Privacy Policy

Overview

Aioma is dedicated to protecting the confidentiality and privacy of information and data entrusted to us. We comply with applicable Data Protection regulations, including in particular the Swiss Federal Act on Data Protection (FADP) and the requirements of the EU General Data Protection Regulation (EU-GDPR). Please read this privacy policy to learn about your rights, what data we collect, how we use and protect it.

Why do we need personal data

Aioma and its services only collect personally identifiable data necessary. We aim towards being transparent when we gather information and limit personal data to a minimum. The main reasons we need personal data is:

  • Providing services, delivering reports, products and other assets and meeting our contractual obligations.
  • Sending invitations and providing access to clients attending our meetings, workshops, training or events.
  • Promoting our products, services and information to existing and prospective clients.
  • Complying with legal and regulatory obligations relating to bookkeeping, tax documentation requirements, sanctions, embargo assessment, countering money laundering, terrorist financing, fraud and other forms of financial crime.
  • Administering, maintaining and ensuring the security of our information systems, applications and websites. 
  • Processing online requests, including responding to requests through our website or contact form, communications from individuals or requests for proposals and quotations.
  • Employment of personnel, engaging freelancers and work processes.
  • Searching for qualified partners and individuals.

Furthermore, we may be required to collect certain personal data by law. If you do not provide such data, we may not be able to provide the services, or we may have to cancel a product or service you have with us.

How we collect personal data

  • Directly: We obtain personally identifiable data directly from individuals in a variety of ways. This includes obtaining personal data from individuals who provide us with their contact information (e.g. business card, complete our online forms, subscribe to our website, register for workshops/training, attend meetings, calls or events we host. We may also obtain personal data directly when, for example, establishing a business relationship, performing professional services through a contract, or our hosted solutions, applications and guides or when receiving recruitment information (e.g. job application).
  • Indirectly: We obtain personally identifiable data indirectly about individuals from a variety of sources, including our clients or business partners. Some of the ways we indirectly gather personal data is:
    • Public sources – Personal data may be obtained from public registers such as news articles, commercial registers and records, sanctions lists, and internet searches.
    • Social and professional networking sites – If you register or login to our websites or services using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want to share with us.
    • Client engagements – Our clients may engage us to perform professional services, which involves sharing personal data they control as part of that engagement. Our work may include personal data processing under our clients’ control, systems and supervision, which may be governed by different privacy terms and policies.
    • Recruitment – We may obtain personal data about candidates, freelancers or workers from an employment agency, and other parties, including former employers.

We may attach personal data to our customer relationship management records to better understand and serve our clients, prospects, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.

What personal data we collect

Aioma and its services obtain the following categories of personal data about individuals through direct or indirect interactions or other situations described in this privacy policy.

  • Personal data: Following there is a list of personal data we commonly collect to conduct our business activities.
    • Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email, Skype or WebEx names, and business postal address)
    • Professional details (e.g., job and career history, educational background and professional memberships, published articles).
    • For employees and contractors, family and beneficiary details for mobility, official approvals and permits, insurance and pension planning services (e.g., names and dates of birth).
    • For employees and contractors, financial information such as taxes, payroll, investment interests, pensions, assets, bank details, insolvency records.
  • Sensitive personal data: When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes. Examples of sensitive personal data we may obtain include:
    • Personal identification documents that may reveal race or ethnic origin, religious beliefs or physical health, and possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
    • For employees and applicants, research and documents required may reveal criminal convictions or offences information.
    • Information provided to us by our contracted clients in the course of an engagement and required to fulfil our contractual obligation.
    • Dietary restrictions when registering for workshops, training or events that reveal religious beliefs or physical health.
  • Location-based data: We may process geographical locations, e.g. when you are using our website or other services to where you are accessing from and provide services near you.

Lawful reasons to process personal data

Aioma relies on the following legitimate reasons when we collect, use, store and retain personal data to operate our business, provide services and exercise our interests:

  • Contract: We process personal data in order to perform our services and meet our contractual obligations.
  • Consent: We rely on your freely given consent at the time you provided your personally identifiable data to us, or we gathered it lawfully indirectly.
  • Legitimate interests: We rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
    • Delivering services and products: To deliver the products and services, our clients have engaged us to provide.
    • Marketing: To deliver professional knowledge, insights, information, special events and offerings we believe are of interest for our clients, prospects, subscribers and other individuals.
    • Partner management and recruitment: To search and engage qualified partners and staff on projects or our organisation.
  • Legal obligations and public interest: We process personally identifiable data in order to meet regulatory and public interest obligations. This includes retaining your information according to requirements by law.

Sharing personal data with third parties

Aioma may share personal data with trusted third parties to help deliver efficient and quality products and services. These recipients are contractually bound to the same level of data governance and safeguards as us, who entrust them with the data. Examples where we engage and share data with third parties include payment and marketing services providers, law enforcement, other government or supervisory authorities, partners providing products and services with us according to the contract, our professional partners such as assurance (audit) and law firms or technology providers. Aioma remains in most cases the data controller.

Transfer of personal data outside Switzerland

Aioma stores personal data on servers located in Switzerland. We may transfer personal data to a trusted partner firm, outlined in the contract, outside Switzerland, when we have a business reason to engage these organisations. Each organisation is required to govern and safeguard personal data at minimum to our level of maturity and in accordance with applicable data protection legislation. We also transfer data outside of Switzerland if a client explicitly instructs us to do so, the client is located outside of Switzerland and it is lawful to do so.

Your data privacy rights

In connection to Aioma data processing, you have the rights listed below. Before responding to any request made in regard to your data rights, we may ask for proof of identity to fully identify you. This helps ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for sufficient information about your relationship with us so that we can locate your personal information.

  • Access: You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
  • Correction: You can ask us to correct our records if you believe they contain incorrect or incomplete information about you. 
  • Erasure: You can ask us to erase (delete) your personal data after you withdraw your consent to processing. We usually delete your data no longer required. Note that legal obligations might prevent us from deleting all your personal data (e.g. bookkeeping purposes).
  • Data portability: In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data in electronic form if technically feasible.
  • Automated individual decision-making: You can ask us to review any decisions made about you which we made solely based on automated processing, including machine learning, profiling, that produced legal effects concerning you or which significantly affected you.
  • Processing restrictions: You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it.
  • Right to object to marketing including profiling: You can object to our use of your personal data for marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
  • Right to withdraw consent: You can withdraw the consent that you have previously given to the processing of your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you, and we will advise you if this is the case.

We aim to respond within 30 days from the date we receive privacy-related communications free of charge. If your request is unfounded or excessive, we might deny your request or demand a fee. Depending on the circumstances, we may be unable to follow your request based on other lawful grounds.

Cookies

[LEGAL ENTITY/Platform] uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit the website, as well as through newsletters or emails that we exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of our web presence, and to measure the effectiveness of our marketing and product or service promotion activities. Where cookies are used, a statement will be sent to your browser explaining the use of cookies.

  1. IP address
    An IP address is a number assigned to your device whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate are recorded for marketing, IT security and system diagnostic purposes. This information may also be used in aggregated form to conduct website trend and performance analysis.
  2. Cookies
    Cookies may be placed on your computer or internet-enabled device whenever you visit [Platform] online. This allows the site to remember your computer or device and serves a number of purposes. On our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 60 days. Ignoring the notification banner and continuing to browse our website, will result in automatic consent given. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
  3. Guidance on cookie control
    Guidance on how to control cookies for common browsers is linked below:
    Google Chrome
    Mozilla Firefox
    MacOS Safari
    Microsoft Internet Explorer
  4. Opting-out
    Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings. You may also delete cookies from your device at any time. Please note that removing or blocking cookies can affect your user experience, and some functionality may no longer be available.
  5. Third-party tools and widgets
    Other third-party tools and widgets are used on our website to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service more comfortable to use. These cookies can be controled as instructed in section 8.3.
  6. For information on additional browsers and device types, please see http://www.cookiecentral.com/faq.
  7. If you wish to know what kind of tools we use that gather personal data from our website, please get in touch with us. 

Personal data confidentiality and security

Please refer to our Legal Notice to find out more about how we protect your personal data and confidentiality of information provided.

Retaining personal data

Aioma retains personal data for so long as it is required for the purposes for which it was collected, for legal and regulatory requirements or contractual arrangements. We also hold on to non-sensitive personal data to make offerings, proposals, stay connected with you and to provide products, services or other contractual obligations. We will dispose of personal data when we no longer need it or the legal retention period has expired.

Automated decision-making and profiling

Aioma and its services currently not uses any automated processing, including machine learning, profiling or other machine intelligence to provide its services. Should that change, we will provide additional information in this section of the privacy policy (for more information refer to section 22 of EU-GDPR).

Policy updates

We regularly review and update this privacy policy according to changing or new requirements. The most current version will always be available on our website. This privacy policy was last updated on 12 August 2019.

Contact information

This website is operated by Aioma, a Swiss organisation and a Swiss governed entity.

To report concerns you may have about our data handling practices you can contact the responsible data protection supervisory authority:
Switzerland: Federal Data Protection and Information Commissioner

Legal Notice

Your contact for privacy questions and concerns

Aioma AG
Marc Gasser
Hardturmstrasse 105
CH-8005 Zurich