Privacy Policy GASSER PARTNER Attorneys-at-Law, Vaduz, as amended June 2018

Here at GASSER PARTNER we make the protection of your personal data our highest priority. Due to our professional duty to confidentiality, in every aspect of our work we are committed to the utmost secrecy. GASSER PARTNER processes your data in accordance with the statutory provisions of the European Data Protection Regulation (GDPR), including any national legislation, as amended.

In this privacy policy, pursuant to Article 12 ff. GDPR, we inform you about the collection of personal data and disclose both the purposes for which such data is processed and how you can exercise your rights under the GDPR.

 

A. Contact details of the data privacy manager pursuant to Article 4 para. 7 GDPR.

If you have any questions about this privacy policy or data protection at GASSER PARTNER Attorneys-at-law, please contact:

GASSER PARTNER Attorneys-at-Law
René Saurer
Wuhrstrasse 6
9490 Vaduz
Liechtenstein
Email: datenschutz@gasserpartner.com
Telephone: +423 236 30 80

 

B. Collection, processing and use of personal data

1. Which categories of personal data are collected?

We may collect the following categories of personal data about you:

(a) your name and contact information such as your home and / or business address, email address and telephone number;
(b) identity and biographical information including your nationality, date of birth, tax status, passport details and country of domicile, your employment and employment history, plus other information relevant to our provision of professional services;
(c) information regarding your financial situation such as income, expenditure, assets and liabilities, sources of wealth, your bank account details and other information necessary for processing payments and for fraud prevention purposes;
(d) to a limited degree, usage data relating to your viewing and accessing of our email marketing materials, and your marketing preferences (see Section C [Newsletters, the Website and Cookies] below).

2. How is that personal data collected?

We may collect your personal data, or you may provide it to us, by various means, sourced from information:

(a) you provide to us when we meet;
(b) provided by our own organization, agents, advisers, intermediaries or custodians of your assets;
(c) communicated by you to us by telephone, post, email or other forms of electronic communication;
(d) drawn from publicly available sources or from third parties, for example when we need to conduct background or due diligence checks (KYC) about you;
(e) collected when you view or access our Website (see section C [Newsletters, the Websites and cookies] below); and /or
(f) collected otherwise in the normal course of providing professional services.

3. What is the basis for processing your personal data and how do we use that personal data?

3.1 We may process your personal data for the following purposes:

(a) to provide a proposal to you in relation to the professional services we offer and for client engagement purposes (including carrying out background checks);
(b) to provide professional services to you (including legal research and associated advisory services);
(c) to manage our relationship with you (including billing and financial management) and for record-keeping purposes;
(d) any other purpose for which you provide us with your personal data;
(e) the purposes set out in Section C (Newsletters, the Website and Cookies) below;
(f) to exercise and defend our legal rights;
(g) to comply with our legal and regulatory obligations, such as the Due Diligence Act (DDA) and other anti-money laundering laws, data protection laws and tax reporting requirements, and / or to assist with investigations by the police and / or competent authorities (where such an investigation complies with the relevant laws) and to comply with court orders;
(h) to safeguard the security of our systems and communications; and /or
(i) for security purposes generally and to ensure the safety of our employees and visitors.

3.2 We may process your personal data for any of the purposes set out above where one (or more) of the following legitimate processing grounds applies:

(a) the processing is necessary to perform a contract with you;
(b) the processing is necessary for us to comply with our legal obligations;
(c) the processing is necessary for our legitimate interests (including business development, if you have not objected to the use of your data - see Section C (Newsletters, the Website and Cookies) below - unless those legitimate interests are overridden by your interests, fundamental rights or freedoms; and /or
(d) you have consented to the processing in question.

4. With whom may we share your data?

4.1 We may share your personal data with:

(a) your organization;
(b) third parties we engage to assist in providing our professional services, such as lawyers, IT and accounting firms and other consultants, public relations advisers, translators and / or couriers;
(c) intermediaries to whom we introduce you;
(d) third party service providers who provide business services to us, such as the providers of anti-money laundering services and background checks, for processing in accordance with our instructions;
(e) our banks and insurers, where appropriate;
(f) courts and other authorities, in connection with the enforcement of the defense of legal rights and the provision of our professional services.

5. How long we will retain your personal data?

5.1. We will retain your personal data for as long as is necessary to fulfil the purposes set out in the Privacy Notice.

5.2. In many cases this will mean that we shall retain your personal data for the same period as we retain your files or a copy of your files. Usually this will not be less than 10 years from the date that the relevant matter ended.

5.3. Longer retention periods may be appropriate, for example, to exercise or defend our legal rights. If there is no longer a legal reason for storing the data, we will delete personal data securely, or in some cases anonymize it.

 

C. Newsletters, the Website and Cookies

1. Newsletter

We may use your contact details to send you (by post or electronically) newsletters, event invitations and other mail promoting our services. We do this on the basis of our legitimate interests or your consent (as appropriate to the communication in question). You can always unsubscribe from these mailings by contacting us at datenschutz@gasserpartner.com.

2. Website

During purely informational visits to our website, during which you neither register nor otherwise send us information, we do not collect any personal data. However, it is possible that the hosting provider (NetZone AG) stores and processes the following personal data in the background, which is sent to our server by your browser.

This data is technically necessary to show you our website and to ensure site viewing stability and security (legal basis Article 6 para. 1 S. 1 (f) GDPR):

  • IP Address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/http-status code
  • Quantity of data transferred in each case
  • Website from which the request originates
  • Browser
  • Operating system and its interface
  • Language and version of the browser software

If errors occur on the main page, the hosting provider stores them for 7 days in ‘error logs’ with the date, IP address, page and type of error.

3. Cookies

In addition to the above data, cookies are stored on your computer each time you use our website. Cookies are small text files that are stored on your hard disk in the browser you use and through which certain information flows to the place that sets the cookie ( in this case, us). Cookies cannot run programs or infect your computer. They do not cause any damage and render our website more user-friendly and efficient.

3.1. Use of cookies:

a) Our website uses the following types of cookies, whose scope and operation are explained hereinafter:

  • Transient cookies (b)
  • Persistent cookies (c)

b) Transient cookies are deleted automatically when you close your browser. These include session cookies. These store a so-called session ID, with which different browser requests can be assigned to the common session. This allows your computer to be recognized each time you return to our website. Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified duration, which may differ depending on the cookie. For us, this is 24 days. You can delete the cookies at any time in your browser security settings.
d) You can configure your browser settings as you wish, for example declining the acceptance of third party cookies or all cookies. However, in doing so you may not be able to use all functions of this website.

3.2. Google Maps

Our website uses Google Maps to display interactive maps and to create directions.

By using this website, you consent to the collection, processing and use of data collected automatically and via your input, by Google, one of its representatives, or third-party providers.

Information on third party providers: Google Maps is operated by Google Inc., 1600

Amphitheatre Parkway, Mountain View, CA 94043, USA. The terms and conditions for the use of Google Maps can be found at: https://www.google.com/intl/de de/help/terms maps.html. Detailed information is available in the Data Protection Center of google.de, with transparency and choice plus data protection regulations at: https://policies.google.com/privacy?hl=de&gl=de.

We use Google Maps to show you our locations and give you the opportunity to plan your journey. In exceptional cases, where personal data is transferred to the USA, Google must comply with the EU-US Privacy Shield: https://www.privacy-shield.gov/EU-

US-Framework.

4. Additional features and offers on our website

In addition to the purely informative use of our website we offer a variety of services designed to help you, if you are interested. To do this, you generally need to provide further personal information which we use to provide the relevant services, and to which apply the following data processing principles.

If we use service providers for individual features in our offer or want to use your data for advertising purposes, we will inform you in detail about the procedures below. We will also specify the defined criteria for storage duration.

5. Contact us

Should you contact us using the online form on our website or by email (office@gasserpartner.com) the information you provide (name, address and/or email address) will be saved for processing the request and for follow-up questions or until you revoke consent. CSL Corporate Services, our IT provider, stores in logs GASSER PARTNER Attorneys-at-law recipient/sender email addresses.

The resulting data will be deleted once the storage is no longer required, or we will restrict its processing should there be statutory retention obligations.

6. Employment application

In addition to contacting us, you can also apply via our website and send us your application documents. The data can be sent to us by email and will be stored by us for appropriate processing and kept either until follow-up questions have been dealt with, or until your revocation.

The resulting data will be deleted once the storage is no longer required, or we will restrict its processing should there be statutory retention obligations.

No liability is accepted for any data stored and collected by your email provider.

 

D. Your Rights

1. You have the following rights regarding your personal data:

  • Right to information,
  • Right to rectification or deletion,
  • Right to restriction of processing,
  • Right to object to its processing,
  • Right to data portability.

2. If you have consented to the processing of your data, you can revoke this at any time.

The revocation can be sent informally to the address of GASSER PARTNER Attorneys-at- law, Wuhrstrasse 6, 9490 Vaduz, Liechtenstein or by email to datenschutz@gasserpartner.com.

3. To the extent that we seek to balance all interests in the processing of your personal data, you have the right to object to its processing. This is the case notably if the processing is not required for the performance of a contract with you, instances of which we have described hereinafter. When you file an objection, please explain why you do not wish us to process your personal data. If your opposition is justified, we will examine the situation and either cease or adjust the data processing or provide you with our overriding legitimate reasons for continuing the processing.

 

4. If you believe that the processing of your data infringes existing data protection laws or violates your data protection rights in any way, you have the right to complain to the supervisory authority. For Liechtenstein, this is:

The Data Protection Agency
Städtle 38
9490 Vaduz
Liechtenstein

 

E. Data security

We have taken appropriate technical and organizational precautions to protect your data from unauthorized illegal or accidental access, processing, use, manipulation, loss or destruction.

Despite all our efforts, we cannot rule out the possibility that information you send us via the internet might be viewed and used by other people. Please note in particular that unencrypted emails sent over the internet are insufficiently protected against unauthorized access by third parties. We therefore recommend you send confidential information by post.

 

F. External Links

Our website contains links to other sites. We do not accept any liability for external links, notwithstanding careful content monitoring, as we have no control over the content and operation of third party websites.

 

G. Changes to the Privacy Policy

In the event of any changes in the legal situation or to services, products or user services, we will update the privacy policy accordingly. If the changes also affect user consent, changes will only be made with the users’ prior consent.