Owner and Data Controller
LAGOM FAMILY ADVISORS SA
CORSO SAN GOTTARDO 88
CH-6830 CHIASSO
SVIZZERA
Owner contact email: info@lagom-fa.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Usage Data; Trackers; language.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Displaying content from external platforms, Building and running this Website, Managing support and contact requests and Handling activities related to compliance.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Building and running this Website
Key components of this Website are built and run directly by the Owner by making use of the software listed below.
WordPress (self-hosted) (this Website)
This Website is built and run by the Owner via a CMS software (Content Management System) called WordPress.
Personal Data processed: language.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Handling activities related to compliance
This type of service allows this Website to handle activities related to compliance.
Legal purposes
Crimes: ascertain responsibility in case of hypothetical computer crimes against the site;
Legal, administrative and audit purposes;
Enforce or defend a right in judicial, extrajudicial or administrative proceedings.
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Managing support and contact requests
This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Contact
as per your request sent via email to the address: info@lagom-fa.com.
Further information about the processing of Personal Data
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Browsing this website
Activities aimed at the functioning of the site and the provision of the service. The system acquires, during normal operation, some personal data whose transmission is implicit in the use of Internet communication. This category of data includes the IP addresses or domain names of the computers and terminals used by users, the addresses in URI/URL (Uniform Resource Identifier/Locator) notation of the requested resources, the time of the request, the method used in the submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc..) and other parameters relating to the operating system and the user's IT environment.
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Legal basis/Justification (users in Switzerland)
In accordance with the art. 6 nLPD, the Data Controller processes your personal data within the applicable legal framework. Where required, and depending on the purpose of the processing activity, the processing of your personal data may be based on the following legal basis/justifying reason:
• for processing relating to navigation on this website, the creation and management of this application, for crimes, for administrative and audit purposes, to assert or defend a right in judicial, extrajudicial or administrative proceedings: Preponderant interest of the owner ;
• to contact you again: preponderant interest of the data controller – sub. especially execution of the contract;
• for processing carried out pursuant to regulatory obligations: need to fulfill a legal or regulatory obligation.
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Personal data (users in Switzerland)
Retention period
Your Personal Data will be stored in compliance with the provisions of the art. 6 n.4 nLPD based on the principle of need for treatment and in particular:
• data relating to navigation on this website: will be kept for the period relating to the browsing session;
• The data collected to process requests sent by the user will be kept for one month.
In any case, the data will be retained for the entire duration of the extrajudicial and/or judicial proceedings, until the terms for the possibility of judicial protection and/or appeal actions have been exhausted. Subsequently, once the aforementioned reasons for the processing cease to exist, the Data will be deleted, destroyed or simply stored in anonymous form.
Recipients of personal data
The user's personal data may be communicated to:
• Data controllers pursuant to art. 9 nLPD as well as authorized persons of the processing;
• Service providers who offer services on behalf of the owner;
• Freelancers who provide services to the owner;
• Financial administrations, public bodies, judicial authorities, law enforcement agencies;
• Third parties exclusively for accounting, tax, legal, insurance needs or in case of checks by police bodies or if required by law.
Such data will not be disclosed and will be processed by subjects duly appointed to carry out these tasks, constantly identified and/or appointed, appropriately trained and made aware of the constraints imposed by law, as well as through the use of security measures. designed to guarantee the protection of your confidentiality and to avoid the risks of loss or destruction, unauthorized access, processing that is not permitted or does not comply with the aforementioned purposes.
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Data communication abroad (users in Switzerland)
Your personal data will be kept in Switzerland and may be transferred abroad to third countries that have the same data protection laws as the country in which the information was initially provided. In this case the Data Controller guarantees an adequate level of security by transferring them to countries which, according to the confirmation of the Federal Data Protection and Information Commissioner (FDPIC) have an adequate level of protection or by concluding a contract between the Data Controller and the legal entity outside Switzerland which receives the data. Specifically, the data will be transferred to Italy.
Nor will your personal data be subject to dissemination or any fully automated decision-making process.
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Your rights under the Federal Data Protection Act (users in Switzerland)
Users can exercise some rights relating to their data within the limits of the law, including the following:
• obtain confirmation as to whether or not personal data is being processed and, in this case, obtain access to the personal data - including a copy of the same - and communication, among others, of the following information: purpose of the processing, categories of personal data processed, recipients to whom these have been or will be communicated, data retention period (right of access);
• obtain, without unjustified delay, the rectification of inaccurate personal data and/or the integration of incomplete personal data (right of rectification);
• obtain, without unjustified delay, the cancellation of personal data (right to cancellation);
• obtain the limitation of processing (right of limitation of processing) in the cases in which the interested party has exercised his right of opposition or rectification;
• receive personal data in a structured format, commonly used and readable by an automatic device, transmit them to another owner without impediments and, where technically feasible, obtain that the personal data are transmitted directly from the company to another owner, if the processing is based on consent and is carried out by automated means (right to data portability);
• object to the processing at any time, for reasons related to your situation (right to object). In case of exercise of this right, the Company will refrain from further processing the personal data, provided that there are no compelling legitimate reasons to proceed with the processing anyway;
• obtain not to be subjected to an automated decision;
• lodge a complaint with the Federal Data Protection and Transparency Commissioner (FDPIC).
When contacting the data controller, the user must ensure that they include their name, e-mail address, postal address and/or telephone number(s) as well as a copy of a valid document for recognition purposes, to be sure that the Data Controller can correctly handle the request forwarded.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Website, if not stated otherwise within this document.