INFORMATION ON THE PROCESSING OF PERSONAL DATA

In compliance with the provisions of the Federal Act on Data Protection (FADP) and EU Regulation 2016/679 (GDPR), we provide you with the necessary information regarding the processing of personal data provided during your navigation on the Data Controller’s website: https://www.cuervoysobrinos.com/.

In this regard, please note that depending on your geographical location or that of the legal entity you represent, your personal data will be processed in compliance with the respective applicable regulation mentioned above.

Please remember that this information does not apply to other websites, pages, or online services accessible via hyperlinks that may be published on the website, including those related to social media pages. Regarding the latter, we therefore invite you to consult their respective privacy and cookie policies.

Website User

You are the person accessing our website to whom this policy is addressed, also referred to as the Data Subject.

Data Controller

The Data Controller of your personal data is:

CUERVO Y SOBRINOS SA (hereinafter “CyS”)

Registered office: Rue de la Gruère, 7 – 2350 Saignelégier, Switzerland

Administrative office: Via Carlo Maderno 54 – 6825 Capolago, Switzerland

Tel. +41 919212773

Email: contact@cuervoysobrinos.com

EU Representative

In accordance with Article 27 of Regulation (EU) 2016/679, the Data Controller has appointed the following EU Representative:

INDO SRLS

Viale Giacomo Mancini, 156, 87100 Cosenza (CS), Italy

VAT No. 03510180783

Tel. +39 02 87366082

Email: dpo@indoconsulting.it

Purpose of processing, legal basis, and retention period of your personal data

1. CONTACT AREAS of the website – Data provided directly by the Data Subject through the contact details indicated in the footer or on the navigation pages.

The explicit and voluntary sending of messages to the contact addresses present on the website entails the acquisition of the sender’s contact data, as well as all personal data included in the communications.

Such data are processed for the following purposes:

1.1 Contacting the User

your contact data will be used for the purpose of contacting you back and responding to your request. Providing this data is necessary to process your requests.

Legal grounds: (for Users in Switzerland) Art. 31 par. 2 letter a) FADP, overriding interest of the Data Controller, specifically the processing of data concerning the Data Subject in direct connection with the conclusion of a contract, the execution of pre-contractual measures, and to fulfill specific User requests.

Legal Basis: (for Users in the EU) Art. 6, par. 1, letter b) GDPR, execution of pre-contractual measures adopted at the request of the Data Subject.

Retention period: the data collected are processed for the time necessary to fulfill the request or for the duration of the validity of the quote/estimate agreed upon between the parties.

2. CONTACT AREAS – Data provided directly by the Data Subject by filling out information request forms.

The explicit and voluntary filling out of forms entails the acquisition of the sender’s contact data and their identification, to allow them to request information about the Data Controller’s services and products.

Such data are processed for the following purposes:

2.1 Contacting the User

your contact data will be used for the purpose of contacting you back and responding to your request. Providing the data marked with an asterisk is necessary to process your requests.

Legal grounds: (for Users in Switzerland) Art. 31 para. 2 letter a) FADP, overriding interest of the Data Controller, specifically the processing of data concerning the Data Subject in direct connection with the conclusion of a contract, the execution of pre-contractual measures, and to fulfill specific User requests.

Legal Basis: (for Users in the EU) Art. 6, par. 1, letter b) GDPR, execution of pre-contractual measures adopted at the request of the Data Subject.

Retention period: the data collected are processed for the time necessary to fulfill the request or for the duration of the validity of the quote/estimate agreed upon between the parties.

2.2 Marketing

your contact data will be used for the purpose of sending various commercial and informative communications concerning the products and services sold by the Data Controller, for sending newsletters, reporting advertising events, and sending promotional communications, thus keeping you updated on our offers. Providing this data is therefore optional and consent (i.e., subscription) can be given by ticking the relevant box on the form; omission only results in the failure to send commercial proposals but does not prevent the processing of your requests.

Legal grounds: (for Users in Switzerland) consent of the Data Subject, Art. 3 para. 1 letter o) UCA and Art. 31 para. 1) FADP. Cancellation can take place according to the instructions found at the bottom of each communication or by writing to the Data Controller.

Legal Basis: (for Users in the EU) consent of the Data Subject, Art. 6, par. 1, letter a) GDPR.

Retention period: until the withdrawal of consent.

3. “REGISTRATION AND AUTHENTICATION” FORM – Data provided directly by the Data Subject by filling out and submitting registration forms or through authentication to a reserved area.

The explicit and voluntary filling out of the registration form or the submission of the authentication form entails the acquisition of the sender’s contact data and their identification to allow them access to the services offered in the reserved area.

Such data are processed for the following purposes:

3.1 Registration and identification

your contact data will be used for the purpose of identifying registered Users and allowing them access to the reserved area. Providing the data marked with an asterisk is necessary to register.

Legal grounds: (for Users in Switzerland) Art. 31 para. 2 letter a) FADP, overriding interest of the Data Controller, specifically the processing of data concerning the Data Subject in direct connection with the conclusion of a contract to allow the User to benefit from the services offered by the website in the reserved area.

Legal Basis: (for Users in the EU) Art. 6, par. 1, letter b) GDPR, execution of contractual measures to allow the User to benefit from the services offered by the website in the reserved area.

Retention period: Until the User’s request for deletion from the reserved area.

3.2 Marketing

your contact data may also be used for the purpose of direct marketing, specifically to send you commercial offers relating to our products and/or services. Such communications may occur via email or through other channels such as phone calls, ordinary mail, SMS, and social media. Providing this data is optional and expressed by the User by selecting the relevant box; omission only results in the failure to send commercial proposals but does not prevent the processing of your requests.

Legal grounds: (for Users in Switzerland) consent of the Data Subject, Art. 3 para. 1 letter o) UCA and Art. 31 para. 1) FADP. Cancellation can take place according to the instructions found at the bottom of each communication or by writing to the Data Controller.

Legal Basis: (for Users in the EU) consent of the Data Subject, Art. 6, par. 1, letter a) GDPR.

Retention period: until the withdrawal of consent.

4. “E-COMMERCE” FORM – Data provided directly by the Data Subject by filling out and submitting forms for the purchase of goods offered on the portal.

The explicit and voluntary filling out and submission of the form, with or without registration, for the purchase of goods, entails the acquisition of contact data and identification of the Data Subject, to allow them to make the desired purchases, as well as data for the selected payment method, information on orders placed, to pre-fill checkout information, and for shipping and billing.

Such data are processed for the following purposes:

4.1 Contractual Purpose

to provide the purchase service for the goods or services offered on the website. Providing the data marked with an asterisk is necessary to execute the contract.

Legal grounds: (for Users in Switzerland) Art. 31 para. 2 letter a) FADP, overriding interest of the Data Controller, specifically the processing of data concerning the Data Subject in direct connection with the conclusion of a contract.

Legal Basis: (for Users in the EU) Art. 6, par. 1, letter b) GDPR, execution of contractual measures adopted at the request of the Data Subject.

Retention period: for the entire duration of the contract and, consequently, for 10 years from the end of the financial year according to the CO (Swiss Code of Obligations).

4.2 Soft Spam

following purchases, your contact data will also be used for the purpose of direct marketing, specifically to send you commercial offers relating to our products and/or services similar to those already purchased. Such communications may occur via email. Providing this data is optional but occurs automatically at the time of purchase.

Legal grounds: processing permitted by law, specifically Art. 3 para. 1 letter o) UCA: “anyone who, when selling goods, works or services, obtains the contact details of customers and informs them of their right to object to mass advertising by means of telecommunications, does not act unfairly if they send them, without their consent, mass advertising for their own similar goods, works or services”.

Legal Basis: (for Users in the EU) Art. 6, par. 1, letter f) GDPR, legitimate interest of the Data Controller.

Retention period: until the User objects through the “Opt-out” system or by writing to the Data Controller.

Payment management: the Company accepts payments by Credit Card (Mastercard and Visa) or through the PayPal payment platform. Data is acquired directly by the provider of the requested payment service; processing takes place in the manner specified in the privacy policy of said service.

[CONTINUA CON LA STESSA STRUTTURA DI FORMATTAZIONE PER LE SEZIONI 5–10, “Categories of recipients of personal data”, “Processing methods”, “Rights of the Data Subject”, “Procedures for exercising your rights” E “INSTRUCTIONS FOR THE WEB MANAGER”, SENZA MODIFICARE ALCUN CONTENUTO.]