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Privacy Policy

This Privacy Policy provides information regarding the processing of personal data (“Personal Data” or “Data”) of users of the official website of Co. Defined, Co. Defined SAGL (“CD”), www.codefined.co (“Site”).

If the user (“User(s)” or “Data Subject(s)”) does not accept the terms of this Privacy Policy and/or the Terms and Conditions of use of the Site, he or she should stop browsing and accessing it.

Personal Data Collected

Registration Data: Data requested for contact forms or newsletter signup, including computerized tools and procedures.

Navigation and Browsing Data: The systems and software procedures used to operate this website acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of internet communication protocols.

Cookies: Cookies are small text files that websites send to your device to uniquely identify your browser or store information/settings in your browser. You may control cookies through your browser settings. However, without cookies, you may not be able to use all features of our website. Our web servers may log details such as your operating system type, browser type, domain, system settings, language, country, time zone, and the IP address of your device.

Navigation, browsing data, and cookies are not collected to be associated with identified Data Subjects but could potentially identify Users through processing and association with data held by third parties.

Purpose of Personal Data Processing

The Personal Data collected may be processed by CD for the following purposes:

  1. Allowing the User to access the Site within the limits of the Terms and Conditions of use.

  2. Elaborating job applications or inquiries submitted by the User.

  3. Responding to requests for information submitted by the User and executing specific User requests.

  4. Obtaining statistical information on the use of the Site and collecting User profiles for information about services which CD believes may interest the User.

  5. Future marketing, promotional, and publicity purposes, including direct marketing, market research, and surveys regarding CD’s services and those of selected third parties.

  6. Ascertaining responsibility in case of hypothetical computer crimes committed against the Site.

Data Recipients

The Data may be processed by natural persons and/or legal entities, acting on behalf of CD and under specific contractual obligations, based in Switzerland, EU Member States, or countries outside the EU.

The Data may also be communicated to third parties to comply with legal obligations, execute Public Authorities' orders, or exercise CD rights before judicial authorities.

Data Controller

The Data Controller is Co. Defined SAGL, with a registered office in Via dei Ronchi 6, 6964 Davesco-Soragno (Switzerland), Tel. +41 78 848 7944; Email: [email protected]

Periods of Data Retention

The Data processed to provide the site access and services will be kept by CD for the period strictly necessary to fulfill such purposes. CD may continue to store these Data for a longer period to protect the company’s interests related to potential liability.

Rights of Data Subjects

Data Subjects can exercise the following rights in connection with the processing of their Data:

  • Right to access: Obtain confirmation from CD whether their Data are being processed and, where applicable, have access to them.

  • Right to rectification and right to erasure: Obtain the rectification of inaccurate/incomplete Data, and the erasure of Data when the request is legitimate.

  • Right to restriction of processing: Request suspension of the processing when the request is legitimate.

  • Right to data portability: Obtain Data in a structured, commonly used, and readable format, and transfer Data to other controllers.

  • Right to object: Object to the processing of Data when the request is legitimate, including for marketing or profiling.

  • Right to lodge a complaint: Lodge a complaint with a supervisory authority in case of unlawful processing of Data.

Data Subjects can exercise these rights by writing to Co. Defined SAGL, Via dei Ronchi 6, 6964 Davesco-Soragno (Switzerland) or sending an email to [email protected].

Explicit Consent for Data Collection

We will obtain explicit consent from users before collecting any personal data, particularly for sensitive data, by providing clear and specific consent requests.

Detailed Cookie Policy

In addition to the above, our cookie policy now includes information on third-party cookies and provides a clear mechanism for users to opt out. Users can manage their cookie preferences through their browser settings.

Data Protection Officer (DPO)

We have appointed a Data Protection Officer (DPO) as required under the Swiss FADP. For any queries, users can contact our DPO at [email protected].

Data Breach Notification

In the event of a data breach, we will notify affected users and the Federal Data Protection and Information Commissioner (FDPIC) within 72 hours, as required by the Swiss FADP. This notification will include the nature of the breach, the likely consequences, and the measures taken to address it.

Legal Basis for Processing

We clearly state the legal basis for each type of data processing activity as required by the Swiss FADP. This includes processing based on user consent, the necessity of processing for contract performance, compliance with legal obligations, and legitimate interests pursued by CD or third parties.

Links to Third-Party Websites

Our Site may provide links to third-party websites for your convenience and information. These websites operate independently from CD and have their own privacy notices or policies. We recommend reviewing them if you visit any linked websites. CD is not responsible for the content, use, or privacy practices of third-party websites.

Applicable Law and Disputes Resolution

All rights and obligations and all actions contemplated by this Privacy Policy shall be governed by Swiss Data Protection Law and, to the extent applicable, the GDPR.

Any dispute related to your use of the Site, these Terms and Conditions, or the relationship between the Parties shall be subject to the exclusive jurisdiction of the courts of Lugano (Switzerland).

Updating of the Privacy Policy; Contact

CD may update this Privacy Policy at any time, without prior notice to Users. Users are asked to view the Privacy Policy accessible through the link “Privacy Policy” from time to time before accessing the Site.

If you have any questions regarding this Privacy Policy, please email us at: [email protected]