Privacy Policy

  1. Data protection

antonioborsi.com adheres to the highest data protection and transparency standards,  regarding  its personal data collection and processing standards. “Personal data” is any information that relates to an identified or identifiable individual.

As part of our commitment to the protection of your personal data, we want to inform you:

  • why and how antonioborsi.com collects, uses and stores your personal data;
  • the legal rules applying to individual data collection;
  • what your rights and our obligations are in relation to the processing of your personal data.

 

  1. What types of personal data do we may collect?

Depending on the relationships or interactions we may have with (or services we may provide to) you, antonioborsi.com may collect and process the following personal data:

  • your name, phone number, physical and electronic mailing address,
  • all information from our interactions with you and the services you use,
  • any records of phone calls between you and antonioborsi.com,
  • data transmitted by your browser and automatically recorded by a server, including access data, IP address, file names as well as the transmitted data volume and the performance of the access, your web browser information and requesting domain,
  • data from public registers or private registers, public administration or other third-party service providers, such as screening providers, credit rating providers, fraud prevention agencies and antonioborsi.com business partners and antonioborsi.com clients,
  • antonioborsi.com may also collect information about business partners, shareholders, beneficial owners, employees, legal representatives, agents and directors. Before providing antonioborsi.com with this information, you should provide a copy of this notice to those individuals.

 

  1. On which legal basis and for which purposes do antonioborsi.com process your personal data?

3.1          Legal requirements

The processing of your personal data by antonioborsi.com will be one of the following:

  1. necessary for antonioborsi.com’s legitimate business and any other interests, without unduly affecting your interests or fundamental rights and freedoms,
  2. required to fulfil antonioborsi.com’s legal or regulatory responsibilities,
  3. necessary in order to allow antonioborsi.com to enter into, a client servicing or any other business relationship with you,
  4. necessary for the performance of a task carried out in the public’s interests,
  5. necessary for establishing, exercising or defending legal claims or
  6. where the processing relates to personal data available in the public domain, and
  7. processed with your consent, where required by law, or processed with your explicit consent in the case of special categories of personal data.

 Examples of the ‘legitimate interests’ referred to above are antonioborsi.com:

  1. pursuing certain of the purposes set out in sections 3.2 below;
  2. exercising our rights under Articles 26 and 27 of the Swiss Federal Constitution, including our freedom to conduct a business and right to property;
  3. being obliged to make any of the disclosures referred to in section 4 below, in its provision of services, and
  4. meeting antonioborsi.com’s accountability and regulatory requirements, in each case provided such interests are not overridden by your privacy rights.

Any consent antonioborsi.com has obtained to process ordinary personal data does not apply for the purposes of the rules under the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”).  

For the purposes of the EU GDPR, antonioborsi.com relies on the lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests and antonioborsi.com’s ability to rely on any such grounds is dependent on your agreement that any conflicting provisions, under  the EU GDPR, are hereby expressly waived by you.

Where the personal data we collect from you is needed to meet our legal or regulatory obligations or enter into a business relationship with you, there is a high likelihood that we may be unable to enter into a business relationship, provide certain services or continue to interact with you, if we are unable to collect any such personal data.

3.2 Purposes of processing

antonioborsi.com processes your personal data for a specific purpose and only processes personal data that is relevant to the achievement of that purpose. In particular, antonioborsi.com processes personal data for the following reasons:

  1. client onboarding processes, including the verification of your identity, assessment of your request (including any guarantee or securitisation requirements) and the conducting of legal and other regulatory compliance checks,
  2. providing client or service solutions to you and ensuring that we can provide and continue to provide you with the best available solutions,
  3. managing our business relationship with you as a client, including communicating with you in relation to any client or services solutions we offer,
  4. helping us to learn more about you,
  5. performing qualitative checks,
  6. conducting market research to understand how to improve our services, contacting you for marketing purposes about services we think could be of interest to you, including those offered by us or our business partners,
  7. meeting antonioborsi.com’s compliance and legal obligations, including disclosures to tax authorities, financial service regulators and any other supervisory bodies, and investigating or preventing illegal activities,
  8. ensuring the safety of our clients, employees and stakeholders,
  9. undertaking statistical analysis, research and operational checks,
  10. for risk management, audit and administrative purposes,
  11. for any other purposes that antonioborsi.com may notify you of, from time to time.

 

3.3. Marketing analysis

antonioborsi.com may collect and use the information about your personal newsletter subscriptions and your personal interaction data (the articles and topics you are interested in, read or subscribe to) to learn about your preferences and improve the knowledge provided to you via antonioborsi.com’s newsletters and any direct communication between you and us. antonioborsi.com will not use your personal interaction data for any other purpose except for improving its services and client offerings.

antonioborsi.com will use your personal data to manage your participation at registered events, manage your subscriptions and, subject to applicable law, to inform you about events or services that may be of interest to you, unless you inform us that you no longer wish to receive any marketing material from us.

3.4. Cookies

A cookie is a small text file that is downloaded onto your terminal computer or smartphone when you access a website. It allows the website to recognize your device and store some information about your preferences or past actions.

What cookies do antonioborsi.com use?

antonioborsi.com uses certain cookies which are essential for the functioning of its website. For example, your log-in details or increasing the performance of our website. This allows antonioborsi.com to measure how many times a page has been visited, whether a page has been visited on the antonioborsi.com website through an advertisement or by other means. Other cookies help antonioborsi.com to remember your settings and for certain pages, antonioborsi.com uses cookies to help us understand your interests as you browse the internet, so we can customize and deliver to a better service to you in the future.

antonioborsi.com may utilize cookies on certain pages to communicate with third party data suppliers in order to understand your digital behaviour. This helps us to target more relevant advertising in the future. The information antonioborsi.com receives is anonymous, but will include statistics such as demographics, online behaviour, product interests and lifestyle. Targeting and tracking cookies are provided via trusted third-party suppliers.

How do I disable cookies?

If you do not want to receive a cookie, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. Please be aware that if you do turn off 'cookies' in your browser, you may not be able to fully access some of our content.

Web analytics services

antonioborsi.com may use your connection data for statistical purposes and to manage and improve the usability of our webpage by means of particular software (e.g. Google analytics) or cookies (as described above).

Social media platforms

You may wish to participate in antonioborsi.com blogs, forums and other social media platforms through which we make content available to you. antonioborsi.com cannot be held responsible if you share personal information that is used, misused or otherwise appropriated by another user.

 

  1. Who has access to personal data and with whom are they shared?

4.1 antonioborsi.com related companies

antonioborsi.com usually shares personal data with related partner companies, in order to ensure a consistently high service standard and to be in a position to provide certain services to you as a client.

4.2 Third Parties

When providing services to you, antonioborsi.com will share your personal data with persons acting on your behalf or otherwise involved in an interaction with antonioborsi.com including, the following types of companies:

  1. a party acquiring interest in, or assuming risk in or in connection with a transaction (such as an insurer);
  2. payment counterparties like beneficiaries, account holders and correspondent banks;
  3. credit rating providers;
  4. issuers, fund managers and their directors and officers, or other financial institutions; and
  5. companies to whom antonioborsi.com, with your prior consent, introduces or refers you.

4.3 Service providers

antonioborsi.com shares personal data with suppliers, including antonioborsi.com companies and other business partners who provide services to us, such as IT, web, marketing, advertising, financial services, debt collection, debt recovery, fraud prevention and other companies.

4.4 Public or regulatory authorities

If required by law, antonioborsi.com will disclose personal data to authorities or regulators.

4.5 Others

In case of a merger or acquisition involving antonioborsi.com, your personal data will be shared within any new entity that results from any such transaction. antonioborsi.com will also share personal data with prospective purchasers whenever we consider selling or transferring part or all of our business activities. antonioborsi.com may need to disclose personal data to exercise its own legal rights, and those of stakeholders and employees, or in response to requests from individuals or their representatives, who seek to protect their legal rights or the rights of others.

  1. International transfers of personal data

Any  partners referred to in section 4 above may be located outside Switzerland. In those cases, except where the relevant country has been determined by Switzerland’s Federal Data Protection Officer to provide an adequate level of protection, antonioborsi.com shall require such a company to comply with all applicable data protection rules.

  1. Your rights

You have a right to ask antonioborsi.com to rectify any inaccuracies in your personal data and to request the restricted use of your personal data pending the consideration of your request.

You have a right to ask antonioborsi.com to stop processing your personal data or to request the deletion of your personal data – while these rights are not absolute, we will always consider your request and provide you with a response accordingly.

You have the right to withdraw your consent for us to process your data at any time. The withdrawal of your consent will not affect the lawfulness of our processing your personal data prior to such  consent withdrawal.

Where antonioborsi.com processes your personal data, on the basis of your consent, or where such processing is necessary for our entering into or performing obligations towards you, pursuant to a business relationship, you may have the right to request your personal data be transferred to you or to another controller. You have the right to ask our Data Protection Manager for a copy of part or all of the personal data we collect and process about you.

  1. Complaints

You may exercise any of your rights in relation to your personal data by writing to us:

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Should you be not satisfied with antonioborsi.com’s response, you have the right to file a complaint to the data protection authority in the jurisdiction where you reside or are permanently employed, or in such other place where you believe an issue, in relation to your data, has arisen.

  1. Security

antonioborsi.com and its selected service providers have appropriate technical and operational measures to prevent unauthorised access to your personal data. Nevertheless, as complete protection cannot be guaranteed for communication via e-mails, online messaging, and other technologies, we strongly recommend sending confidential information through alternative secure means.

  1. Changes to personal data

We are committed to keeping your personal data correct and up to date. Therefore, if your personal data changes, please inform us of the change .

  1. Other provisions

antonioborsi.com will retain personal data for the period of your business or contractual relationship with antonioborsi.com plus 10 calendar years thereafter, reflecting the length of time for which legal claims may be made following termination of such business relationship. Any ongoing or anticipated legal or regulatory proceedings may lead us to retain your personal data beyond this period.

antonioborsi.com stores all business communication and client data in an archive located within Switzerland for a period of at least 10 years.

  1. Status of this privacy notice

antonioborsi.com reserves the right to amend its privacy notice from time to time. If the privacy notice is updated, we will take reasonable steps to inform you of any such update by appropriate means or through the standard communication channels we normally use to communicate with you.