Privacy Notice
Effective as of May 2nd, 2023.
This Privacy Notice (the “Privacy Notice”) describes the principles based on which Cervo Advisory ltd. (hereinafter “Cervo Advisory”, “we” or “the Controller”) processes personal data collected through our website www. cervoadvisory.ch (the “Website”) or by other means from Cervo Advisory. It informs you in particular about what personal data we collect, for which purposes it is processed, with whom it may be shared, for how long we retain it and which rights and options relating to the use of your personal data you may have. “Personal data" means any and all information relating to an identified or identifiable natural person, for example name, address, e-mail address, an online identifier or the phone number.
This Privacy Notice applies as far as the processing activities are not subject to other privacy policies or are provided for by applicable law. Please read this Privacy Notice carefully. By using our services, you consent to the collection and processing of your personal information as set forth in this Privacy Notice.
If you provide us with personal data of other persons, please provide their personal data only if you are allowed to do so in line with applicable data protection laws and only if the other person would agree to you providing its personal data to us for the purposes the data are collected and the processing of its personal data according to our Privacy Notice.
Content
- Who controls the personal data
- How do we process personal data
- What personal data do we collect for which purposes
- On what legal basis do we process personal data about you
- With whom do we share your personal data
- Transfer of personal data to countries outside the EEA
- For how long we keep information about you
- Social Media Plug-Ins
- No automated decision-making, including profiling, with legal effect
- Security
- Third-party privacy policies
- Children
- What are your rights
- 14. Changes to our Privacy Notice
1. Who controls the personal dataThe Controller of personal data collected according to this Privacy Notice is:
Cervo Advisory AG
Samstagernstrasse 48d
8832 Wollerau | Switzerland
Telefon: +41 (0)79 660 89 89
E-Mail: info@cervoadvisory.ch
Website: www.cervoadvisory.ch
Cervo Advisory determines the purposes and means of the processing of your personal data and is therefore responsible for the processing and use of your personal data as described in this Privacy Notice. If you have any questions or concerns regarding this Privacy Notice or how we process your personal data, kindly contact us at any time by sending an email to info@cervoadvisory.ch.
2. How do we process personal dataAny personal data collected through the Website is processed in accordance with the provisions of applicable data protection and privacy laws. We collect and process personal data carefully and for the purposes described in this Privacy Notice. In accordance with applicable law, we may also use your personal data in other ways as described in this Privacy Notice. In such event, we will provide specific privacy policies or notices at the time of collection and obtain your consent where necessary. We always seek, to the extent reasonably possible, to collect information on an anonymized or pseudonymized basis so we cannot recognize your identity.
3. What personal data do we collect for which purposesWe may collect the following data via our Website:
a) Information automatically collected
Cervo Advisory collects and stores information that your browser automatically transmits to us in "server log files" when visiting our Website. These may include the following data:
- Browser type and browser version
- Operating system used
- Referrer URL (the previously visited website)
- Host name of the accessing computer
- Date and Time of the server request
- Internet Protocol address (IP address)
- Transmitted data volume
- Other similar data and information which serve to avert danger in the event of attacks on our IT systems.
These data will not be combined with data from other sources. It is stored by us until it is automatically deleted within a period of three - six months.
The data automatically collected as described above is processed for the purposes of proper functioning of our Website, e.g. for establishing a connection, ensuring stability and uninterrupted system security, to improve our services, and for statistical purposes in the event of attacks on the network infrastructure on which the Website is made available.
b) Information provided by you via email, letter mail or by phone call
We collect information which you actively and voluntarily provide us with through the Website by sending a message to our contact email address or by phone call. This may include the following personal data:
- Name, first name, address, email address, phone number, language spoken, additional information about you;
- Your message or your inquiry.
We will use the information provided by you for the processing and answering your inquiry, or for the lawful purposes which were evident from the circumstances, which may include the following purposes:
- To best respond to your questions or requests regarding our services, to ask you questions and to provide additional information related to our services, tailored to your request or interests;
- To communicate with you (e.g. about our services) and provide you with the best possible information that you require from us before, during or after termination of a contract;
- For complying with legal or other regulatory requirements and internal rules;
- For establishing, exercise and/or defend actual or potential legal claims, investigations or similar proceedings;
- For other lawful purposes, where such processing arises from the circumstances or was indicated at the time of collection.
c) Information collected or generated in connection with the provision of consulting services
We collect and generate information if you, as an individual entrepreneur or as an employee representing a company, wish to receive strategic advice from us, for example in the hotel or tourism sector. This may include the following personal data:
- Surname, first name, address, e-mail address, position, telephone number, payment information and other information you provide us with.
The provision of this personal data is always voluntary, based on your consent or a contract, to fulfill the services you have requested. Please note that without the provision of this information, the service requested cannot be provided, or cannot be provided in the desired quality.
We will use the information we collect from you to provide you with the best possible advice in the service area you have requested, which may include the following purposes:
- To best answer your questions or requests regarding our services, to ask you questions and to provide additional information related to our services that is tailored to your inquiry or interests;
- To communicate with you and to give you the best possible advice that you request from us before or during a contract;
- For the processing of the payment related to the services we provided;
- complying with legal or other regulatory requirements and internal rules;
- For establishing, exercise and/or defend actual or potential legal claims, investigations or similar proceedings;
- For other lawful purposes, where such processing arises from the circumstances or was indicated at the time of collection.
4. On what legal basis do we process personal data about youThe processing of your personal data for the purposes described can be based on the following legal grounds:
- Your consent, only if it may be withdrawn at any time;
- For the performance of a contract with you or for the intention to enter into a contract with you (e.g. in the context of a strategic consultation, which you wish from us);
- to comply with a legal obligation (e.g. for tax reasons or for purposes of legal investigations or proceedings); or
- for the purposes of our legitimate interests, for example for maintaining and improving our internal business administration, organization, operations, risk management, protection of systems and premises, prevention of fraud and other offences, for advertising and marketing activities, to guarantee an effective, efficient, secure and harmonized service, to comply with legal or other regulatory requirements and internal rules, and for establishing, exercise and/or defend actual or potential legal claims, investigations or similar proceedings.
Should the processing be based on your consent or our legitimate interests, you may withdraw consent or object to that processing at any time by contacting us directly at info@cervoadvisory.com. Please note, however, that the withdrawal of your consent will not affect the lawfulness of processing based on your consent before the withdrawal.
5. With whom do we share your personal dataWe take the necessary measures to ensure that only our authorized personnel and auxiliary persons who have the necessary knowledge, and where necessary (according to the need-to-know principle), have access to your personal data in order to fulfill the purposes for which your personal data was collected.
We may transfer your personal data to the following possible categories of recipients in accordance with the purposes and legal basis of the processing described above and insofar as this is necessary for the corresponding data processing, e.g. as part of a recruiting process of a potential employer:
- Our trusted third-party service providers, including processors (e.g. providers of IT services);
- Payment service providers, financial institutions;
- Our consultants and other business partners;
- The public, media, including social media sites of ours (e.g. LinkedIn);
- Governmental administrations, courts and other competent authorities;
- Other parties in potential or actual legal proceedings.
We choose our partners and data processors carefully and only upon sufficient guarantees they have appropriate technical and organizational measures in place. Our data processors may only process personal data on documented instructions from us. They all are subject to confidentiality requirements and may use your personal data solely to the extent necessary to fulfill the purpose for which your personal data was collected, except as otherwise required by law.
6. Transfer of personal data to countries outside the EEAThe personal data collected through our Website is stored in Switzerland. Moreover, we may transfer, store and process your personal data in data locations around the world, for example where our third-party providers or business partners are located. Therefore, we may transfer your personal data outside the European Economic Area (EEA) if it is required for the data processing described in this Privacy Notice in accordance with applicable law.
If data is disclosed to countries that do not guarantee an adequate level of protection, Cervo Advisory will ensure adequate protection of data disclosed by putting appropriate safeguards in place, such as contractual guarantees (e.g., on the basis of EU standard clauses), binding corporate rules, or transferring data pursuant to your explicit consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims. You may obtain more information about our appropriate safeguards by contacting us via email to
info@cervoadvisory.ch. 7. For how long we keep information about you We retain your personal data for as long as necessary to fulfill the purposes for which your personal data was collected. For this reason, we will delete or anonymize personal data (or equivalent) once they are no longer necessary to achieve the purposes, subject however (i) to any applicable legal or regulatory requirements to store personal data for a longer period (e.g. for tax or accounting reasons), or (ii) if we have an overriding interest (e.g. an interest for reasons of proof to establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings, including legal holds, which we may enforce to preserve relevant information, or if we have an interest in non-personalized analysis).
On that basis, we normally process personal data subject to the following rules and obligations:
- For contract related personal data (including business records and communication), we retain personal data as long as the contractual relation is ongoing and for ten years after the termination of the contractual relationship unless (i) a shorter or longer statutory storage obligation is applicable on a case-by-case basis, (ii) the retention is required for reasons of proof or another valid reason based on applicable law, or (iii) the deletion of the data is required earlier (because e.g. the data is no longer required or we are required to delete the respective data);
- For operational data containing data (e.g. protocols, logs), we retain personal data for a period of 3 - 12 months.
8. Social Media Plug-InsWe have installed on our Website the plug-in of the social network LinkedIn Corporation, 1000 West Maude Avenue Sunnyvale, California 94085, USA. You can recognize the LinkedIn plug-in ("LinkedIn Recommended" button) by the LinkedIn logo. When you call up a page of our website that contains such a plug-in, a direct connection is established between your browser and the LinkedIn server. LinkedIn thereby receives the information that you have visited our Website with your IP address. If you click the LinkedIn button while you are logged into your LinkedIn account, you can link the content of our pages on your LinkedIn profile. This allows LinkedIn to associate the visit to our pages with your user account. We would like to point out that we, as the provider of the Website, have no knowledge of the content of the transmitted data or its use by LinkedIn. For more information, please visit:
www.linkedin.com/legal/privacy-policy.
9. No automated decision-making including profiling with legal effect We do not make any decision about you which is based solely on automated processing and which has legal effect on you or significantly affects you in a similar way.
10. SecurityWe have implemented various technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.
Cervo Advisory may use third party data processors to collect and process your personal data. Any data processors commissioned by us will only process your personal data in accordance with our instructions and are legally obliged to adhere to strict security procedures when handling personal data.
Unfortunately, transmission of information via the internet is not wholly secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is done so at your own risk. For this reason, you are always free to transfer your personal data to us via alternative means, e.g. by telephone. Once we have received your information, we employ strict procedures and rigid security measures to try to prevent unauthorised access.
11. Third-party privacy policiesPlease note that if you click on the link to a third-party website (e.g. LinkedIn), you will be directed to a website that we do not control and our privacy policy will no longer apply. Your browsing and interaction on any other website is subject to the Terms of Use and the privacy policies and notices of those third-party websites. Furthermore, we cannot guarantee the accuracy and timeliness of these links.
We recommend that you read the terms of use and the privacy policies and notices of other websites carefully before submitting personal information via this Website. We are not responsible or liable for the information content on such third-party websites.
12. ChildrenAs a matter of principle, we do not process any personal data of children. If we collect personal data from children under the age of 16, we obtain the consent of a parent or legal guardian.
13. What are your rights You may request information from Cervo Advisory as to whether data concerning you is being processed. In addition, you have the right to request the correction, destruction or restriction of personal data regarding yourself as well as to object to the processing of personal data. Should the processing of personal data be based on your consent or our legitimate interests, you may withdraw consent or object to that processing at any time. However, please note that a withdrawal does not affect the legitimacy of the processing activities that took place before you withdrew your consent. In certain cases, you may have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer.
Requests in this respect shall be submitted to Cervo Advisory via the following email address: info@cervoadvisory.ch. Cervo Advisory reserves the right to restrict the rights of the affected user in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.
If we refuse your request or if you are not satisfied with our processing, you are also entitled to lodge a complaint with the competent supervisory authority and seek a judicial remedy. For users located in Switzerland, the competent authority is the Federal Data Protection and Information Commissioner in Switzerland (http://www.edoeb.admin.ch). For the users located in the EU Countries, a list of the supervisory authorities can be found at
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
14. Changes to our Privacy NoticeThis Privacy Notice may be changed from time to time and without prior notice or announcement. All changes to this Privacy Notice are effective when they are posted on the Website unless indicated otherwise. When we change the Privacy Notice in a material manner, we will let you know via email and/or a prominent notice on our Website or in another appropriate manner prior to the change becoming effective and update the ‘effective date’ at the top of this page.
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