Política de Privacidad

VULCAN ASSETS MANAGEMENT SA, route de Malagnou 38A, 1208 Geneva, (“VULCAN“, the “Company“, “us” or “we“) understands that your personal data and your privacy are important to you. 

The purpose of this Website Privacy Notice (the “Website Notice“) is to inform data subjects (“you” or the “User“) who access the website http://www.vulcan-am.ch (the “Website“) about how we collect, store, process and protect their personal data (“Data“). 

The Website Notice only applies to your use of the Website. For how we process data if you are a potential/actual client or a contractual partner/service provider, please refer to our Data Privacy Notice available at [insert link]. 

The Website furthermore uses cookies. For more information, please refer to our Cookie policy available at this link: https://vulcan-am.ch/cookies-settings/.  

1. Which Data we collect

The type of Data collected and processed by the Company depends on how you use the Website. 

i. Use of the Website

Whenever you use the Website, we will gather the information that is forwarded to our servers based in Switzerland by your browser, notably the access data required for technical reasons to be able to display the Website and warrant its stability and security. This includes the IP address, the date and time of your visit, the access status/HTTP status code, the referrer URL, the browser used, etc.

ii. Contact by email or phone

You can contact us by email or phone. 

Regarding any contact by email or phone, in addition to the elements mentioned under Chapter 1.i, we will receive the personal information you voluntarily provide us in your communication, for instance your name, address, email, telephone number, date and time of the request and content of your request. The emails you send us are stored in our servers in Switzerland. 

iii. Statistics

The statistics services allow VULCAN to monitor and analyze traffic data on the Website. They are used to keep track of the user of the Website behavior. The Website uses Google Analytics.

2. Why we process the Data

We may process the Data for the following reasons:

• to provide you with access to the Website;

• to be able to manage, secure, stabilize, develop and optimize the Website;

• to carry out statistical and other analysis regarding the use of the Website;

• to process your request, if you contact us using the contact form of the Website;

• to send you the Newsletter if you subscribe to it;

• to reply to your email/to any request submitted by you;

• to comply with any applicable laws and regulations;

• to comply with the request or requirement of any court of any relevant jurisdiction or any relevant authority; and

• for use in connection with any legal proceedings or regulatory action (including prospective legal proceedings/ regulatory action) and for obtaining legal advice or for establishing, exercising or defending legal rights.

3. How we store and protect the Data 

VULCAN only stores the Data for as long as necessary for the purposes described under Chapter 2 above and/or for as long as it has your permission to keep it, or if otherwise required by law.

Data will only be stored in our physical server/cloud located in Switzerland. We have taken the appropriate technical and organizational precautions to ensure that our servers are accessible exclusively to duly authorized persons. We have taken suitable technical measures to safeguard the Data. 

4. Your rights

You may exercise the following rights with respect to the Data:

• right to information – you can ask VULCAN if it processes Data about you;

• right to access Data – you can ask us to provide you with a copy of the Data it processes;

• right to request the rectification of Data – you can ask the Company to correct the Data if it is inaccurate;

• right to request the deletion of Data – you can ask us to delete the Data, subject to the Company being under a legal obligation to retain the Data or having a legitimate interest to retain the Data;

• right to request a limitation of the processing of Data – you can ask VULCAN to temporally restrict or to limit the processing of the Data, subject to any potential applicable legal provisions;

• right to request a prohibition on the processing of Data – you can ask VULCAN to stop the process of the Data, subject to any potential applicable legal provisions;

• right to withdraw your consent to the processing of Data – you can inform the Company that you revoke your consent, to the extent that you have given said consent to any specific purpose of processing the Data. The withdrawal of your consent will not affect the lawfulness of any processing of Data carried out before said withdrawal/carried out based on another grounds for justification.  

The exercise of any right set forth in this Chapter 4 shall be carried out as per the modalities provided for in Chapter 7. It may be refused or limited for legal reasons or based on the applicable data protection law. We will inform you of the reasons for such refusal/restriction to the extent permitted by law. 

5. Recipients of your Data

We may disclose Data in the situations described below:

• to third parties who provide services to us (e.g. IT companies);

• to public authorities, regulators or governmental bodies or other third parties, when required by law or regulation; or

• otherwise if you consent to such disclosure.

We do not sell the Data.

6. Transfer of Data abroad

We may transfer the Data we collect to countries other than the country in which the information was originally collected. Your Data might/will be transferred to or made accessible from the following countries:

• Switzerland;

• Countries within the EEA;

• United States of America.

These destination countries may not have the same laws on personal information as the country in which you initially provided the information through the Website. 

When we transfer your Data to other countries, we will protect that information as described in the Website Notice and in accordance with applicable law. If necessary, we require the recipients referred to in Chapter 5 above to comply with appropriate safeguards designed to protect personal information.

7. Communications

In case of questions about the Website, the Website Notice or more generally about data protection, please contact us by email at info@vulcan-am.ch

If we are unable to assist you, if you are not satisfied with our answer or if you believe that our processing of the Data is in contradiction with the applicable legal provisions, you can contact the Swiss Federal Data Protection and Information Officer and/or with any competent EU supervisory authority if applicable based on your place of residence. 

8. Amendments 

The Website Notice does not form part of any contract/contractual relation between you and VULCAN and your consent to the Website Notice is not required. We may revise the Website Notice unilaterally at any time without prior notice. Any change will be immediately posted on the Website. The current version of the Website Notice available on the Website shall apply. It is therefore recommended to consult the Website Notice regularly.