Privacy Policy

Data Controller

Holding 58 SA

Via Livio, 24
CH-6830 Chiasso
Switzerland

Types of Data Collected

Among the Personal Data collected by this application, either independently or through third parties, are: first name, last name, phone number, email, Cookies, and Usage Data.

Full details on each type of data collected are provided in the relevant sections of this privacy policy or through specific information texts displayed before the collection of the data itself.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically while using this application.

Unless otherwise specified, all Data requested by this application is optional. If the User refuses to provide the required Data, it may be impossible for this application to provide the Service. In cases where some Data is optional, Users are free to refrain from communicating such Data without any consequence on the availability or operation of the Service.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

Any use of Cookies – or other tracking tools – by this application or by the owners of third-party services used by this application, unless otherwise specified, has the purpose of providing the Service requested by the User, as well as the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this application and guarantees that they have the right to communicate or disclose them, releasing the Data Controller from any liability to third parties.

Methods and Place of Data Processing

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to other parties involved in the operation of this application (administrative, sales, marketing, legal, system administration personnel) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of processing.

The Data Controller may process Personal Data relating to the User if one of the following applies:

The User has given consent for one or more specific purposes; in some jurisdictions the Data Controller may be allowed to process Personal Data without the User’s consent or another of the legal bases below, until the User objects (“opt-out”) to such processing.
Processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
Processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.
Processing is necessary to fulfill the services provided by this application.

In any case, the Data Controller 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.

The Data is processed at the operating offices of the Data Controller and in any other places where the parties involved in the processing are located. For further information, contact the Data Controller.

Personal Data may be transferred to a country other than the one where the User is located. For further information regarding the place of processing, the User can refer to the relevant sections of this document.

Users also have the right to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization 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 Data Controller to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquiring with the Data Controller using the information provided in the contact section.

Data Retention Period

Personal Data shall be processed and stored for as long as required by the purpose for which they have been collected. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the legitimate interests of the Data Controller shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.

Where the processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of 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 exercised after expiration of the retention period.

Purposes of Processing the Collected Data

The User’s Data is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Contacting the User and Analytics.

Users can find further detailed information about such purposes of processing and the specific Personal Data used for each purpose in the relevant sections of this document.

Details on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contacting the User
Contact form
By filling in the contact form with their Data, the User authorizes the use of these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.
Personal Data collected: first name, last name, phone number, email.

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Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to track User behavior. Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this application, compile reports, and share them with other services developed by Google. Google may use the Personal Data to contextualize and personalize ads within its advertising network. Personal Data collected: Cookies and Usage Data.
Place of processing: United States of America (USA) – Privacy Policy – Opt Out. Participant in the Privacy Shield framework.

User Rights

Users may exercise certain rights regarding their Data processed by the Data Controller.

In particular, the User has the right to:

Withdraw consent at any time. The User may withdraw previously given consent to the processing of their Personal Data.
Object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent. Further details on the right to object are provided in the section below.
Access their Data. The User has the right to obtain information regarding the Data processed by the Controller, certain aspects of the processing, and to receive a copy of the Data processed.
Verify and request rectification. The User may verify the accuracy of their Data and request its update or correction.
Restrict processing. Under certain conditions, the User may request the restriction of the processing of their Data. In this case, the Controller will not process the Data for any purpose other than storing it.
Request the erasure or removal of their Personal Data. Under certain conditions, the User may request the deletion of their Data by the Controller.
Receive their Data and have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transmitted without hindrance to another controller. This provision applies when the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party, or on pre-contractual obligations thereof.
Lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details about the right to object

When Personal Data is processed in the public interest, in the exercise of an official authority vested in the Controller, or for the purposes of the legitimate interests pursued by the Controller, Users may object to such processing on grounds related to their particular situation.

Users are informed that, should their Data be processed for direct marketing purposes, they can object to such processing at any time without providing any justification. To find out whether the Controller is processing Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise rights

To exercise their rights, Users may send a request to the Controller using the contact details provided in this document. Requests are free of charge and will be processed by the Controller as quickly as possible, in any case within one month.

Additional information about Data processing

The User’s Personal Data may be used by the Controller in legal proceedings or in the stages leading to possible legal action arising from improper use of this application or the related Services by the User.

The User declares to be aware that the Controller may be required to reveal Personal Data upon request of public authorities.

Upon the User’s request, in addition to the information contained in this privacy policy, this application may provide the User with additional and contextual information concerning specific Services, or the collection and processing of Personal Data.

For operational and maintenance purposes, this application and any third-party services it uses may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, where technically and legally feasible, through this application and/or by sending a notice to Users via any contact information available to the Controller. Users are 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 Controller shall collect new consent from the User, where required.

Notes

Personal Data means any information that directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data is information collected automatically through this application (or third-party services employed in this application), which may include: the IP addresses or domain names of the computers used by the User who connects with this application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used 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 used by the visitor, the various time details per visit (e.g., the time spent on each page) 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.

The User is the individual using this application who, unless otherwise specified, coincides with the Data Subject.

The Data Subject is the natural person to whom the Personal Data refers.

The Data Processor (or Processor) is 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.

The Data Controller (or Controller) is the natural or legal person, public authority, service, 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 application. Unless otherwise specified, the Data Controller is the owner of this application.

The Application is the hardware or software tool by which the User’s Personal Data is collected and processed.

Cookies are small sets of data stored in the User’s device.

Legal References

This privacy statement has been prepared based on multiple legal systems.

Unless otherwise specified, this privacy policy relates exclusively to this application.

Last Update

April 2025