Privacy Policy

The www.lakeward.ch website was produced and published by Lakeward
Management AG with its registered office in Switzerland at Dufourstrasse 47, 8008
Zurich, entered in the Commercial Register of the Canton of Zurich, Switzerland,
under no. CHE-304.477.041. As such, we are responsible for the collection,
processing and use of your personal data and for conformity of data processing with
the applicable data protection laws.

Your trust is very important to us. We therefore take data protection extremely
seriously and have appropriate security measures in place. We of course comply
with all legal requirements under the Swiss Federal Act on Data Protection (FADP),
the Ordinance to the Federal Act on Data Protection (OFADP), the
Telecommunications Act (TCA) and with the provisions of the EU General Data
Protection Regulation (GDPR) and other provisions of Swiss and European data
protection law.

An explanation of how we handle your personal data is given below.

Please be aware that this information will be revised and updated from time to time.
We therefore recommend that you regularly check this Privacy Policy.

1. Scope and purpose of collection, processing and use of personal data

1.1. When you visit our website

When you visit our website, our servers record this access in a temporary log file. As is standard practice whenever a connection to a web server is established, this log file includes the following technical data, is created without any involvement on your part, and is stored on our servers for a maximum of six months before being deleted automatically:

The IP address of the requesting computer;
The name of your internet service provider;
The date and time of access;
The website from which the website was accessed (referrer URL), and potentially the search term used;
The name and URL of the retrieved file;
The status code (e.g. error message);
Your computer’s operating system;
The browser you are using (type, version and language);
The transfer protocol used (e.g. HTTP/1.1).

The purpose of collecting and processing this data is to enable use of our website (establishing a connection), to ensure system security and stability over the long term, to optimise our internet offering and to carry out internal statistical analysis. These purposes constitute a legitimate interest in data processing on our part pursuant to Article 6(1)(f) GDPR.

The IP address is also evaluated alongside other data in the event of a network infrastructure attack or other prohibited use or misuse of the website, in order to investigate the matter and take preventive action. It could potentially be used for identification purposes in criminal investigations or in civil or criminal proceedings against the user. This constitutes a legitimate interest in data processing on our part pursuant to Article 6(1)(f) GDPR.

1.2 When you contact us by e-mail

Our website offers the option of contacting us by e-mail.

You are responsible for the message and/or content that you send us in this way. We recommend that you do not transmit any confidential information. Personal data is only collected if you voluntarily provide it to us. As such, you are responsible for deciding what data you share. To be able to answer your questions, we may sometimes ask you to provide further information such as your address, telephone number, etc. We collect such personal data from you only where this is needed to respond to your questions or to provide a service that you have requested.

Dealing with your enquiries submitted via e-mail constitutes a legitimate interest in data processing on our part pursuant to Article 6(1)(f) GDPR. You can withdraw your consent for such data processing at any time (see Section 9 “Contact”).

1.3. When you contact us by telephone

Our website offers the option of contacting us by telephone.

You are responsible for the message and/or content that you share with us in this way. We recommend that you do not transmit any confidential information. Personal data is only collected if you voluntarily provide it to us. As such, you are responsible for deciding what data you share. To be able to answer your questions, we may sometimes ask you to provide further information such as your address, telephone number, etc. We collect such personal data from you only where this is needed to respond to your questions or to provide a service that you have requested.

Dealing with your enquiries raised via telephone constitutes a legitimate interest in data processing on our part pursuant to Article 6(1)(f) GDPR. You can withdraw your consent for such data processing at any time (see Section 9 “Contact”).

1.4. When you use our contact form

You have the option of contacting us via a contact form on our website. When using this form, we require the following information:

First name and last name*;
Country*;
E-mail adress*;
Subject;

The fields marked with an * are mandatory.

We use this data solely to be able to respond to your enquiry personally and in the most appropriate way. Dealing with your enquiries raised via the contact form constitutes a legitimate interest in data processing on our part pursuant to Article 6(1)(f) GDPR. You can withdraw your consent for such data processing at any time (see Section 9 “Contact”).

2. Cookies

Cookies help make various aspects of your experience of our website simpler, smoother and more meaningful. Cookies are information files that your web browser automatically stores on your computer’s hard drive when you visit our website. Cookies do no harm to your computer’s hard drive and do not transmit any personal information on users to us.

Most internet browsers accept cookies by default. However, you can configure your browser settings so that no cookies are stored on your computer or so that you are always notified of any new cookies. Instructions on how you can manage your cookies in the most commonly used browsers are given below:

Please be aware that deactivating cookies may mean that you are unable to use the full functionalities of our website.

3. Tracking tools: Google Analytics and Google Tag Manager

We use Google Analytics, a web analysis service provided by Google Ireland Limited, Google Building Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland and Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. Google Analytics uses methods that enable website use to be analysed, such as cookies. They compile information on how you use this website, such as:

The path via which a user navigated to the website;
The time spent on the website and its subpages;
The subpage from which the user left the website;
The country, region or city from which access was made;
The end-device used (type, version, colour depth, resolution, width and height of browser window) ;
Repeat or new visitor;
The browser provider/version;
The operating system used;
The referrer URL (previous web page) ;
Host name of the requesting computer (IP address) ;
Time of server request.

This information is transmitted to and stored on Google servers in the USA. In so doing, the IP address is truncated through the activation of IP anonymisation on this website prior to transmission; this applies in Member States of the European Union, other signatory states of the European Economic Area and Switzerland. The anonymised IP address sent to Google Analytics by your browser is not combined with any other data held by Google. In exceptional cases only, the full IP address might be transmitted to a Google server in the USA and truncated there. In such cases, we have contractual guarantees in place that Google will adhere to adequate data protection standards.

The information is used to analyse how the website is used, to produce reports on website activity, for other services connected to use of the website and the internet, for market research purposes and to design this website in a way that meets users’ needs. Google may share this information with third parties where this is legally permitted and where the third parties process this data on behalf of Google. Google undertakes that under no circumstances will the IP address be used in conjunction with other data relating to the user.

We also use Google Tag Manager to manage our services in connection with usage- based advertising. The Tag Manager tool itself is a cookie-free domain and does not record any personal data. Instead, the tool triggers other tags, which may in some cases record data. If you have performed a deactivation at domain or cookie level, this remains in place for all tracking tags implemented using Google Tag Manager.

The legal basis for processing data for the above purposes is our legitimate interest pursuant to Article 6(1)(f) GDPR. You can withdraw your consent for such data processing at any time (see Section 9 “Contact”).

Users can prevent the data recorded by the cookies and relating to their use of the website (including the IP address) from being gathered and processed by Google by downloading and installing a browser plugin available via this link:

https://tools.google.com/dlpage/gaoptout?hl=en-GB

An opt-out cookie will be stored on your device. If you delete your cookies, you will need to follow this link again.

4. Google Maps

We use the Google Maps API (Application Programming Interface, “Google Maps”) provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA on our website for the visual representation of geographical information (maps). When Google Maps is used, information on your use of our website, including your IP address, is transmitted to a Google server in the USA and stored there.

The legal basis for processing data for this purpose is our legitimate interest pursuant to Article 6(1)(f) GDPR. You can withdraw your consent for such data processing at any time (see Section 9 “Contact”).

It is possible to deactivate Google Maps services and prevent the transmission of data to Google by deactivating JavaScript in your browser. Please be aware that if you do so you will be unable to use the map feature.

You can find more information on how Google collects, processes and uses your data and your rights in this regard in the Google Privacy Policy at https://policies.google.com/privacy, and in the Google Maps/Google Earth Additional Terms of Service at https://www.google.com/help/terms_maps/.

5. Social media plug-ins

On our website, we offer certain social media functions, including in particular links to videos on YouTube. Link sharing is possible for the following social media platform:

YouTube, a service operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

When you click on a social media symbol, you are directed to the social media platform in question. You will then need to log into your user account, if you are not already logged in. When you click on a social media symbol, a direct connection is established between your browser and the server of the social media platform in question. In this way, the platform receives the information that you visited our website from your IP address and followed the link to that social media platform. When you access a platform via a link while logged into the platform in question, the content of our website could be linked to your profile on that platform, i.e. the platform could directly link your visit to our website with your user account. If you wish to prevent this, you should log out of the account in question before clicking on the link. Such an association will still be made if you log in to the platform after clicking on the link.

In such cases, we are not considered to have disclosed your data under the Data Protection Act. Please be aware that we as the provider of this website have no knowledge of the data transmitted or of the use of the data by the provider of social media plugins. You can find further information in the social media providers’ privacy policies.

6. Links to our social media profiles

Our website includes links to our social media profile on the following social media platform:

LinkedIn Corp., 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA;

When you click on a link to one of our social media profiles, a direct connection is established between your browser and the server of the social media platform in question. In this way, the platform receives the information that you visited our website from your IP address and followed the link. When you access a platform via a link while logged into the platform in question, the content of our website could be linked to your profile on that platform, i.e. the platform could directly link your visit to our website with your user account. If you wish to prevent this, you should log out of the account in question before clicking on the link. Such an association will still be made if you log in to the platform after clicking on the link.

You can find further information on the purpose and scope of data collection and processing by the social media platforms named above and the applicable rights and data protection options in their privacy policies.

7. Storage and sharing of data with third parties

7.1. Central storage and linkage of data

We store the data covered by this Privacy Policy in a central electronic data processing system. Your data relating is systematically collected, linked and evaluated in order to respond to your enquiries and to perform our services. To achieve this, we work with Mirabit AG, Neustrasse 2, Romanshorn, Switzerland.

Diese Verarbeitung beruht auf unserem berechtigten Interesse im Sinne von Art. 6 Abs. 1 lit. f DSGVO zur kundenfreundlichen und effizienten Verwaltung von Kundendaten. Sie können dieser Datenverarbeitung jederzeit widersprechen (siehe Ziffer 9, Kontakt).

7.2. Retention period

We store your personal data only for as long as is needed for the provision of the services that you have requested or for purposes for which you have given your consent.

Please note, however, that defined retention periods may apply by law to certain types of data. We are required to hold this data until the end of the retention period. For example, business communications and contracts concluded must be retained for up to ten years. We block such data in our systems and use it solely to fulfil our legal obligations.

7.3. Sharing of data with third parties

We only share your personal data where you have given us your express consent, where we are under a legal obligation to do so or where this is necessary to assert our rights, especially for the enforcement of claims arising from contracts. We also share your data with third parties where this is necessary for the use of our website or the processing of enquiries that you make when you contact us.

We also share your data with our affiliated companies, including Lakeward Advisory AG, c/o Treforma AG, Grabenstrasse 25, CH-6340 Baar, Switzerland, where this is necessary for the performance of the requested service.

One service provider with which personal data gathered via the website may be shared or which may have access to such data is our web hosting company, Mirabit AG, Neustrasse 2, CH-8590 Romanshorn, Switzerland. The website is hosted on servers located in Switzerland. Data is shared for the purposes of providing and maintaining the functionalities of our website. The legal basis for such processing is our legitimate interest in data processing pursuant to Article 6(1)(f) GDPR.

7.4. Cross-border data sharing

We are permitted to share your personal data with third-party companies outside Switzerland commissioned by us for the purposes of the data processing described in this Privacy Policy.

Such providers are bound by the same data protection rules as we are. Where the level of data protection in a country does not meet Swiss or European standards, we ensure by contractual means that the protection of your personal data will comply with Swiss or EU requirements.

7.5. Information on data sharing with the USA

In the interests of completeness, you should be aware that under US legislation the US authorities may undertake monitoring actions that permit the general storage of all data sent from the European Union or Switzerland to the USA. This takes place without differentiation, restriction or exception, based on the purpose pursued and without objective criteria that would allow access by the US authorities to personal data and its subsequent use to be restricted to specific, strictly limited purposes that would justify access to such data.

You should also be aware that the USA offers no legal remedy for data subjects from EU Member States or Switzerland that would enable them to gain access to the data relating to them and to have it rectified or deleted, and that there is no effective legal protection against access rights by the US authorities. We expressly draw the attention of data subjects to this situation so that they can make an informed choice about approving the use of their data.

7.6. Data security

We take appropriate technical and organisational security measures to protect your personal data that is stored with us against manipulation, partial or total loss and unauthorised access by third parties. Our security measures are improved on an ongoing basis as the technology becomes more sophisticated.

You should always keep your login details confidential and close your browser windows when you have finished communicating with us, particularly if you are using a shared computer.

We also take our internal data protection extremely seriously. Our employees and the service providers that we use are bound by confidentiality and required by us to comply with data protection regulations.

8. Right of access, right to erasure and right to rectification

You can withdraw your consent for data processing at any time. You have the following rights:

The right of access : You have the right to demand access at any time, free of charge, to the personal data that we hold on you, where we process such data. You are entitled to check what personal data we process in relation to you, and to check that we are doing so in accordance with the applicable data protection rules.

The right to rectification: You have the right to have any inaccurate or incomplete personal data rectified and to be informed of the rectification. We will in such cases inform the recipients of the affected data about the changes made, provided this is not impossible or excessively onerous.

The right to erasure: You have the right to have your personal data erased under certain circumstances. The right to erasure may be rejected in individual cases.

The right to restrict processing: You have the right under certain conditions to demand that the processing of your personal data be restricted.

The right to data portability: If you are resident in an EU or EEA Member State, you have the right under certain circumstances to receive the personal data concerning you, which you have provided to us, free of charge and in a machine- readable format.

The right to lodge a complaint with a supervisory authority: If you are resident in an EU or EEA Member State, you have the right to lodge a complaint with a competent supervisory authority concerning the manner of processing of your personal data.

Right to withdraw consent: You have the right to withdraw consent at any time. However, such withdrawal does not render unlawful any past processing activities based on your consent at that time.

9. Contact

If you have any questions about data protection in relation to our website, would like more information or wish to request that your data be deleted, please e-mail us at info@lakeward.ch.

You can also write to us by post at:

Lakeward Management AG
Dufourstrasse 47
CH-8008 Zurich

As at: August 2020