This policy applies to all users of the www.croce-associes.ch website.
We are committed to protecting client confidentiality, and to complying with all the data protection laws and regulations designed to safeguard your personal information.
The specific data that we process and the way that we do this can vary, mainly depending on the services that we provide to you or arrange with you. The information below is made available solely to give you an overview of the way we process your personal data, and the rights that you have when you use this website. When you request or arrange a service, we will inform you, in detail and in advance, of the data processing that will be involved in providing the service.
However, the lawful basis for most of the processing we carry out is that it is necessary for the performance of the (pre)contract that exists between you and one of the firm’s lawyers to provide legal services (assistance, representation or advice).
Consequently, by spontaneously sending us documents, including via our online platform, or by sending us emails containing your personal data, you are giving us your express consent to process this data to fulfil the requests that you have made and/or to provide the services and/or information that you have requested.
We will always respect your fundamental rights and freedoms as regards your data. You can refuse all or part of the processing described in this confidentiality policy at any time. Moreover, we take client confidentiality extremely seriously and will never communicate your personal data to a third party (a court, the authorities, the opposing party, etc.) without your consent, except if we are legally required to do so.
Under the Swiss Criminal Code (article 321 CC) and also the Federal Act on Freedom of Movement for Lawyers (article 13 FAFML) and the Swiss national rules of professional conduct (article 15 NRPC), both our lawyers and the other people working for and with the firm (secretaries, interns, translators, etc.) are bound by client confidentiality rules. Consequently, your information cannot be communicated to the authorities or to any third party without your consent. This obligation covers all the documents you provide to us and does not terminate when the contract between us ends.
Client confidentiality is an absolute right. It covers both representation in court and before the authorities and legal advice.
The legal profession in Switzerland is subject to disciplinary supervision. Faults are sanctioned both under criminal law and by disciplinary action, which can ultimately result in the lawyer being struck off.
Only services directly linked to legal practice are covered by the lawyer’s client confidentiality obligation. Consequently, if a lawyer carries out work that is not typically part of their remit, such as for example providing wealth management, financial intermediation, company director or trustee services, this is not covered by the client confidentiality obligations of the legal profession.
Consequently, when we provide financial intermediation services regulated by the Swiss Financial Market Supervisory Authority (FINMA) and our business relationship is not covered by the legal profession’s client confidentiality obligations, we may be required under anti-money laundering and terrorist financing rules to inform the Money Laundering Reporting Office Switzerland (MROS) or the Federal Justice and Police Department of any suspicion of money laundering.
When you visit the CROCE & Associés SA Website, our web server automatically records details about your visit (for example, your IP address, the web site from which you visit us, the type of browser software used, the CROCE & Associés SA Website pages that you actually visit including the date and the duration of your visit).
In addition, we collect personal data which you provide through the CROCE & Associés SA Website, for example when you enter personal details (e.g. name, address, e-mail address, phone/fax number) on a registration page or if you sign up for our email newsletter.
CROCE & Associés SA will use your personal data:
- for the purpose of answering your requests,
- for the purposes of technical administration and research & development of the CROCE & Associés SA Website,
- for user administration and marketing,
- to inform you about our services and products, and for such purposes as otherwise specified.
CROCE & Associés SA uses tracking technology such as cookies or tags to gather information as outlined above to understand how visitors use the CROCE & Associés SA Website. Tracking technology helps us manage and improve the usability of the Website, for example by detecting whether there has been any contact between your computer and us in the past and to identify the most popular sections of the CROCE & Associés SA Website.
When using this Website, you can provide your name, and email in the registration form for the newsletter. By registering, you confirm your wish to receive our latest publications and news. The information sent by email is free.
CROCE & Associés SA only contacts individuals who specifically requested via our registration form. Registration is free and involves no commitment on your part.
You can stop receiving our newsletters at any time by contacting us at the following address: firstname.lastname@example.org
Your churn will be effective within 72 hours of your request.
CROCE & Associés SA may disclose your information to its affiliates and its and their agents and companies of the Group (including abroad) to perform services for CROCE & Associés SA and for the purposes stated above. Our affiliates and agents who have access to personal data obtained through the CROCE & Associés SA Website are obliged to respect privacy
Subject to legal requirements (e.g. disclosure to government entities, regulatory authorities or other agencies), we do not pass on your personal data to third parties. In particular, CROCE & Associés SA will never sell, exchange or disclose in any form whatsoever your personal data.
When transferring personal data internationally we make sure that we comply with applicable laws and regulations, for example, by entering into agreements which will ensure that the recipients of your information maintain an adequate level of data protection.
We may use social plug-ins of various social networks, for example LinkedIn, Twitter or Google. These plug-ins are functions of the respective social network through which you can share content of our Site with your social media contacts, for instance, or recommend this content to others. Social plug-ins can be identified by the logo of the respective social network.
Via the integrated social plug-ins, the social network operators, which are usually located in the United States of America, will be informed that you have called up the respective pages of our Website. If you are logged into any of the social networks at the same time, the operator will be able to match the relevant call-ups with your account at the respective social network. Moreover, if you interact with social plug-ins, the relevant information will be forwarded to the respective social network. For details on the purpose and scope of data processing, collection and use by the social networks we are using, and on your rights and optional settings in this context, please refer to the social networks’ statements on data protection to be found on the respective websites.
All electronic messages sent to and from CROCE & Associés SA are automatically retained in a distinct journaling system which preserves the evidential weight of the e-mails. They are protected by reasonable technical and organisational measures and may only be accessed in justified cases in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations) to specific persons in defined functions (e.g. Legal, Compliance). All emails are disposed of after the applicable retention period has expired.
The Internet is generally not regarded as a secure environment, and information sent via the Internet (such as to or from the CROCE & Associés SA Website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than exists in your country of residence.
Please note that we accept no responsibility or liability for the security of your information whilst in transit over the Internet to CROCE & Associés SA. In order to protect your privacy we would like to remind you that you may choose another means of communication with CROCE & Associés SA, where you deem it appropriate.
You can use our web portal (client area) to send us your documents and receive documents from us, easily and quickly. The portal is password protected and the data we collect is stored on secure servers in a location outside the European Union and the United States. Although we can never guarantee that any document transfer system is completely secure, this is currently the safest and most efficient method available for exchanging documents between us. We recommend you use it for any documents you need to send us. We will send you an initial password, and then update it regularly. You should never give your password to anyone else. These precautions protect your data from loss, misuse, unauthorised access, disclosure, alteration and destruction.
As required by the Swiss Federal Act on Data Protection and our code of conduct, you can:
- check whether we hold your personal data,
- ask us to provide you with a copy of your personal data,
- ask us to return any document you have provided to us (subject to any legal requirement we may have to keep a copy), and
- require us to correct any of your personal data that is inaccurate.
We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
The CROCE & Associés SA Website does not seek to collect personal data from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal data to CROCE & Associés SA on the CROCE & Associés SA Website.
The person responsible for the processing of your personal data is Manuela Robutti-Croce (telephone +41 (0)22 906 85 00; email@example.com). Please do not hesitate to contact her with any questions you may have.
If you are not satisfied with CROCE & Associés SA’s response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen.
Last update : April 2019