Aletheia Consulting SA ("Aletheia") operates the website at address "https://www.aletheiasa.ch" which aims to provide information on the characteristics of the services offered, and a service to set up free interviews with people interested in obtaining more information in order to evaluate the possible subsequent conclusion of a contract.
This document informs the persons concerned about the use of the acquired data, and about the terms and conditions under which the preliminary contacts take place in case of interviews or free preliminary consultations, use of the forms and of the material present in the "download" section or however made available to the persons concerned.
If the contract is concluded, further relations are regulated, also for the treatment of the data, by the contract itself; if it is not concluded, the data are treated and kept only to fulfil legal obligations and for the time necessary for this only, until the expiry of the limitation terms of the respective rights, and within the limits of consent regarding the sending of communications.
Some data may be disclosed to other parties, such as Tresorit for file downloads, Hostpoint for web hosting, Protonmail for email messages and Microsoft for appointment setting. In this case it is necessary to refer to the respective privacy policies; the communication to Microsoft takes place on the basis of the exception constituted by the treatment carried out for the conclusion of a possible contract.
(1) IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER AND HIS REPRESENTATIVE
The data controller is Aletheia Consulting SA, with headquarters in Via Calprino 18, 6900 Paradiso (CH), and EU representative Aletheia S.r.l. with registered office in Piazza Giovanni XXIII 8, 93100 Caltanissetta (Italy).
(2) CONTACT DETAILS OF THE DATA PROTECTION DEPARTMENT
The Data Protection Officer - Consultant for data protection is Marcello Mancuso, who can be reached at email@example.com and mobile +41(78)404.4270.
(3) PURPOSES AND LEGAL BASIS OF THE PROCESSING ACTIVITIES
This website collects only the data of users who fill in the appropriate form, decide to send the data of the self-assessment test or make an appointment for a free interview for further information or a free preliminary consultation. These data are transmitted voluntarily by the user, and their absence prevents the establishing of a contact; no other data are acquired involuntarily during the navigation, even through cookies, except those possibly stored by Tresorit (email address) regarding the opening of downloaded files. The data acquired are the following:
- Company name (optional)
- Your name (mandatory)
- Your email (mandatory)
- Company phone (optional)
- Reason for contact (mandatory)
- Other data provided directly after contacting.
These data are used for the following purposes:
a - Direct contact and test evaluation feedback, free preliminary consultation, kick-off meeting, free information interview and other negotiations prior to the possible conclusion of a contract
b - Sending communications to update on products and services via email (optional).
The legal bases are negotiations for the conclusion of a contract for the processing in point "a" and the consent, revocable at any time, for the processing in point "b".
(4) DESTINATARIES OR CATEGORIES OF DESTINATARIES OF PERSONAL DATA
Your data may be communicated to the following subjects:
- subjects who can access the data by virtue of a provision of the law or by order of the competent authority;
- our employees, if designated System Administrator or as a subject acting under our authority as Data handler;
- subjects who carry out, in total autonomy, as separate Data Controllers, or as Data Processors appointed for this purpose by the Data Controller, purposes ancillary to the activities and services of the preceding paragraph: in particular, we use for communications and file exchange Tresorit, which is a subject based in Switzerland and therefore covered by declaration of adequacy, with servers within the EU borders. Our website and some utilities are hosted by Hostpoint, a provider based in Switzerland, which therefore also offers adequate guarantees, while e-mails are managed by the provider Protonmail, based in Switzerland, which uses advanced technologies for data security in transit and therefore also adequate. The relevant data (name and email address, reason for contact) are transferred abroad under the exception relating to the conclusion or execution of a contract provided for in the LPD, as Microsoft provides sufficient technical and organizational security guarantees.
(5) TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION
As stated in the preceding paragraph, the utility for scheduling appointments is managed through Microsoft. The relevant data (name and email address, reason for contact) are transferred abroad under the exception relating to the conclusion or execution of a contract provided for in the LPD, as Microsoft provides sufficient guarantees, by means of appropriate technical and organizational measures, that the security of personal data is adequate.
(6) PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED, OR IF IT IS NOT POSSIBLE, CRITERIA USED TO DETERMINE SUCH PERIOD
The data will be processed exclusively for the purposes specified in paragraph 3, and only to the extent necessary and compatible with such purposes. They are retained for a period equal to the period of prescription of any rights for the purpose of protection before the competent authorities, and beyond if expressly required by law or by order of the competent authority.
(7) RIGHTS THAT YOU CAN EXERCISE
You have the right to:
- request access to and rectification or erasure of personal data or restriction of processing;
- object to processing;
- request data portability;
- withdraw consent at any time, without prejudice to the lawfulness of processing based on consent until its withdrawal;
- file a complaint with the supervisory authority.
(8) EXISTENCE OF AUTOMATED DECISION MAKING PROCESSES, INCLUDING PROFILING AND, IF POSITIVE, SIGNIFICANT INFORMATION ON THE LOGIC IN QUESTION, AND ON THE SIGNIFICANCE AND INTENDED CONSEQUENCES OF SUCH PROCESSING FOR THE INTERESTED PERSON
We do not do any such thing.
(9) TERMS OF PERFORMANCE OF OUR FREE PRELIMINARY SERVICES
You accept responsibility for the data you provide us with and you guarantee that you have the right to communicate or disseminate them, releasing us from any liability to third parties.
Our free preliminary services are:
- provision and possible evaluation on request of the self-assessment test;
- free preliminary remote consultation;
- pre-bid meeting (kick-off meeting).
These services are provided offline, by means of oral interviews or exchange of e-mails or equivalent individual communications.in all cases our activity consists of a first contact that is carried out only on the basis of the elements reported by you, without verification, with the sole purpose of information of the principles and rules abstractly applicable to the case that you propose, the abstract possibilities of solution according to the applicable rules and the technical and organizational measures available. Therefore, it does not constitute specific advice for your specific case, and cannot give rise to any liability on our part due to the limitations mentioned above.
- Before making any decision, you must obtain specific expert advice. We do not authorize or guarantee that you will make any decision based on our preliminary discussions. -
If you request it, we will make an offer and in case of your acceptance we will conclude a contract that will regulate our further relationship.