities, corresponding law firms, professional and other associations, visitors to our website, participants in events, events, research publications, possible newsletter recipients, and other entities or their contact persons and employees.

In this Data Protection Statement, we inform about such data processing.

If you provide us with data about other persons (e.g., family members, representatives, counterparts, or other related persons), we assume that you are authorized to do so and that these data are correct and that you have ensured that these persons are informed of the disclosure where there is a legal obligation to inform (e.g., by previously bringing them to the attention of this Data Protection Statement).

Personal data recorded by us based on the use of our website or as a result of a notification by the user are treated with the utmost care. We take technical and organizational security measures to protect your personal data, and such personal data is saved and/or processed only within the scope of its intended use. Your personal data in principle will not be disclosed to third parties unless this is necessary within the scope of the execution of the mandate received.

We would like to point out that Studio Salvioni has limited influence on the corresponding, possible, unauthorized processing of electronic personal data, especially those subject to telecommunication object, by intelligence, police or other security authorities or internal or external services. If you wish us to take enhanced security measures for your personal data, it is your responsibility to inform us in advance. Such augmented measures may result in additional expenses or costs.

The form for making inquiries to Studio Salvioni is equipped with SSL (secure socket layer) protocol disconnection system, equipped as such with cryptographic protocols such as to ensure basic secure communication between source and recipient. Nevertheless, as specified below in no. 3 about communication by E-Mail, we advise against its use in the case of communication of confidential or particularly sensitive data or information.

Studio Salvioni is in principle opposed to the use of the Firm’s e-mail address or website as a means of receiving or sending to third parties unwanted, non-contextual advertising or “spamming” and in principle does not send newsletters.

2. WHO IS THE DATA CONTROLLER?

Art. 19 DPA and when applicable, Art. 13 GDPR, require the data controller of collected data to provide certain information to the data subject. This duty is followed up by the Studio as follows.

Responsible under the Data Protection Act for the processing described in this data protection declaration:

lawyer Niccolò Salvioni *

Niccolò Salvioni Law and Notary Firm

Via della Gallinazza 6

6600 Locarno

Switzerland

tel. 0041 (0)91 751 12 38

fax 0041 (0)91 751 94 84

info@salvionilaw.ch

(*lawyer registered in the Register of Lawyers of Canton Ticino and member of the Order of Notaries of Canton Ticino, Switzerland)

As part of the management of the website https://www.salvionilaw.ch and related resources (web-design, maintenance, and hosting), as well as the management of IT Studio Salvioni makes use of external providers of goods and/or services active in the Canton of Ticino or Switzerland, for which the relevant data are stored in/accessible from the Canton of Ticino or Switzerland. These external suppliers/service providers have access to the data only to the extent necessary for the proper and efficient performance of their tasks, subject to assumption of an obligation of confidentiality and non-use in relation to the users’ Personal Data. Studio Salvioni’s e-mail server, electronic database -both cloud and local- and paper archive are managed internally and are accessible only to Studio Salvioni’s staff, as well as external IT re-sponsors functionally involved in systems maintenance activities. IT managers are active and established in Ticino or Switzerland and are bound by obligations of confidentiality and non-use in relation to users’ personal data.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?

When you use our services, use the website, or otherwise deal with us, we collect and process different categories of personal data. In principle, we may collect and otherwise process this data in particular for the following purposes:

• Communication: we process personal data in order to be able to communicate with you and third parties, such as parties to the proceedings, courts or authorities, via e-mail, transmission systems via drop in encrypted secure sharing systems based in Switzerland, telephone, letter, Whatsapp or otherwise (e.g. to respond to inquiries, in the context of legal advice and representation, as well as the initiation or execution of contracts). For this purpose, we are authorized to process in particular the contents of the communication, your contact data and marginal communication data, but also image and audio recordings of (video) phone calls. In case of audio or video recording, we will inform you separately about this and you are free to communicate with us if you do not want any recording or if you want to stop the communication. When we are required to establish your identity, we collect additional data (e.g., a copy of an identity document). Studio Salvioni can be contacted at the e-mail address info@salvionilaw.ch. Communications pertaining to the relationship between the parties shall be effected in writing and shall be deemed to be validly and effectively executed upon receipt thereof, if made by regular mail, respectively upon receipt of the read conformation, if made by electronic mail.
• Communications via electronic mail (or WhatsApp): The website may collect personal data provided by the user, through the receipt of electronic mail (E-Mail) communications via the “contact” function of the website or via the address in-fo@salvionilaw.ch. It is recommended not to transmit through the contact system or to the E-Mail address of the Firm of information and/or documents containing particularly sensitive personal and/or confidential information, since this is an insecure means of communication and does not guarantee the protection of confidentiality. The user in principle authorizes Studio Salvioni to transmit by ordinary (non-secured) e-mail documents and/or information, including those containing personal and/or confidential information, using the E-Mail address (or WhatsApp) provided by the user in response to user requests received by fax, telephone or e-mail. The user, in full awareness of the risks, releases the Firm from any liability in the event of unauthorized access by third parties to documents and/or personal and/or confidential information transmitted or received via E-Mail or WhatsApp from the Firm. Studio Salvioni is available to provide the user with alternative encrypted and securitized electronic document drop communication channels, should this be desired.
• Other personal information, such as, for example, information concerning 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 analyzed, in an automated and anonymized manner, exclusively to evaluate the introduction of new features, to improve the quality of the services offered and to optimize the usability of the website.
• The website does not process or broadcast content or advertisements designed based on online behavior, profile users, or monitor the use of web resources or e-mail. The website does not sell, rent, trade, and/or lend personal data to third parties.
• Initiating and entering into contracts: with a view to entering into a contract, such as in particular a contract for the establishment of a mandate relationship, with you or your principal or employer, including the investigation of possible conflicts of interest, we may collect and otherwise process in particular, your names, contact details, powers of attorney, declarations of consent, information about third parties (e.g. contact persons, family and con-tact data), contract contents, date of contracting, solvency data, as well as any other data you make available to us or that we collect from public sources or third parties (e.g., commercial registry, companies providing solvency data, sanction lists, media, legal protection insurance, or from the Web).
• Contract management and performance: we collect and process personal data to fulfill our contractual obligations to our clients and other contractual partners (e.g., suppliers, service providers, corresponding law firms, project partners, translations, anonymized internal researches including those based on artificial intelligence systems) and in particular to be able to provide and enforce contractual services. This also includes data processing for the execution of mandates (e.g., legal advice and representation of our clients before courts and authorities, and correspondence) and data processing for the execution of contracts (collection, court proceedings, etc.), accounting, and -where permitted and authorized according to the mandate- public communication. To this end, we process in particular data that we receive or have collected as part of the initiation, conclusion and execution of the contract, as well as data that we create as part of our contractual performance or that we collect from public sources or other third parties (e.g., courts, authorities, counterparties, information services, media, investigative agencies or from the web). Such data may include, in particular, minutes of interviews and consultations, notes, internal and external correspondence, contractual do-documents, documents that we prepare and receive in the context of proceedings before courts and authorities (e.g., case files, appeals and appeals, judgments and decisions), general information about you, counterparties, or other persons, as well as additional information related to the mandate, performance slips, invoices, and financial and payment information. 
• Management of our website: to securely and stably manage our website, we collect technical data, such as IP address, information about your terminal’s operating system and settings, region, time and type of use. In addition, we use cookies and similar technologies. For more information see No. 8.
• Improvement of our electronic offerings: to continuously improve our website, we may collect data about your behavior and preferences, e.g., by analyzing the way you navigate our website.
• Security purposes and access controls to premises and facilities: we collect and process personal data to ensure and continuously improve adequate security of our IT and other infrastructure. These include the surveillance and control of electronic access to our IT systems, as well as physical access to our premises, analysis and testing of our IT infrastructure, systems and error checks, and the establishment of security copies. For documentation and security purposes (as a preventive measure and for the clarification of incidents), we also keep access protocols and visitor lists on our premises and apply surveillance systems (e.g., security cameras or other). The presence of surveillance systems is signaled at the relevant venues through appropriate signs.
• Compliance with laws, directives and recommendations of authorities and internal regulations (“Compliance”): we collect and process personal data in order to comply with applicable laws (e.g., for anti-money laundering, tax obligations or our professional obligations), self-regulations, certifications, industry standards, our “corporate governance” as well as for internal and external investigations to which we are (in the process) a party (e.g., through a prosecuting or supervisory authority or a mandated private entity).
• Risk management and business management: we collect and process personal data in the context of risk management (e.g. for protection against criminal activities) and business management-le. This includes, among other things, our business organization (e.g., re-source planning) and business development (e.g., buying and selling sectors or businesses).
• Application for a position: if you apply for a position with us, we collect and process the relevant data for the purpose of reviewing the application, carrying out the candidature procedure, and, in the case of successful applications, preparing and entering the relevant contract. For this purpose, in addition to your contact data and the data contained in the relevant communication, we also process the data contained in your application documents and data that we may additionally collect about you, e.g. from professional social networks, the web, the media and references, if you consent to the collection of references. The processing of data in connection with the employment relationship is the subject of a separate data protection statement.
• Additional purposes: other purposes include, for example, training, education or research, as well as administrative purposes (e.g., accounting). We may listen to or record telephone and video conferences for training, evidentiary, and quality assurance purposes. In those cases, we will inform you separately (e.g., by means of a display during the video conference in question) and you will be free to tell us if you do not want the recording or stop the communication (if you do not want your image recorded, please turn off the camera). In addition, we may process personal data for the organization, conduct and follow-up of events, such as lists of participants and content of reports and discussions, but also audio and video recordings that are made during such events. The protection of other legitimate interests is also among the additional finalities, which cannot be mentioned exhaustively.

4. WHERE DOES THE DATA COME FROM?

• From you: you, either personally or by delivery or exhibition of documents or certificates, or by submissions, your terminal, by videoconferencing, or by encrypted and secured document drop exchange services that we may provide to you, disclose to us most of the data we process, e.g., in connection with our professional services, use of our website and apps, or communication with us). Based on the new Article 8 of the Swiss Code of Ethics (SCC), “A lawyer shall verify the identity of his or her clients with due care“. With the exception of individual cases (e.g. legal obligations), you are not obliged to co-disclose your data. However, if, for example, you enter contracts with us or wish to use our services, you must provide us with certain data necessary to be able to carry out the requested activities. If you refuse to provide personal data, this may make it impossible for us to carry out the activities mentioned in No. 1. The use of our website is also not possible without the processing of data.
• Contact form and inquiry by short message from our website 

The contact form on the website can be used as an alternative to sending an E-Mail message and is intended only for persons who are at least 18 years of age.

The form to formulate questions to the Firm is equipped with SSL (Secure Socket Layer) protocol connection system, equipped as such with cryptographic protocols such as to ensure secure co-communication between source and recipient.

Regarding the contact form, in order to process your request, if you communicate it to us through the contact form, we process the following personal data about you:

first name,

surname,

e-mail address,

street,

city,

country,

subject of the request and

brief content of the request,

within a reasonable period of time and in the manner we deem most appropriate to protect your personal data in relation to the case submitted.

The legal basis for this processing is your consent to processing pursuant to Art. 4 of the Swiss Federal Data Protection Act (DPA – SR 235.1) and/or Art. 6 of the Data Protection Act of the Canton of Ticino (DPA – RL 163.100) and/or Art. 4 para. 6.1.a) GDPR if applicable.

We are assisted in the operation of our contact form by our information technology service providers, located in Switzerland, who may possibly have access to this data.

It is not possible for us to process your request without also receiving the data needed to be able to contact you and to understand and process the request. The provision of further information is optional.

You may withdraw your consent to the processing of the data provided at any time with effect for the future.

In the case of questions formulated by means of a contact form, we will endeavor to respond in as reasonable a time as possible during the applicable office hours in Canton Ticino, considering in any case the following:

• In the case of confidential information or questions, susceptible to protection in the context of professional secrecy, it is in any case always advisable to avoid transmitting such information via the Internet, despite the data protection systems put in place. In such a case, it is preferable that you make an appointment to discuss the matter with a lawyer or notary you trust.
• In case the problem you have to deal with is subject to legal deadlines for reaction, it is advisable, in parallel with sending the short application, that you make contact by telephone with the professional identified to you, in order to clarify the need to act within a given deadline and quickly agree on the conditions for accepting or not accepting a mandate.
• A question from you via Contact Form or e-mail message does not represent the establishment of a contractual mandate relationship with the Firm, nor is it likely to give rise to any liability of the Firm, for any reason whatsoever.
• From third parties: we may also obtain data from publicly accessible sources (e.g., enforcement registry, land registry, commercial registry, media or web, incl. social media or open sources) or receive it from (i) authorities, (ii) your employer or principal, who has a business relationship or otherwise has anything to do with us, as well as from (iii) other third parties (e.g. clients, counterparties, legal protection insurances, credit information agencies, address com- merchants, associations, contractual partners, web analytics services). This includes data that we process as part of the initiation, conclusion, and execution of contracts, as well as data from correspondence and interviews with third parties, but also all other categories of data in accordance with Chapter 3. If, to be able to access such privileged information for the purpose of carrying out the mandate, explicit consent on your part is required, this will be given by signing the Information and express consent to the processing of personal data which will be signed at the time the mandate is given, or posteriorly, should the need arise. 

5. TO WHOM DO WE DISCLOSE YOUR DATA?

Within the scope of the purposes stated in number 3, we will transmit your personal data, or only a selected part thereof, to the following categories of recipients. Where necessary, we will request your consent for this purpose or request our supervisory authority to release us from our obligation of confidentiality. 

• Related law firms: Subject to your explicit authorization, domestic or foreign correspondent law firms may use your data, as described in this data protection statement, for the same purposes as we do (see No. 3). In general, recipients process data on their own responsibility.
• Service providers: we cooperate with service providers in Switzerland and abroad, who (i) on our behalf (e.g., IT service providers), (ii) under our joint responsibility or (iii) under their own responsibility process the data they have received from us or collected for us. (This category includes e.g. IT service providers, banks, insurance companies, collection companies, companies providing solvency data, address auditors, other le-gal firms or consulting firms, translation or special analysis services including through artificial intelligence services.) As a rule, we enter into contracts with these third parties on the use and protection of personal data.
• Customers and other contractual partners: referring primarily to our customers and our other contractual partners for whom the transmission of your data under the contract results (e.g. because you work for a contractual partner or the latter provides services for you). Also included in this category of recipients are entities with which we cooperate, such as other law firms in Switzerland and abroad or even legal protection insurances. In principle, recipients process data under their own responsibility.
• Authorities and courts: we may transmit personal data, or parts thereof, to offices, courts, and other authorities in Switzerland and abroad, if this is necessary for the fulfillment of our contractual obligations and for the execution of mandates, if we are legally obligated or self-required to transmit personal data, or if this appears necessary to protect our interests. Recipients process data under their own responsibility.
• Counterparties and involved persons: if necessary for the fulfillment of our con-contractual obligations, for the execution of mandates, we also transmit your personal data to counterparties and additional involved persons (e.g. guarantors, lenders, related companies, other firms, factfinders or experts, etc.).
• Other persons: this refers to other cases where the involvement of third parties is evident from the purposes mentioned in No. 3. This concerns e.g., delivery or payment recipients named by you, third parties in the context of representative relationships (e.g., your lawyer or bank) or persons involved in administrative or judicial proceedings. We also have the option of passing on your personal data to our supervisory authorities, particularly if this is necessary in the individual case for release from our obligation of secrecy. You may also be interested in data processing if, within the scope of the mandate, in your interest and explicit authorization, within legal limits, it is necessary to cooperate with the media, transmitting material (e.g., photos or other) to them. In the context of business development, we may buy or sell businesses, parts of businesses, assets or companies, or create partnerships that may com-port the disclosure of data (including about you, e.g., as a customer or supplier or representatives of the same) to those involved in these transactions. In the context of communicating with competitors, trade organizations, associations and other entities, an exchange of data about you may also take place.

All these categories of recipients may in turn involve third parties, so that your data may also be accessible to them. We may restrict processing by certain third parties (e.g. IT service providers), but not by other third parties (e.g. authorities, banks, etc.).

At special events we may also allow certain third parties to collect personal data about you on our website and at events on our part for them (e.g., media photographers, providers of tools we have placed on our website, etc.). To the extent that we do not participate decisively in such data collections, the responsibility lies solely with such third parties, whom we therefore invite you to contact directly with any questions and to assert your data protection rights. We have listed your rights in No. 7. You can find information about the activities on our website at No. 8. Personal data are not subject to dissemination.

6. DOES YOUR PERSONAL DATA ALSO GO ABROAD?

Personal data may be transferred to countries within the European Union and to third countries within the scope of the purposes mentioned in No. 1. We process and store personal data primarily in Switzerland and the European Economic Area (EEA), as appropriate-for example, through sub-processors of our service providers, corresponding attorneys, or in proceedings before foreign courts and authorities-but potentially to any country in the world. Even in the context of our client business, your personal data can reach any country in the world.

If a recipient is located in a country that does not guarantee an adequate level of data protection, we will contractually obligate the recipient to comply with an adequate level of data protection (for this purpose, we use the European Commission’s revised model contractual clauses, found here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? including the necessary additions for Switzerland), to the extent that the recipient is not already subject to legally recognized data protection guarantee legislation. We may also disclose personal data in a country without adequate data protection, without entering into our own contract, if we can rely on a derogatory provision for this purpose. An exception may apply in particular in the case of legal proceedings abroad, but also in the case of overriding public interests or if the performance of a contract in your favor requires such disclosure (e.g., if we disclose data to our corresponding law firms), if you have consented, or it is not possible to obtain your consent within a reasonable period of time and the disclosure is necessary to protect your life or physical integrity or that of a third party, or if it involves data that you have made generally accessible and to the processing of which you have not objected. In certain circumstances, we also rely on the exception for data from a legally required registry (e.g., Trade Registry), which we have legitimately been able to view.

7. WHAT RIGHTS DO YOU HAVE?

In connection with our data processing, you are entitled to certain rights. In accordance with applicable law, you can request information about the processing of your personal data, have inaccurate personal data corrected, demand the deletion of personal data, object to the processing of data, demand the delivery of certain personal data in a standard electronic format or its transmission to other data controllers.

If you wish to exercise your rights vis-à-vis us, please contact us; our contact information can be found in No. 2. To rule out abuse, we need to identify you (e.g., with your ID, if necessary). 

Please note that these rights are subject to conditions, exceptions or restrictions (e.g. to protect third parties, trade secrets or because of our obligation of secrecy). We reserve the right to black out copies or to provide only extracts for reasons related to data protection legislation or for reasons of secrecy. In certain special cases, if so prescribed by law, access to data may be denied, particularly to third parties.

In the European context under Art. 15 (Right of access), 16 (Right to rectification), 17 (Right to erasure), 18 (Right to restriction of processing), 20 (Right to data portability), and 21 (Right to object) of the EU Regulation 2016/679 (GDPR), if applicable, the data subject may at any time request access to and rectification or erasure of personal data or restriction of processing concerning him or her or object to its processing, in addition to the right to data portability, by submitting written notice to the Data Controller. The data subject may also lodge a complaint with the Supervisory Authority of the state where he or she resides or works.

8. HOW ARE COOKIES, SIMILAR TECHNOLOGIES AND SO-CIAL MEDIA PLUG-INS USED IN OUR WEBSITE AND OTHER DIGITAL SERVICES?

During the use of our website, data, stored in protocols (especially technical data) result. In addition, we may employ cookies and similar techniques (e.g., pixel tags or fingerprints) to recognize website visitors, analyze their behavior, and recognize their preferences. A cookie is a small file that is transmitted between the server and the user’s system that allows a deter-mined device or browser to be recognized. 

You can set your browser to automatically reject, accept or delete cookies. You can also disable or delete cookies in individual cases. You can find out how to manage cookies in your browser in your browser’s help menu.

Neither the technical data we collect nor the cookies generally contain personal data.

We also use social media plug-ins, which are small pieces of software that create a connection between your visit to our website and a third-party provider. The social media plug-in will tell the third-party provider that you have visited our website and may transmit to the third-party provider cookies that they have previously installed on your web browser. Find more information on how these third-party service providers use your personal data collected through their social media plug-ins in their respective data protection statements.

In addition, we use our own tools and services of third-party providers (who in turn may use cookies) on our website, to improve the functionality or content of our website (e.g. integration of videos or maps), to set up statistics.

We may currently use the offerings of the following service providers and public-tary partners, in which case their contact details and further information regarding individual data processing can be found in the respective data protection declaration:

• Google Analytics 

Service provider: Google Ireland

Data protection statement: https://support.google.com/analytics/answer/6004245

Information for Google accounts: https://policies.google.com/technologies/partner-sites?hl=it 

Some of the third-party providers we employ may be located outside Switzerland. Please see No. 6 for information regarding the disclosure of data abroad. From the point of view of data protection law, they are partly “only” responsible for processing by us and partly re-sponsible bodies. Further guidance on this can be found in the data protection declarations.

The data collected are reviewed exclusively by Studio Salvioni internally, periodically and primarily to assess the geographical area of origin of those who express interest in Studio Salvioni. This information can give useful indications regarding the areas of law and geographical market of origin, indications that can be indicative to determine which set- tors to focus our attention in view of the positioning of the professional offer. Such data are not transferred outside of Studio Salvioni. The data are not processed automatically nor are they object of profiling.

9. HOW DO WE PROCESS PERSONAL DATA ON OUR PAGES IN SOCIAL NETWORKS?

We may operate pages and other online presences on social networks and other platforms operated by third parties and in this context process data about you. In this context, if we receive data from you (e.g., when you communicate with us or comment on our content) and from platforms (e.g., statistics), platform providers may analyze your usage and process this data along with other data they hold. They also process this data for their own purposes (e.g. marketing and market research purposes or for the management of their platforms) and act as data controllers for this purpose. Find-find more information about processing by platform operators in the data protection statements of their respective platforms. 

We currently use the following platforms, and the identity and contact details of the platform operator can be found in the Data Protection Statement:

• Facebook

www.facebook.com

Data Protection Statement: www.facebook.com/privacy/policy

• LinkedIn

www.linkedin.com

Data protection statement: https://de.linkedin.com/legal/privacy-policy

• Twitter

www.twitter.com

Data Protection Statement: https://twitter.com/it/privacy

• WhatsApp

www.whatsapp.com

Data Protection Statement: https://whatsapp.com/it/privacy

We have the right, but not the obligation, to monitor third-party content before or after it is published on our online sites, to delete content without notice, and, where appropriate, to report it to the provider of the platform in question.

It is possible that some of the platform providers are located outside Switzerland. See No. 6 for information regarding the disclosure of data abroad.

By using the website, the user accepts the terms and conditions of this Data Protection Statement, in effect at the time of access. The current version can be viewed by clicking on the appropriate “Privacy & cookie policy” link on the website homepage. It is your responsibility to carefully check the status of the terms and conditions before accessing the site, Studio Salvioni’s right to update this document at any time and at its own discretion being reserved.

10. WHAT ALSO NEEDS TO BE PAID ATTENTION TO?

We assume that the EU General Data Protection Regulation (“GDPR“) does not apply in our case. However, should this exceptionally be the case for certain data processing, this No. 10 also applies exclusively for the purposes of the GDPR and data processing subject to it. 

We base the processing of your personal data in particular on the fact that

– it is necessary as described in No. 3 for the initiation and conclusion of contracts as well as for their management and implementation (Art. 6 para. 1 lit. b RGPD); 

– it is necessary to protect our legitimate interests or those of third parties as described in no. 3, in particular for communication with you or third parties, for the operation of our website, for the m-improvement of our electronic offerings and registration for certain offerings and services, for security purposes, for compliance with Swiss law and internal regulations for our risk management and business conduct, and for further purposes such as training and education, administration, evidence and quality assurance, organization, holding and follow-up of events, and for the safeguarding of further legitimate interests (cf. No. 3) (Art. 6 para. 1 lit. f GDPR);

– by reason of our mandate or position is required or permitted by law or the law of the EEA or a member state (Art. 6 para. 1 lit. c RGPD) or is necessary to protect-your vital interests or those of other natural persons (Art. 6 para. 1 lit. d RGPD); 

– you have consented to the processing separately, for example by posting a statement to that effect on our website (Art. 6 para. 1 lit. a) and Art. 9 para. 2 lit. a RGPD).

We would like to point out to you that, in principle, we process your data for the period of time required by our processing purposes (see no. 3), legal retention periods, and our legitimate interests, in particular for documentation and evidentiary purposes, or that their retention is technically necessary (e.g. in the case of backups or document management systems). Unless legal or contractual obligations or technical reasons oppose this, we will in principle delete or anonymize your data once the retention or processing period has expired, within the framework of our usual processes and in accordance with our retention guideline.

Failure to mention certain personal data may result in the inability to provide the relevant services or to enter into a contract. As a matter of principle, we indicate where the personal data requested from us are mandatory.

The right to object to the processing of your data, stipulated in No. 7, applies to the processing of data for direct marketing purposes.

If you do not agree with our handling of your rights or data protection, please let us know (see contact details in no. 2). If you are in the EEA, you also have the right to file a complaint with the data protection supervisory authority in your country. The list of EEA authorities is available at: https://edpb.europa.eu/about-edpb/board/members_it.

Our representative in the EEA pursuant to Article 27 of the GDPR (where required and applicable): see contact details at no. 2.

11. DISCLAIMER REGARDING THE WEBSITE, APPLICABLE LAW AND PLACE OF JURISDICTION

The website https://www.salvionilaw.ch as well as the information contained therein is intended solely qua the purpose of presenting Studio Salvioni and informing in a structured manner about legal knowledge open to the public. It is not to be understood as legal opinion, nor can the information be adopted to concrete cases without the support, case by case, of a professional.

The information on the website is intended to give general information and does not determine al-any legal relationship in relation to Studio Salvioni.

Although Studio Salvioni has tried to provide accurate and up-to-date information, it cannot assume any responsibility for any inaccurate or erroneous information contained on the website, nor for similar problems that may arise in relation to sites to which the Studio Salvioni website refers. 

The above-mentioned website is the property of Studio Salvioni of Locarno, which holds full and exclusive intellectual property over the website and related resources, its graphics, databases and conte-nts, as well as over any legally protected signs and designations, and registered trademarks or rights thereto. 

Any reproduction or publication by third parties for commercial or promotional use of any element of the website, unless otherwise indicated or explicitly authorized, is prohibited.

Copyrights for the pages, images, texts, present on the website belong to Studio Salvioni. Their use outside the personal context is permitted only with the consent of Studio Salvioni, by citing the source. All rights are reserved.

The website implements security measures reasonably imposed by circumstances and proportionate against unauthorized access, use, transmission, alteration, loss or destruction of personal data. Such measures include technical, physical and organizational measures. However, given the nature of the Internet as an “open network,” Studio Salvioni cannot guarantee or warrant that data will not be intercepted or acquired by unauthorized third parties.

The legal relationship between the user and Studio Salvioni with respect to access and use of the website (and related resources) is governed by Swiss substantive law, excluding the rules of private international law.

The parties choose the District Court of Locarno – City, 6600 Locarno Canton of Ticino, Switzerland as the court of exclusive jurisdiction in the event of any dispute arising out of or simply related to the use of the Website. Studio Salvioni reserves the right to refer to the competent Judge at the registered office, branch or domicile of the user or client.

12. IS THIS DATA PROTECTION STATEMENT SUBJECT TO CHANGE?

If this data protection declaration is not part of a contract with you, we may adjust it at any time. The version published on this website is always the current version.

Locarno, January 16, 2024