Wecan Group SA (hereafter «WCG») is a company with its seat at Rue Eugène-Marziano 25, 1227 Geneva, Switzerland.
WCG is committed to respect your privacy and to comply with the provisions of the Swiss Data Protection Act (DPA) and the EU General Data Protection Regulation (GDPR).
1. The information we collect
1.1 Personal Data
The data collected by WCG includes all information necessary for WCG to carry out its contractual and legal obligations (“Personal Data”):
– Any information necessary to perform our Know Your Client (KYC) obligations, that is personal identification information, including corporate name, first name, family name, date of birth, gender, addresses, emails, telephone numbers, nationality, citizenship, residency, identity documents. The Personal Data includes any document that you provide to us, such as a copy of a passport;
– Information on relevant family members and business relationships;
– Education, professional qualifications, employment and professional information, references;
– Banking details;
– Information collected by our Website as described below (see section 1.3).
Personal Data is collected at different times and from different sources:
– When you or your organization/company contact us to contemplate or engage our services;
– Information gathered through our team in the framework of our contractual obligations;
– Through email, fax or telephone communications;
– Our Website.
1.3 Cookies, tracking and other similar techniques
1.3.1 In order to optimize your experience on the Website, cookies and similar tracking techniques may be used. These are small files that are saved on the web browser and that store certain configurations and data in the web browser to exchange them with WCG’s system. These are not used under any circumstances to store your Personal Data.
1.3.3 You are further informed that the Website also uses other third parties services like the above-mentioned Google Analytics such as Mix Panel, Hotjar and others.
1.3.4 The Website may use social plugins for various social network websites (hereinafter referred to as “Social network”), such as facebook.com (operated by Facebook, Inc.), twitter.com (operated by Twitter, Inc.) and plus.google.com (operated by Google, Inc.) (hereinafter referred to as the “Plugin(s)”). When the User visits a website that contain Plugins, the User’s browser will directly connect to the servers of the respective Social network. The content of the Plugin is directly transmitted to the User’s browser from each Social network and is integrated into the Website. By integrating the Plugin, the Social network receives the information that the User has visited the Website.
If you are logged on a Social network, it can associate your visit to the account of the respective Social network. If you interact with the Plugin, the corresponding information from your browser is directly sent to the respective Social network and stored there.
2. Why we collect and process your Personal Data
The Personal Data collected and processed by WCG may be used to:
(i) Contact you;
(ii) Identify you;
(iii) Perform our contractual duties regarding you or your organization/company;
(iv) Conduct administrative or operational processes within WCG;
(v) Process and respond to requests, enquiries or complaints received from you or someone within your organization/company;
(vi) Manage and administer your or your organization/company’s business relationship with WCG, including processing payments and billing;
(vii) Comply with any legal obligation where WCG is required to process the Personal Data, such as keeping records for legal purposes (anti-money laundering, tax, corporate);
(viii) Provide, monitor and improve WCG’s services;
(ix) Send newsletters and marketing material;
(x) Monitor the use of the Website;
(xi) Comply with any requests of or duties towards governmental authorities, law enforcement agencies, regulatory bodies or courts;
(xii) Establish, exercise or defend the legal rights of WCG or for the purposes of legal proceedings;
(xiii) For any other legitimate business purpose or overriding interest of WCG.
3. Sharing of information, access and transfers
3.1 Access by WCG
The management and employees of WCG may access your Personal Data to comply with WCG’s contractual and legal duties.
3.2 Access by service providers, business partners and others
You hereby expressly authorise WCG to use service providers and to delegate certain tasks (such as IT services and infrastructure, server location, maintenance and other services) to third parties. You further expressly authorise WCG to transfer Personal Data to third parties in the event of a merger, sale, liquidation or transfer of all or a portion of WCG’s assets. This implies that Personal Data may be communicated to such companies outside Switzerland.
In this context, you are hereby informed that certain jurisdictions do not have legislation providing an appropriate level of protection within the meaning of the Swiss Federal Act on Data Protection. If the User’s Personal Data has to be shared with such companies and the other conditions of the DPA and/or GDPR are not met, WCG will request your consent.
3.3 Compliance with applicable laws and requests by authorities ; overriding interests of WCG
WCG may transfer Personal Data to third parties such as local or foreign governmental authorities, law enforcement agencies, regulatory bodies or courts, when such transfer is reasonably necessary to comply with provisions of the law or a mandatory legal request or to protect an overriding interest of WCG.
4. Storage and Security
Your Personal Data is entered into our electronic systems and paper files that are processed and stored physically and electronically on servers located in Switzerland.
5. Retaining of Personal Data
We retain your Personal Data as long as necessary for the purposes mentioned above, to provide our Services and to satisfy our contractual and legal obligations (such as reporting or accounting obligations).
If the Personal Data is no longer required for the execution of our contractual duties, it will be returned or deleted unless such data is necessary to implement a legal duty, in particular retention duties pursuant to tax or commercial law. This includes in particular the Swiss code of obligations, the Swiss Anti-Money Laundering Act, the Swiss VAT Act, and Swiss tax law.
6. Your rights
You have a right of access pursuant to Article 8 DPA (Article 15 GDPR), a right of rectification where the information we hold about you is inaccurate pursuant to A rticle 5 DPA (Article 16 GDPR), a right to request that your Personal Data be erased according to Article 5 LPD (Article 17 GDPR) or to restrict the use of your personal information pursuant to Articles 12, 13, 15 DPA (article 18 GDPR), a right to object to the processing of Personal Data pursuant to Article 4 DPA (article 21 GDPR) and, where applicable, data portability according to Article 20 GDPR. You may also submit a complaint with the competent data protection authority if you have any concerns (Article 77 GDPR).
If you have a question or request, please send us an email at the following address: firstname.lastname@example.org
You may withdraw your consent at any time. Please note that such withdrawal shall only apply for future collecting/processing of your Personal Data and does not impact the collecting/processing which occurred in the past. Please note that WCG may nevertheless process your Personal Data in presence of legal obligations or an overriding interest of WCG, including exercising its legal rights. Withdrawing your consent may lead to the end of the business relationship with WCG.
Please inform us as soon as possible if any of your Personal Data changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide our services.
You are liable for the accuracy and extensiveness of the data transferred to WCG and for providing updates should your Personal Data change.
WCG cannot be held responsible for any situation that may arise due to us having any inaccurate, incomplete, inauthentic or otherwise deficient personal data that you or a third party has provided to us.
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