1. Information about the collection of personal data and contact information of the person responsible
1.1 We are pleased that you are visiting our website and thank you for your interest. In the following we inform you about the handling of your personal information when using our website. Personal information is any data with which you could be personally identified.
1.2 This Privacy Notice applies to the processing of your personal data by FIRST INDEPENDENT FUND SERVICES LTD (FIFS), Klausstrasse 33, 8008 Zurich.
For questions or requests related to data processing by FIFS, you may revert by mail to the address above write us via E-mail at firstname.lastname@example.org.
1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or requests to the person responsible), this website uses SSL or TLS encryption. You can see an encrypted connection to the string "https://" and the lock icon in your protocol.
2. Data collection when you visit our website
When you use our website for information purposes, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you call our website, we collect the following data that are technically necessary for us to display the Web page:
- our visited Web page
- date and time at the time of the access
- quantity of the sent data in byte
- source/reference, by which you arrived on the page
- used browser
- used operating system
- IP address
The processing takes place in accordance with Article 6 paragraph 1 lit. f GDPR based on our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. We reserve the right however to check the server log files, later concrete evidence should point to an illegal use.
Please note that for non-acceptance of cookies, the functionality of our website may be limited.
Personal data collected within the framework of the contact with us (e.g., via contact form or email). Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored solely for the purpose of answering your request for contact and the associated technical administration and use. Legal basis for the data processing is our legitimate interest in answering your request in accordance with Article 6 paragraph 1 lit. f, GDPR). If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1). 1 lit. b, GDPR). Your data will be deleted after final processing of your inquiry; this is the case if it can be inferred from the circumstances that the facts in question have been conclusively clarified and provided that there are no legal storage obligations to the contrary.
5. Use of your data for direct marketing (newsletter)
If you subscribe to our email newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your email address. Another possible information is voluntary and is used to personally talk to you. We use the so-called opt-in procedure for sending the newsletter. This means that we only be sent an email newsletter, if you have explicitly confirmed that you consent to the sending of newsletters. With your registration you give us your consent for the use of your personal data according to Art. 6 Abs. 1 lit. a GDPR. When you register for the newsletter, we store your IP address entered by the Internet Service Provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your email address at a later point in time. The data collected by us when registering for the newsletter will be used exclusively for the purposes of advertising in the form of the newsletter. You can unsubscribe at any time via the link provided in the newsletter or by an appropriate message to us. After your cancellation, your email address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data or we reserve the right to use data in excess thereof, which is permitted by law and about which we inform you in this declaration.
6. Web analysis services
This website uses Google AdWords, an analysis service of Google, and within Google AdWords the conversion tracking. Google AdWords stores a cookie for conversion tracking on your computer's hard drive (so-called "conversion cookie") when you click on an ad placed by Google. These cookies lose their validity after 30 days and are not used for personal identification. If you visit certain pages on our website, Google and we can recognize that you clicked on the ad and were redirected to that page. The information obtained through conversion cookies is used to compile statistics for AdWords customers who use conversion tracking. These statistics tell us the total number of users who clicked on the ad served by Google and visited a page with a conversion tracking tag.
In addition to Conversion Tracking, we also use the features:
- Target groups with common interests
- user-defined target groups with common interests
- ready-buying target groups
- similar audiences
- demographic and geographical focus
7. Tools and miscellaneous
Google Web Fonts
8. Rights of the affected parties
The applicable data protection law grants you comprehensive rights of data subjects (rights of information and intervention) vis-a-vis the data controller with regard to the processing of your personal data, about which we inform you below:
- Right to information in accordance with article 15 GDPR: in particular, a right to receive information, have your personal data processed by us, the purposes of the processing, the categories of processed personal data, the recipients or categories of recipients; to which your data were disclosed or are the existence of a right to correction, cancellation, constraint processing, object to the processing, the planned storage period or the criteria for the determination of the storage period, complaint to a supervisor, the origin of your data, if it is not collected by us when you, the existence of an automated decision making including profiling, and any meaningful information about the involved logic and the specific scope and the intended effects of such processing, as well as your right to be informed as to which guarantees exist in accordance with article 46 GDPR in forwarding your data to third countries;
- Right of rectification in accordance with article 16 GDPR: you have the right incorrect data relating to you for immediate rectification and/or completion of your incomplete data stored by us.
- Right to cancellation in accordance with article 17 GDPR: you have the right to require the deletion of your personal data when the conditions of article 17 para. 1 GDPR. This right however in particular then does not exist, if the processing to the exercise of the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or to claim, exercise or defence of legal claims is required;
- The Right to restrict the processing pursuant to Art. 18 GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data contested is verified, if you refuse to delete your data due to inadmissible data processing and instead request the restriction of the processing of your data, if you need your data to assert, exercise or defend legal claims, after we no longer need this data after the purpose has been achieved or if you have filed an objection for reasons of your particular situation, as long as it has not yet been determined whether our legitimate reasons predominate;
- If you have exercised your right to have the responsible party correct, delete or limit the processing, this party is obliged to inform all recipients to whom the personal data that concerns you has been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort. It is your right to have the responsible party inform you regarding such recipients.
- You have the right to receive the personal data you have provided to us in a structured, current and machine-readable format or to request its transfer to another responsible person, insofar as this is technically feasible.
- Right to revoke consents granted in accordance with Art. 7 para. 3 GDPR: You have the right to revoke consent to the processing of data at any time with effect for future for the future. In the event of revocation, we will delete the data concerned without delay, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its revocation.
- Right of appeal under Art. 77 GDPR: If you believe that the processing of personal data concerning you is contrary to the GDPR, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or suspected infringement, without prejudice to any other administrative or judicial remedy.
9. Right of objection
When we process your personal data in the framework of interests as a result of our overriding legitimate interest, have you at any time right for reasons arising from your particular situation to the processing to file an opposition with effect for the future. If you exercise your right of objection, we end the processing the affected data. We will however continue processing the data if we have demonstrably compelling reasons for processing which are in need of protection and which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. If your personal data are processed by us in order to participate in direct marketing, you have the right at any time object to the processing of personal data relating to you for the purpose of such advertising. You can object as described above. If you exercise your right of objection, we end the processing the affected data.
10. Duration of the retention of personal data
The duration of the retention of personal data shall be determined on the basis of the respective statutory retention period (e.g., trade and tax retention periods). After the deadline, the data are routinely deleted when they are no longer necessary for the performance of the contract or contract and/or continues on our part no legitimate interest in the further storage.
Zurich, August 2020