Dear Client,
We wish to inform you that, pursuant to Article4(5) of the Swiss Data Protection Act (DPA) and, where applicable, Articles 13and 14 of Regulation (UE) 2016/679 (GDPR), the personal data you provide or that we collect within the context of our activities will be processed in accordance with the principles set forth in the aforesaid regulations and with the stringent confidentiality requirements to which our business activities are subject. Please note that the EU Regulation is only applicable to the processing of personal data within the territorial scope asset out in Article 3 of the GDPR, that is to say:
IBEX SERVICES Ltd and its subsidiaries do not have a business establishment inthe EU. The company may occasionally process personal data of data subjectsas part of a general monitoring activity.
In the context of our activities, we process the following categories of personal data:
Your personal data will be processed for the following purposes:
3.1. Compliance with legal obligations
Some of your personal data (specifically: your name, surname, address, date and place of birth, tax code, a photocopy of your identity document)will be collected in order to comply with the law, regulations and sector-specific rules, or instructions issued by supervisory or regulatory authorities or bodies.
Such data will be processed in order to:
Personal data processed for the above purposes may be retained for up to 10 years from the date of termination of the contractual relationship.
3.2. Purposes strictly related and instrumental to the management of contractual relationships
Some personal data-such as data collected prior to signing the contract-are necessary in order to manage business relations with you as a client or for the performance of contractual obligations and to meet your specific requests.There is no obligation to provide the personal data required for such purposes.You may therefore choose not to provide these data. However, that may undermine the management and/or continuation of the contractual relationship with you or the execution of the operations you have requested.
Such data will be processed in order to:
3.3. Data processed on the basis of the data subject's consent
Subject to your consent and until you object, the Company could process your personal data for the purposes of direct marketing an d profiling, especially in relation to newsletters, meetings, promotional offers, market research, informative material, satisfaction surveys, commercial and advertising material or in connection with events and initiatives, especially conferences and meetings open to the public. The Company does not carry out such activities for relations to Interested parties, possibly subject to profiling following behaviour monitoring, whose data, if collected, are used only for general analysis of the origin of contact s and the type of services object of interest. Processing will be carried out by automated means, e - mail, operator telephone calls, text messages, chat rooms and paper - based mail, on the following personal data: name, surname, private address, telephone number, fax 3 number, e - mail address, social media profile, cookies, technical identifiers (IP, unique mobile device identifiers, etc.). Data processed for the above purposes may be retained for the entire period of the mandate and for up to 3 years from the date of termination of the main contractual relationship or of the service requested (e.g., newsletter). Providing such data is optional albeit necessary for the above purpose. If you do not provide such data we will be unable to contact you for direct marketing initiatives based on your interests. This will, however, not have any negative consequences for the purposes set forth under points 3.1 – 3.3 above.
For the above purposes, your data may be disclosed to the following categories of subjects, in Switzerland or abroad, including outside the European Union, in their capacity as controllers in respect of such data (the list is not exhaustive):
For the above purposes, your data may be made available to the following categories of subjects, in Switzerland or abroad, including outside the EuropeanUnion, in their capacity as processors:
Please also note the following:
The data you provide may be processed by automated means, in writing or using electronic or telematic tools, including tape recordings and the use of other equivalent storage media, based on procedures and systems completely in line with the purposes referred to above and such as to guarantee security and confidentiality as required by the applicable regulations. The data in question may also be stored and retained in printed or electronic form, recorded on tape or other equivalent storage media, in the case of recorded telephone calls. Personal data may be stored on servers located in Switzerland in accordance with the laws in force and with full assurance of compliance with security and confidentiality requirements. You may obtain a copy of your personal data by sending a written request addressed to the controller, at the e-mail info@taxnomadims.org, or the postal address of our registered office.
It is assumed that the data are transferred abroad exclusively by virtue of a legal obligation or if this is necessary to fulfil the contract with the Customer, respectively on his instruction. In particular, data may be transferred where necessary to the execution of a contract concluded between the data subject and the data controller, or the execution of pre-contractual measures taken at the request of the data subject; or where the transfer is necessary for the conclusion or execution of a contract between the data controller and another natural or legal person in favor of the data subject; or the transfer is necessary for important reasons of public interest; or the transfer is necessary to ascertain, exercise or defend a right in court; or the transfer is necessary to protect the vital interests of the person concerned or of other persons, if the person concerned finds himself in the physical or legal incapacity to give his consent; or the transfer is made from a register which, under Union or Member State law, aims to provide information to the public and can be consulted by both the general public and any one able to demonstrate a legitimate interest ,only on condition that the requirements for consultation provided for by Union or Member State law are met.
In line with the provisions of Article 14 of the Swiss DPA and point (f) of Article 14(2) of the GDPR, we will not only process personal data provided directly by you but also other data obtained in other ways, for example from public and/or private databases. More specifically we use, for our clients, databases to gather the information we need in order to comply with legal requirements in the context of prevention and detection of money laundering, terrorist financing and fraud (e.g. the World - Check database). All information and personal data obtained through such databases will be processed and retained exclusively by our company.
Pursuant to Article 8 of the Swiss DPA, data subjects have the right to verify the correctness of their personal data, and to request the modification, rectification and/or updating of such data. Upon written request, the data subject has the right to be informed as to whether and how any personal data concerning him or her are being processed. Data subjects are also entitled to withdraw their consent to the processing of their personal data. In some specific cases, where prescribed by law, access to data may be denied. Data subjects have the right to obtain advice on the protection of personal data from the Federal Data Protection andInformation Commissioner ("Federal Commissioner"), and to report illegal data processing activities when:
The Federal Commissioner can be contacted at the addresses shown on www.edoeb.admin.ch/edoeb/it/home/l-ifpdt/contatto.htm l. In case of subjecting the processing of personal data to the GDPR following profiling created on monitoring pursuant to art. 3para. 2 lit. b GDPR, you may exercise your rights as envisaged under Articles15, 16, 17, 18, 19, 20, 21, 22 of said GDPR.
The data subject has the right to obtain from the controller, within the limits established by the Regulation, free access to the personal data concerning him or her, erasure of such data, the rectification of inaccurate data, the completion of incomplete data , the restriction of processing to storage only, and the right to object to processing, the cancellation (right to be forgotten) and the portability of your data. Where the data subject provided the personal data on the basis of his or her consent or the processing is necessary for the performance of a contract and data processing is carried out by automated means, the data subject is entitled to receive such personal data in a free structured, commonly used, machine - readable format and, where technically feasible, to transmit the personal data to another controller. The data subject has the right to withdraw his or her consent at 5 any time in accordance with point (a) of Article 6 (1) or point (a) of Article 9 (2) of the GDPR without affecting the lawfulness of processing based on said consent before its withdrawal. The data subject has the right to lodge a complaint with the competent supervisory authority in the Member State of his or her habitual residence or place of work or place of the alleged infringement. In any case, whichever regulation is applicable, rights must be exercised in writing by notifying the controller at the e - mail address info@taxnomadims.org, or the postal address of our registered office.
The controller is the subsidiary of IBEX SERVICES Ltd (registered office in Chiasso, Via Serafino Balestra 6)
E - mail address: info@taxnomadims.org
Telephone number: +41 91 6836343
Persons authorised to process personal data pursuant to Article 29 of the GDPR are the company's employees and co - workers, who will process said data according to the principles of confidentiality and security established by the applicable regulations.
