Data controller
Intycode Sagl
Vicolo Concordia 1, 6932 Breganzona (Lugano), Switzerland
UID/VAT: CHE-260.486.512
Commercial register of the Canton of Ticino: CH-501.4.028.222-3
E-mail: compliance@intycode.com
Intycode Sagl manages any personal data collected through the cookies used on cleversuite.ch (the "Site").
Legal basis and consent
Swiss law (FADP). The processing of any personal data collected through technical cookies is based on the controller's overriding legitimate interest in providing a functioning and secure website (Art. 31 FADP). Under Art. 45c lit. b TCA, the use of cookies necessary to transmit a communication or to provide a service expressly requested by the user is permitted subject to prior information, without the need for prior consent.
European Union law (GDPR / ePrivacy Directive). The cookies used fall within the consent exemption of Art. 5(3) of Directive 2002/58/EC, as they are strictly necessary to provide the service requested by the user. Any related processing of personal data is based on the controller's legitimate interest (Art. 6(1)(f) GDPR) and, for the download-area cookie, on the performance of a contract (Art. 6(1)(b) GDPR).
For this reason the Site does not display a cookie consent banner: no cookies requiring consent are set. On your first visit we only show a short information notice, which you can dismiss and which in no way affects how the Site works or triggers any additional technology.
Should analytics or marketing cookies be introduced in the future, this policy will be updated and a prior-consent mechanism will be implemented, revocable at any time.
Transfers of data abroad
The data collected through the cookies described above is processed exclusively in Switzerland, in the data centres of Infomaniak Network SA.
Should providers located in the European Economic Area or in third countries be involved in the future, transfers will take place only to countries offering an adequate level of protection under the list in the Swiss Data Protection Ordinance (DPO) and the adequacy decisions of the European Commission, or on the basis of standard contractual clauses (SCCs) recognised by the FDPIC and approved by the European Commission.
Your rights
As a data subject, you may exercise the following rights:
- access to your personal data (Art. 25 FADP; Art. 15 GDPR);
- rectification of inaccurate data (Art. 32 FADP; Art. 16 GDPR);
- erasure of your data (Art. 32 FADP; Art. 17 GDPR);
- restriction of processing (Art. 18 GDPR);
- data portability (Art. 28 FADP; Art. 20 GDPR);
- objection to processing based on legitimate interest (Art. 21 GDPR).
Requests can be sent to compliance@intycode.com. We normally respond within 30 days.
You also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland or, if you reside in the EU, with the supervisory authority of your Member State.
Representative in the European Union
Intycode Sagl has no establishment in the European Union. The processing described in this policy currently falls within the exception of Art. 27(2)(a) GDPR: it is occasional, does not include large-scale processing of special categories of data and is unlikely to result in a risk to the rights and freedoms of natural persons. For this reason, no representative in the Union has been designated.
Should the volume or nature of our processing change, we will appoint an EU representative and publish their details here.
Changes to this policy
This Cookie Policy may be updated to reflect technical changes to the Site or changes in the legal framework. The version in force is always published on this page, together with the date of the last update. Material changes will be clearly signalled on the Site.
Contact
For any question regarding this Cookie Policy or the processing of personal data:
Intycode Sagl
Vicolo Concordia 1, 6932 Breganzona (Lugano), Switzerland
E-mail: compliance@intycode.com
Questions about cookies or your data?
Write to us: we respond within 30 days of receiving your request, and exercising your rights is free of charge.
This policy is issued in Italian and English. In the event of divergence, the Italian version prevails.
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