Privacy Policy

The data processing carried out by Frame Asset Management SA is conducted in compliance with the principles of fairness, lawfulness, transparency, and protection of confidentiality and the rights of each website user. This privacy policy provides an overview of how the data collected through the website www.frameam.ch is processed and the rights of every data subject, in accordance with the applicable data protection laws and regulations.

Data Controller

The Data Controller is Frame Asset Management SA (hereinafter, Frame AM) with its registered office at Via Vanoni 4, CH-6900 Lugano.
For further information on personal data processing or to exercise your rights, you can contact us by:

Writing to: Frame Asset Management SA, Via Vanoni 4, CH-6900 Lugano, Switzerland
Emailing: info@frameam.ch
Calling: +41 91 921 38 72

Personal Data and Processing

Personal data is information that identifies or can identify, directly or indirectly, a natural person and may provide information about their characteristics, habits, personal relationships, etc. Personal data includes, but is not limited to, the following: name, surname, address or other contact details, an identification number, or an online identifier.
Processing is any operation performed on personal data, with or without the use of automated processes. Processing includes, but is not limited to, the collection, recording, organizing, storing, modifying, consulting, deleting, or destroying data.

Processed Personal Data

Website Navigation

The computer systems responsible for the website's functioning acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This data is not collected to be associated with identified data subjects, but due to its nature, it could allow for the identification of the User through processing and associations with data held by third parties. This data includes the IP addresses or domain names of the computers used by the User connecting to the Website; the URI addresses (Uniform Resource Identifier) of the requested resources; the time of the request, and other parameters relating to the User's operating system and IT environment. This data is used solely to obtain anonymous statistical information on the website’s use to ensure its proper functioning, to identify anomalies and/or abuses, and is deleted immediately after processing. This data could be used to establish liability in the event of hypothetical computer crimes against the Controller or third parties.

Data Provided by the User

Voluntary, explicit submission of emails to the addresses indicated on this website involves the subsequent acquisition of the sender’s address, necessary for responding to requests, as well as any other personal data included in the message.
Personal data such as name, surname, email, and phone number are collected by the Controller when the “Contact” Form is filled out.
Personal data, such as the email address, is collected when the “Desknews”, “Monthly Bulletin”, “Newsletter”, or “Press Review” forms are completed.
In the case of unsolicited applications, data included in the CV and personal information provided by the Candidate through the email addresses on this website will be processed.

Purpose of Processing

User's personal data will be processed for the following purposes:

To respond to the User's requests by providing information on services of interest;
To follow up with potential candidates concerning unsolicited applications;
To fulfill legal obligations, regulations, and meet requests from competent authorities;
To send communications of interest to the User who has given their consent through the completion of one of the website's forms (“Desknews”, “Monthly Bulletin”, “Newsletter”, “Press Review”).

Legal Basis for Processing

Each processing operation is justified by one of the following legal bases:

Processing is necessary to fulfill the User's requests. In this case, providing personal data is mandatory;
Processing is necessary to comply with a legal obligation. In this case, providing data is mandatory;
Processing is necessary for the pursuit of the Controller's legitimate interest/predominant interest, provided it does not override the User's interests or fundamental rights and freedoms that require the protection of personal data. In this case, providing data is optional;
Processing is based on the User’s consent. In this case, providing data is optional, and consent can be withdrawn at any time by the Controller.

Data Sharing and Third Parties

Within the activities of Frame Asset Management SA and for the specified purposes, the Client’s personal data may be shared with Third Parties, duly appointed as “Data Processors,” who provide specific services (e.g., web hosting) on behalf of the Controller and under its specific instructions.

Method and Duration of Personal Data Storage

All personal data is stored electronically on servers located in Switzerland.
If necessary, the Controller may transfer data outside of Switzerland. In such a case, the Controller guarantees that the transfer will be in compliance with applicable legal provisions.
Client's personal data is stored for the period strictly necessary to fulfill the aforementioned purposes, in compliance with confidentiality and applicable regulations. If the processing is based on the Client's consent, personal data may be stored by the Controller until such consent is withdrawn.
CVs and information from unsolicited applications will be stored for up to 24 months from receipt if the application is unsuccessful.

User Rights

Every user can request, at any time, confirmation of whether their personal data is being processed and, concerning this data, they have the right to:

Request access to the data to obtain information on the purposes of the processing, the recipients to whom the data may be communicated, and the duration of processing (where possible);
Request the withdrawal of consent at any time, without affecting the lawfulness of the processing based on the consent provided before the withdrawal;
Request rectification of personal data if it is inaccurate or incomplete;
Request deletion of data if it is no longer necessary for the purposes for which it was collected, is inadequate for the processing purposes, the user has withdrawn consent, or the data has been processed unlawfully;
Request restriction of data processing, where applicable by law;
Request the transfer of data to another Data Controller in a commonly used and machine-readable format, without hindrance from the current Controller (where provided by applicable law);
Object to the processing of their data, specifically to decisions based solely on automated data processing, including profiling;
Lodge a complaint with the competent Authority if they believe that the processing of their data violates the applicable data protection regulations.

The user can exercise their rights by using the contact information provided in the "Data Controller" section.

Updates

Frame Asset Management SA reserves the right to modify or simply update the content of this Privacy Policy, in part or entirely, even due to changes in applicable legislation. These changes will be binding as soon as they are published on the Website. If the User continues to access or use the service after such publication, it is presumed that they have expressly accepted these changes. Therefore, Frame Asset Management SA invites the User to regularly visit this section to become aware of the most recent and updated version of the Privacy Policy to stay informed about the data collected and how Frame Asset Management SA uses it..

Date: 01.09.2023