Privacy policy on the processing of personal data. Effective as of 19 august 2025
INTRODUCTION
The relationship with the user is regulated according to what is provided by the Swiss Federal Law on Data Protection (LPD) of September 25, 2020. More favorable rights provided by the user’s national law are preserved. In particular, for users who are in a country belonging to the European Union, the rights provided by the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR) apply. Users residing outside Switzerland are informed that this country has received an Adequacy Decision from the European Commission on January 15, 2024. Therefore, the transfer of personal data to Switzerland can be carried out without the need to obtain authorizations from the competent Privacy Authority.
Data Controller
Sotefin SA
VAT CHE-115.486.008
Via Gaggiolo 27, CH-6855 Stabio, Switzerland
Email: info@sotefin.ch
Phone:+41 91 950 88 41
Site to which this privacy policy refers:https://www.sotefin.com/en/ (Sito).
The Data Controller has not appointed a DPO. Therefore, you may send any inquiries directly to the Data Controller.
GENERAL INFORMATION
This document describes how the Data Controller processes your personal data.
The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.
Site registration
The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.
Purchases on the Site
It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose.The Data Controller does not process the user’s data to send “reminder” emails to purchase products and/or services from the Data Controller.
Answering your requests
Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.
Marketing
The Data Controller will not send you advertising material and/or newsletters regarding its own products or those of third parties. We use Google services, such as Google Ads and Google Analytics, to personalize advertisements and enhance user experience. This includes the collection of personal data and cookies, used to show you ads that match your preferences. Upon consent, you will be asked to authorize the use of this data. More details on cookie usage and consent management can be found in this website’s cookie policy.
Profiling
The Data Controller does not carry out “profiling” with your personal data. Therefore, it will not send you advertising material and/or newsletters relating to its own products or third parties of your specific interest.
Data transfer
The Data Controller does not transfer your personal data to third parties.
Geolocalization
The Site does not implement tools to geolocate the user’s IP address.
Curriculum Vitae
It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes.
Booking Service
There are no third-party appointment booking systems active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the heading.
Photographs and videos
The Data Controller does not request the publication of photographs and/or videos of you. Therefore, your data will not be processed for these purposes.
Web scraping
The use of any automated process or system to access, acquire, copy, or monitor any part of our website, including, but not limited to, web scraping, crawling, or spidering techniques, is expressly prohibited. The Data Controller reserves the right to take all necessary measures, including legal action, to prevent and prosecute any unauthorised scraping activities. By using the Site, the user or any third party agrees not to: (i) use automated systems, such as bots, scrapers, or spiders, to access or interact with the Site; (ii) collect content, data, or other information on the Site without express written permission; (iii) distribute, display, publish, or otherwise use content acquired through scraping techniques without consent. Any breach of this clause will be considered a material breach of the terms of use of the Site and will result in appropriate action being taken, including the possible suspension of access to the Site and the taking of legal action to protect the interests of the Data Controller.
Communication of personal data
As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.
The “communication” of personal data to third parties is different from the “transfer” (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.
Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.
PRIVACY POLICY
Art. 1 Method of processing
1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality.
1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.
1.3 Through the Site are not processed “special data”. Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.
1.4 No judicial data is processed through the Site.
Art. 2 Communication of personal data
The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:
- The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
- Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law.
- The Data Controller uses employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
- In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
- The Data Controller does not use CRM platforms (companies that carry out the activity of sending automated communications to users. Therefore, your personal data are not communicated to these companies.
- The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose.
- The Data Controller does not utilize banking institutions and companies that manage payment networks.
- Buyers’ personal data are not communicated to couriers or forwarding agents.
The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.
Art. 3 Personal data retention
3.1 This article describes how long the Data Controller reserves the right to retain your personal data.
- User data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site.
- For customer care purposes, data will be deleted once the service is completed and, in any case, within a maximum period of 3 months after the last exchange of e-mails with the person concerned.
3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.
Art. 4 Transfer of personal data
4.1 The Data Controller is located in a country that has an adequate level of security from a regulatory standpoint. If the transfer of your personal data takes place to a non-EU country and for which the European Commission has expressed a judgment of adequacy, the transfer is deemed safe from a regulatory standpoint in any case. This article 4.1 indicates from time to time the countries where your personal data may possibly be transferred and where the European Commission has expressed a judgment of adequacy.
- Your personal data may be transferred to the USA based on what is established by the adequacy decision of the European Commission. With this decision, the European Commission has determined that the USA provides personal data protection comparable to that offered by the European Union.
- The transfer of your personal data may take place in Switzerland. The transfer is covered by the decision of the European Commission of January 15, 2024, which found that Switzerland ensures an adequate level of protection for personal data transferred from the European Union. The decision was motivated by the publication of the Swiss privacy law in force since September 1, 2023.
4.2 Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred.
4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the reference country, together with that which governs the relationship with the user as indicated in the Preamble.
- At the request of the user, the Data Controller will apply to the processing of personal data any more favourable legislation provided for by the user’s national legislation.
Art. 5. Your rights
The Data Controller informs you that you have the right:
- to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability
- revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation
- to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).
The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.
Art. 6. Amendments
The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In case of substantial changes to this privacy policy, the Data Controller may give notice of such changes also by email.