The site www.clearfinity.ch (hereinafter referred to as "Website") is edited and published by Clearfinity Managing Partner Sàrl (hereinafter referred to as "Clearfinity"). Please refer to our Legal Notice for more information about our company and our Website.

Access to and use of our Website is governed by all applicable laws, our Terms of Use and Privacy. If you do not agree to these terms, you are not permitted to continue using the Website and our services.

Clearfinity respects your right to privacy.

All processing of personal data carried out as part of the services offered by Clearfinity on the Website is carried out in accordance with the Federal Data Protection Act of 19 June 1992 (LPD, R.S 235.1) and Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the "General Data Protection Regulation", "RGPD"), where applicable.

This Privacy Policy explains how and for what purpose we use information collected about you through our Website or through offline programs or events.

We invite you to regularly review our Privacy Policy to stay informed of any updates.

1. DATA CONTROLLER

Clearfinity Managing Partner Sàrl

Grand-Rue 13, 1204 Geneva - Swizterland

Registered with the Trade Registry of the State of Geneva.

N° IDE & VAT: CHE-214.024.634

Director of Publication and data protection: Francoise Roden

Contact: Tel: +41 79 890 08 08 / E-mail: info@clearfinity.ch

2. YOUR CONSENT

By browsing our Website or providing us with your personal data, you agree to the rules described in this Privacy Policy. If you do not agree with these rules, please do not use or visit our Website or provide us with your personal data.

3. THE DATA COLLECTED

We only collect personal data that you are willing to provide us, which results from your actions on our Website and which we need to offer or improve our services to you, or for another legitimate reason, i.e personal contact information such as: name, first name, birth date, address, email, phone number;

We may collect personal data about you from third party data aggregators (e.g. Google), promotional partners, public sources and third-party social networking sites. Such information may include personal data as part of your profile on a third-party social network and that you allow that third party to share with us, pursuant to their rules.

When we use social plugins, we may also collect and process personal data in connection with your accounts on social networks. The collection and processing of personal data communicated to us by these social networks is governed by the Privacy Policies specific to these social networks, which we invite you to consult.

4. COOKIES

We use cookies, which are files stored on your computer when you visit our Website and may collect certain information, such as your IP address or browsing preferences.

Among these cookies, the cookies classified as necessary are stored on your browser as they are essential for the functioning of the basic functionalities of the Website.

We also use third party cookies that help us analyze and understand how you use our Website. These cookies will only be stored in your browser with your consent.

We use the following cookies on our website:

Name	Description
moove_gdpr_popup	Gestion de la politique d’utilisation des cookies sur clearfinity.ch
_ga (xxxxx)	Traceur Google analytics

To manage cookies and trackers, depending on the display, click on the information bar at the bottom of the screen then choose to authorize any of the cookies.

Alternatively, you can add the plugin ‘GaOptOut’ recommended by Google and lodge an objection to your IP address being collected and saved or tracker and cookie data being sent.

You also have the possibility to refuse the cookies.

The Help section of Internet browsers tells you how to refuse new cookies. You will receive a notification message.

In order to facilitate your approach, here are the links to the Help sections of the most commonly used browsers:

- Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies,
- Safari: http://support.apple.com/kb/PH5042,
- Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647,
- Firefox: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies,

For more information on how cookies and targeted advertising work, you can visit www.youronlinechoices.eu and www.allaboutcookies.org.

Refusing to use some performance cookies may result on the Website or its utilities malfunctioning. As the visitor or the client, you are solely liable for the consequences of your choices. Clearfinity cannot under any circumstance be held liable for its malfunction.

5. WHY DO WE COLLECT AND USE PERSONAL DATA

We may use your personal data to:

• to fulfil your mandates on a contractual basis;
• to respond to your queries;
• to contact you for marketing purposes;
• to combine with information we receive from others to help understand your needs and to provide you with better service, including customizing our Website and serving you interest-based advertising;
• for safekeeping and maintenance of our Website; for reporting; and for risk, dispute and record management.

6. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

Personal data are not generally transmitted to third parties, they will only be transmitted in the context of processing your requests and mandates, Clearfinity will be required to legitimately communicate your personal data to our subcontractors.

We have adopted internal policies and procedures through which all our team members are sensitized to the importance of maintaining control of personal data.

Your personal data may be transferred to the following third parties:

• Based on the consent you have given;
• Persons or entity that you direct us to share your information with;
• To our subcontractors for legitimate processing to respond to and fulfill your requests. Our subcontractors receiving only the data required to fulfill your requests and using it exclusively for that purpose;
• To our subcontractors in the context of legitimate processing so that we can provide you with a user-friendly and optimized Website;
• To our subcontractors for legitimate processing and with your consent for marketing and advertising purposes;
• In the event of a merger or acquisition of all or part of Clearfinity by a third party;
• To authorities having the right to access the information in the context of the implementation of legal obligations.

In any case where cross-border transfer is done, we ensure that an adequate protection is guaranteed for personal data to be transferred outside of Switzerland and the EEA. In some specific cases when this level of protection is not guaranteed, we will obtain your prior consent or establish with the recipient of personal data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. You may request access to a copy of these safeguards by contacting us.

7. SUBCONTRACTORS

Clearfinity carefully selects its subcontractors, who are also committed to protecting your data.

Function	Name	Description
ANALYSIS TOOL	GOOGLE ANALYTICS	We use the analysis tool of GOOGLE Inc. Website: https://analytics.google.com/analytics/web/; Data Protection Policy: https://policies.google.com/privacy?hl=en-US If you want to disable Google Analytics, you will find the add-on for your relevant browser by clicking on:  www.tools.google.com/dlpage/gaoptout?hl=fr. Please note the deactivation Google Analytics may prevent the use of certain features available on the Website.
EMAIL	Mailchimp	For our mailings, we use MAILCHIMP of The Rocket Science Group, LLC. Website: https://mailchimp.com/; Data protection Policy: https://mailchimp.com/legal/privacy/
CMS	WORDPRESS	We use the CMS WORDPRESS from Automattic et surtout la communauté WordPress ! Website: www.wordpress.com; il s’agit d’un wordpress autohébergé donc la ref est wordpress.org Et ce qui suis ne nous concerne pas Data protection Policy : www.automattic.com/fr/privacy/.

 

8. DATA RETENTION

We do not, as a matter of business practice, retain personal data longer than necessary for the purposes stated and to comply with legal requirements, unless otherwise agreed to by you.

Your data may however be stored and/or archived for a limited period, which shall not exceed 10 years of time (unless legal obligations or regulations require or allow a longer retention period).

At the end of the applied retention period, we shall delete your data without it being required that any further information be provided to you.

9. SECURITY OF YOUR DATA

We take all reasonable technical and organizational precautions to protect your personal data from loss, unauthorized access and other violations. This data will not be sold or shared with third parties, except as provided in this Privacy Policy.

When the personal information we collect is no longer required for the purpose for which it was collected, or for any legal requirement, we destroy or delete it.

10. YOUR RIGHTS

You can request access to the personal data we hold about you by contacting us at info@clearfinity.ch. You have the right to tell us if you wish to withdraw your consent, correct, update or delete your personal data from our records. To help us process your request, please provide us with your name and contact information.

You can unsubscribe at any time to no longer receive communications from us by using the "unsubscribe" option at the bottom of each newsletter received or by contacting us at info@clearfinity.ch. You can also limit the use of tracking technologies, such as cookies, by configuring your browser to choose whether to accept or decline them.

Last update :  July 2021