Aletheia Consulting SA manages this website, at “https://www.aletheiasa.ch” which aims to provide information about our services.
This document is intended to inform you about the use of your data, and about the terms and conditions under which our preliminary contacts take place in the event of free preliminary consultation, use of the modules and material in the “download” section or otherwise made available to you , and kick off meetings.
In summary, through this site we do not acquire data from you, unless you decide to contact us. In this case, we will use the data that you will communicate to us exclusively to respond to your requests, and for the negotiations for the possible conclusion of a contract with you, according to the following terms and conditions.
If we and you agree on a service contract, our further relationships will be regulated, also for data processing, by the contract itself; if a service contract is not closed, the data will be processed and stored only to fulfill legal obligations and for the time necessary for this only, and within the limits of your consent regarding the sending of newsletters.
This applies to the www.aletheiasa.ch site, while some of your data may be processed by other subjects, such as Tresorit for downloading files or Wire for chat. In this case you need to refer to their privacy policies.
(1) Identity and contact details of the data controller and his representative
The Data Controller is Aletheia Consulting SA, based in via Franscini 2a, 6710 Biasca (CH), with EU representative Aletheia S.r.l. based in piazza Giovanni XXIII 8, 93100 Caltanissetta (Italy).
(2) Contact details of the Data Protection Manager
The Data Protection Officer is Avv. Marcello Mancuso, reachable at firstname.lastname@example.org and at mobile +41 (78) 404.4270.
(3) Purposes and legal bases of processing activities
This site only collects the data of the users who fill out the contact form or who decide to send the data of the self-assessment test.
These data are transmitted voluntarily by the user, and failure to do so prevents contact; no other data is acquired unintentionally during navigation, except for those stored by Tresorit regarding the opening of downloaded files.
The data acquired are the following:
– Company name (optional)
– Your name (required)
– Your email (required)
– Business phone (optional)
– Reason for contact (required)
– Other data provided directly after contact
They are used for the following purposes:
a – Direct contact and test evaluation feedback, free preliminary consultancy, preliminary offer meeting (kick-off meeting) and other negotiations for the possible conclusion of a contract
b – Sending newsletters to update on products and services via email (optional).
The legal bases are the negotiations for the conclusion of a contract for the treatments at point “a” and the consent, revocable at any time, for the treatment at point “b”.
(4) Recipients or categories of recipients of personal data, if any
Your data may be destined to the following subjects:
– subjects who can access the data by law or by order of the competent authority;
– our employees, if designated as System Administrator or as a subject acting under our authority;
– subjects who carry out, in total autonomy, as separate Data Controllers, or in their capacity as Data Processors appointed for the purpose by the Data Controller, auxiliary purposes for the activities and services of the previous paragraph: in particular we provide communications and file exchange thanks to Wire and Tresorit, which are subjects based in Switzerland and therefore covered by a declaration of adequacy, with servers within the EU borders. You should also note that all data thus transmitted is encrypted, and not accessible by Wire and Tresorit.
Our site and some utilities are hosted by Hostpoint, a Swiss-based provider, which therefore also offers appropriate guarantees, while e-mails are managed through the Swiss-based provider Protonmail, which uses advanced technologies for data security even in transit and therefore also adequate.
(5) Transfer of personal data to a third country or an international organization and the existence or absence of an adequacy decision by the Commission or reference to appropriate or appropriate safeguards and the means to obtain a copy or when they have been made available
As mentioned in the previous paragraph, there is no such transfer.
(6) Period for which personal data will be stored, or if this is not possible, criteria used to determine this period
Data processing is carried out exclusively for the purposes specified in paragraph 3, and only to the extent necessary and compatible with these purposes. They are kept for a period equal to that of prescription of any rights for the purpose of defense before the competent offices, and beyond if expressly requested by the law or by the order of the competent authority.
(7) Rights you can exercise
You have the right to:
– request access and rectification or cancellation of personal data or limitation of processing;
– oppose the processing;
– request data portability from us;
– revoke your consent at any time, without prejudice to the lawfulness of the treatment based on the consent until its withdrawal;
– submit a complaint to the supervisory authority.
(8) Existence of automated decision-making processes, including profiling and, if so, significant information on the logic in question, as well as on the significance and expected consequences of this treatment for the data subject
We don’t do anything like that.
(9) Conditions of provision of our preliminary free services
You assume responsibility for the data you transmit to us and you guarantee that you have the right to communicate or disseminate them, freeing us from any liability to third parties.
Our preliminary free services are:
– provision and possible evaluation upon request of the self-assessment test;
– free remote preliminary consultancy;
– preliminary offer meeting (kick-off meeting).
These services are provided offline, through oral interviews or exchange of e-mail messages or equivalent individual communications.
In all cases our activity consists of a first contact that is carried out solely on the basis of the elements reported by you, without verification, for informational purposes only, of the principles and rules abstractly applicable to the case in point, of the abstract possibilities of solution in based on the applicable rules and the technical and organizational measures available. It therefore does not constitute punctual advice aimed at your specific case, and due to the above-mentioned limits it cannot give rise to our responsibility.
— Before making any decision, you must take the specific opinion of an expert. We do not authorize you or give any guarantee if you make decisions based only on our preliminary talks —
If you request it, we will make an offer and in case of your acceptance we will eventually conclude a contract that will regulate our further relationships.