Privacy Policy

1. Preamble

Valori Asset Management SA, Chiasso (TI-CH) (hereinafter also referred to as the “Company”) collects personal data (as defined below) in compliance with applicable laws and regulations, in particular the Swiss Federal Data Protection Act (“DPA“) referred to as the “privacy regulations.”

We are very concerned about protecting your privacy and ensuring lawful treatment of personal data of all users of our Electronic Services. We understand that by using our Electronic Services you may entrust us with personal information (“Personal Data”), and we want to reassure you that we take our responsibility to protect and secure this data very seriously. Therefore, with this privacy statement, we inform you about what data we process in the use of our Electronic Services, how we process it, to whom we disclose it, and what security measures we have taken to protect your data.

This Privacy Statement applies to all Data we receive as a result of your use of our Electronic Services. It does not apply to Personal Data that we receive through other channels, or to third party Electronic Services (“Third Party Electronic Services”), even if you access them through links from our Electronic Services or if they are necessary to provide our Electronic Services. We have no control over the content and privacy policies of Third Party Electronic Services and therefore cannot take any responsibility for them.

2. Definitions

Under privacy regulations, the terms below have different meanings:

  • “Personal data” includes any information about an identified or identifiable natural or legal person;
  • “Processing” means any operation or set of operations, performed with or without the aid of automated means, that applies to (groups of) personal data, including collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consulting, using, disseminating, communicating by transmission, disseminating or otherwise disclosing, aligning or interconnecting, restricting, erasing or destroying.
  • “Browsing Data” are acquired by the computer systems and procedural software responsible for the operation of this site in the course of their normal operation. This is personal data whose transmission is implicit in the use of Internet communication protocols. This category includes IP addresses, addresses in URI/URL (Uniform Resource Identifier/Locator) notation, the time of the request, the type of request, the size of the outgoing packet, the status of the response given by the server (received, error, etc.) and other parameters related to the operating system.

3. Data controller

The data controller is Valori Asset Management SA, Viale Alessandro Volta, 16, CH-6830 Chiasso Switzerland, registered in the Commercial Register of the Canton of Ticino under CHE-179,959,647.

4. Type of personal data acquired, purpose, legal basis and data retention

Data are collected and managed for the purposes and at the times indicated below:

Data

Method of data acquisition

Purpose of treatment

Legal basis for processing

Data retention time

Technical data, such as IP address, browser characteristics (type, language, plug-ins installed, etc.).

Automatic while visiting the platform

Platform visit by the user

Overriding private interest

Up to 1 year

Identity information such as name, address, company name, photograph, email address

Entered by the user when registering for the platform or using the contact forms if any

Personal data registration to take advantage of the site’s newsletter service

Overriding private interest

N. A.

Modes currently not implemented

E-mail

Submitted by user

Newsletter registration

Overriding private interest

Until cancellation request

Session duration

Automatic while visiting the platform

Statistics

Overriding private interest

Up to 1 year

We process data based on the following legal bases:

  • Legitimate interest of Valori Asset Management SA or third parties;
  • Il tuo consenso;
  • Fulfillment of contractual obligations and implementation of measures before the conclusion of the contract;
  • Legal obligations.

We process data specifically for the following purposes:

  • Analyze our website to improve its usability, security, and effectiveness;
  • The language of use and other local and site customization settings;
  • Ensuring the security and operational functioning of our IT environment;

We process your personal data in accordance with applicable data protection laws and for as long as necessary.

We retain your personal data for as long as necessary for the purposes described in these data protection guidelines or as required by law.

5. To whom will collected data be disclosed?

We will only disclose your personal information if we are required to do so to fulfill our legal or regulatory obligations, for business or administrative reasons, or because you have asked us to do so. This is likely to include disclosure:

  • within the Company;
  • To third parties who process personal data on our behalf (IT system providers and other service providers);
  • to any government, regulatory agency, enforcement or exchange body, or court that requires it under applicable law or regulation.

We may transmit data for the above purposes within the Company (any subsidiaries/branches), to representatives of the Company or service providers engaged by the Company, both within and outside the country in which you are currently located. All mentioned persons and companies receiving data are required to comply with national and international data protection laws and data protection standards.

The Company transmits your data to countries outside Switzerland:

  • For the purpose of providing Electronic Services;
  • if you have given your consent (for example, in your contracts with the Company or as part of your privacy settings); or
  • on the basis of legal obligations, at the request of authorities or as part of similar processes under applicable law.

If necessary, the Company must disclose the data to supervisory authorities, judicial authorities or other competent persons, within the scope of applicable laws and according to supervisory obligations

6. Can the Company transfer data to a third country and/or international organizations?

The data collected by the Company is stored in Frankfurt, Germany. Storing your data outside Switzerland, particularly in an EU country, ensures that the protection is comparable to that guaranteed in Switzerland and, in general, for all member states of the European Economic Area. If this is not possible, we will verify that the provisions of the applicable legislation on the transfer of personal data to third countries will be complied with in any case.

7. Web Analytics Tools and Social Media Plug-ins.

We may use third-party analytics tools, such as Google Analytics, to monitor the Electronic Services. This includes using cookies to analyze how users use our Electronic Services, collecting the following usage data, among other things:

In addition, we may use so-called social plug-ins. The plug-ins can be recognized by the logos of the social networks to which they belong.

8. Transmission of Data through an Open Network.

The Company’s Electronic Services may contain links to third-party Electronic Services that are neither operated nor controlled by us. Please note that such third-party Electronic Services are not subject to this Privacy Policy, and we are not responsible for either their content or the policies of such providers regarding data processing. Therefore, we recommend that you read and review the privacy statements or terms of use for the relevant Third Party Electronic Services.

9. Link

In case you use our Electronic Services through an open network, the Company makes you aware that third parties (e.g., App Stores, network providers, or the manufacturer of your device) may access and process your data regardless of their location. Open networks are not under the Company’s control and therefore cannot be considered a secure environment. Data transmitted through such an open network cannot be guaranteed to be secure or error-free, as it may be intercepted, modified, damaged or destroyed, or may be lost, arrive late or incomplete, contain viruses or be monitored. In particular, data transmitted through an open network-even if the sender and recipient are in the same country-can leave that country and be transmitted and processed in a third country, where less stringent data protection rules may apply than in the country where you are currently located. If data are transmitted through an open network, we cannot be held responsible for their protection. Consequently, we assume no responsibility or obligation for the security of your data during such a transmission. Therefore, we recommend that you do not transmit strictly confidential information through open networks. Where you deem it appropriate, you may communicate with the Society through other means.

10. How we protect your personal data

The security of your personal data is important to us, and we take various technical and organizational measures to protect it.

We are committed to safeguarding and protecting personal data by taking appropriate measures against accidental or unlawful destruction, loss, alteration or unauthorized disclosure.

The Company implements both physical and electronic and procedure-specific security precautions. This includes, for example, the use of firewalls, customized passwords, encryption and authentication technologies. Our employees and authorized service providers are held by us to confidentiality and compliance with data protection provisions.

In addition, access to personal data is strictly limited to those employees and third parties (e.g., service providers) who must have access (the “need-to-know” principle).

11. Rights of interested parties

Under privacy regulations, users have a number of rights in relation to their personal data. They have the right to request access to, rectification or deletion of that information, the right to restrict or object to processing, and, under certain circumstances, the right to data portability.

If a user has provided consent to the processing of their data, they have the right (under certain circumstances) to withdraw that consent at any time.

A data subject who wishes to exercise the above rights is requested to send an e-mail to info@valam.ch.

We try to respond to you within a maximum of one month, although we reserve the right to extend this period for more complex requests. We also reserve the right to charge a reasonable administrative fee for any manifestly unfounded or excessive requests regarding access to personal data and for any additional copies of personal data requested.

Under applicable data protection laws and regulations, you have the following rights:

  • You can request information about the personal data we keep about you;
  • You can request that data be transmitted in a generally usable, machine-readable, standardized format (data portability);
  • You can request that inaccurate personal data be corrected;
  • You can request that your data be deleted if the bank is not authorized or legally obligated to retain it;
  • You can request that the processing of your data be restricted;
  • You can object to the processing of your personal data

In addition, you may have the right to file a complaint with the relevant data protection authority.

12. Contact us

If you have any questions about the processing of your personal data, please contact us:

Valori Asset Management SA

Via Alessandro Volta 16 CH-6930 Chiasso –

Tel: +41 (0)91 695 80 80

E-mail a: info@valam.ch

This Privacy Policy was last updated in August 2023.