In this data protection declaration, we, Wipolero Treuhand AG (hereinafter referred to as Wipolero, we or us), describe how we collect and process personal data. This data protection declaration is not an exhaustive description; other declarations relating to data protection may regulate specific matters. For the purposes of this data protection declaration, personal data means all information that relates to a specific or identifiable person.

Wipolero Treuhand AG is responsible for the data processing described here, unless otherwise stated in individual cases. Data protection enquiries can be sent to us by letter or e-mail, enclosing a copy of the user's ID or passport for identification purposes:

Wipolero Treuhand AG / Bösch 71 / P.O. Box / 6331 Hünenberg / Switzerland /
Tel: +41 (0)41 790 44 33 / info@wipolero.ch 

We process personal data in the following categories of processing in particular.

• Customer data of customers for whom we provide or have provided services.
• Personal data that we have received indirectly from our clients in the course of providing the service.
• When visiting our website
• When using our newsletter
• When participating in an event organised by us.
• When we communicate or a visit takes place.
• In the case of other contractual relationships, e.g. as a supplier, service provider or consultant.
• For applications
• If we are required to do so for legal or regulatory reasons.
• Where we are carrying out our due diligence or other legitimate interests, for example to avoid conflicts of interest, prevent money laundering or other risks, ensure data accuracy, check creditworthiness, ensure security or enforce our rights.

More detailed information can be found in the description of the respective categories of processing in point 4.

The personal data we process depends on your relationship with us and the purpose for which we process it. In addition to your contact details, we also process other information about you or about people who have a relationship with you. This information may also be sensitive personal data.

 We collect the following categories of personal data, depending on the purpose for which we process it:

·       Contact information (e.g. surname, first name, address, telephone number, e-mail)

·       Customer information (e.g. date of birth, nationality, marital status, profession, title, job title, passport / ID number, AHV number)

·       Risk assessment data (e.g. credit rating information, commercial register data)

·       Financial information (e.g. data on bank details)

·       Mandate data, depending on the mandate (e.g. tax information, articles of association, minutes, projects, contracts, employee data (e.g. salary, social security), accounting data, beneficial owners, ownership)

·       Website data (e.g. IP address, device information, browser information, website usage (analysis and use of plugins, etc.)

·       Application data (e.g. CV, references)

·       Marketing information (e.g. newsletter registration)

·       Security and network data (e.g. visitor lists, access controls, network and mail scanners, telephone call lists)

To the extent permitted, we also take certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, internet) or receive such data from our clients and their employees, from authorities, (arbitration) courts and other third parties. In addition to the data about you that you give us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities (so that we can, for example (e.g. so that we can conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information, information about you provided to us by people close to you (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or involving you (e.g. references, your address for deliveries, full addresses, etc.). References, your address for deliveries, powers of attorney) Information on compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the utilization or provision of services by you (e.g. payments made, purchases made), information from the media and Internet on your person (insofar as this is indicated in the specific case, e.g. in the context of a job application etc.).Your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, details of your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location details).

4.1. Provision of services

We primarily process the personal data that we receive from our clients and other business partners in the course of our client relationships and other contractual relationships with them and other persons involved in them.

The personal data of our customers is in particular the following information:

• Contact information (e.g. surname, first name, address, telephone number, e-mail, other contact information)
• Personal information (e.g. date of birth, nationality, marital status, profession, title, job title, passport / ID number, AHV number, family circumstances, etc.).
• Risk assessment data (e.g. credit rating information, commercial register data, sanctions lists, specialised databases, data from the internet)
• Financial information (e.g. data on bank accounts, investments or shareholdings)
• Mandate data, depending on the mandate, e.g. tax information, articles of association, minutes, employee data (e.g. salary, social insurance), accounting data, etc.
• Particularly sensitive personal data: This personal data may also include sensitive personal data, such as data relating to health, religious beliefs or social assistance measures, particularly if we provide payroll processing or accounting services.

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Conclusion or execution of a contract with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement (e.g. advice, fiduciary services)
• Fulfilment of a legal obligation (e.g. when we perform our duties as tax advisors or are obliged to disclose information).
• Safeguarding legitimate interests, (e.g. for administrative purposes, to improve our quality, ensure safety, manage risk, enforce our rights, defend ourselves against claims or to check for possible conflicts of interest).

Consent (e.g. to send them marketing information).
 

4.2. Indirect data processing from service provision

When we provide services to our clients, we may also process personal data that we have not collected directly from the data subjects or personal data from third parties. These third parties are usually employees, contacts, family members or persons who have a relationship with the clients or data subjects for other reasons. We need this personal data to fulfil contracts with our clients. We receive this personal data from our clients or from third parties engaged by our clients. Third parties whose information we process for this purpose will be informed by our clients that we are processing their data. Our clients may refer to this privacy policy for this purpose.

The personal data of the persons who have a relationship with our customers is in particular the following information:

• Contact information (e.g. surname, first name, address, telephone number, e-mail, other contact information, marketing data)
• Personal information (e.g. date of birth, nationality, marital status, profession, title, job title, passport / ID number, AHV number, family circumstances, etc.).
• Financial information (e.g. data on bank accounts, investments or shareholdings)
• Mandate data, depending on the mandate e.g. tax information, statutes, minutes, employee data (e.g. salary, social insurance), accounting data
• Particularly sensitive personal data: This personal data may also include sensitive personal data, such as data relating to health, religious beliefs or social assistance measures, particularly if we provide payroll processing or accounting services.

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Conclusion or execution of a contract with or for the benefit of the data subject (e.g. when we perform our contractual obligations)
• Fulfilment of a legal obligation (e.g. if we perform our duties as tax advisors or are obliged to disclose information).
• Safeguarding legitimate interests, in particular our interest in providing optimum service to our customers.

4.3. Use of our website

No personal data need to be disclosed in order to use our website. However, the server collects a range of user information with each call, which is temporarily stored in the server's log files.

When using this general information, no allocation to a specific person takes place. The collection of this information or data is technically necessary to display our website and to ensure its stability and security. This information is also collected to improve the website and to analyse its use.

This is in particular the following information:

• Contact information (e.g. surname, first name, address, telephone number, e-mail)
• Other information that you submit to us via the website
• Technical information automatically transmitted to us or our service providers, information on user behaviour or website settings (e.g. IP address, device type, browser, number of clicks on the page, opening of the newsletter, click on links, etc.), and information on the website.

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Safeguarding legitimate interests, (e.g. for administrative purposes, to improve our quality, analyse data or publicise our services).
• Consent (e.g. to the use of cookies or the newsletter).

4.4. Participation in events

If you attend an event organised by us, we collect personal data in order to organise and run the event and, if necessary, to send you additional information afterwards. We also use your information to inform you of other events. It is possible that you will be photographed or filmed by us at these events and that we will publish this footage internally or externally.

 This involves the following information in particular:

• Contact information (e.g. surname, first name, address, telephone number, e-mail)
• Personal information (e.g. profession, function, title, employer company, eating habits)
• Pictures or videos
• Payment information (e.g. bank details).

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Fulfilment of a contractual obligation with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement (enabling participation in the event)
• Safeguarding legitimate interests (e.g. holding events, disseminating information about our event, providing services, efficient organisation).
• Consent (e.g. to send them marketing information or to create visual material).

4.5. Direct communication and visits

When you contact us (e.g. by phone, email or chat) or when we contact you, we process the necessary personal data. We also process this personal data when you visit us. In this case, you may be required to leave your contact details before visiting us or at reception. We keep this information for a certain period of time to protect our infrastructure and information.

We use the "Zoom" or "Microsoft Teams" service to conduct telephone conferences, online meetings, video conferences and/or webinars ("online meetings"). We process the following information in particular:

• Contact information (e.g. surname, first name, address, telephone number, e-mail)
• Marginal data on communication (e.g. IP address, duration of communication, communication channel)
• Recordings of conversations, e.g. during video conferences
• Other information uploaded, provided or created by the user during the use of the video conferencing service, as well as metadata used for the maintenance of the service provided Additional information on the processing of personal data by "Zoom" or Microsoft Teams can be found in their privacy statements.
• Personal information (e.g. profession, function, title, employer company)
• Time and reason for the visit.
   

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Fulfilment of a contractual obligation with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement (provision of a service)
• Safeguarding legitimate interests (e.g. security, traceability and processing and administration of customer relationships).

4.6. Applications

You can submit your application for a position with us by post or via the e-mail address provided on our website. The application dossier and all personal data disclosed to us in connection with it will be treated in strict confidence, will not be disclosed to any third party and will only be processed for the purpose of processing your application for employment with us. Without your consent to the contrary, your application file will either be returned to you or deleted/destroyed after the application process has been completed, unless it is subject to a legal obligation to retain it. The legal basis for processing your data is your consent, the fulfilment of the contract with you and our legitimate interests.

In particular, we process the following information:

• Contact information (e.g. surname, first name, address, telephone number, e-mail)
• Personal information (e.g. profession, function, title, employer company)
• Application documents (e.g. letter of motivation, certificates, diplomas, CV)
• Assessment information (e.g. assessment of personnel consultants, reference information, assessments)

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Safeguarding legitimate interests (e.g. hiring new employees)
• Consent.

4.7. Suppliers, service providers, other contractual partners

When we enter into a contract with you to provide a service for us, we process personal data about you or your employees. We need this data to communicate with you and to use your services. We may also process this personal data in order to check whether there could be a conflict of interest in connection with our work as tax advisors and to ensure that we do not enter into any unwanted risks, e.g. with regard to money laundering or sanctions, when working with you.

 We process the following information in particular:

• Contact information (e.g. surname, first name, address, telephone number, e-mail).
• Personal information (e.g. profession, function, title, employer company).
• Financial information (e.g. data on bank details).

We process this personal data for the purposes described above on the basis of the following legal grounds:

• Conclusion or execution of a contract with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement

 Safeguarding legitimate interests, (e.g. avoiding conflicts of interest, protecting the company, enforcing legal claims).
 

We use cookies on our website. These are small files that are automatically created by your browser and stored on your end device (laptop, tablet, smartphone or similar) when you visit our site.

Information is stored in the cookie that arises in connection with the specific end device used. However, this does not mean that we gain direct knowledge of your identity. The use of cookies serves, on the one hand, to make the use of our offer more pleasant for you. We use so-called session cookies to recognise that you have already visited individual pages of our website. These are automatically deleted after you leave our site.

In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again in order to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you. These cookies enable us to automatically recognise that you have already been to our website when you visit it again. These cookies are automatically deleted after a defined period of time.

The data processed by cookies are necessary for the purposes mentioned. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a notice always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website.
 

We use the following web analysis tools and re-targeting technologies in order to obtain information about the use of our website, to improve our internet offer and to be able to address you with advertising on third-party websites or on social media: Google Analytics,

These tools are provided by third-party providers. As a rule, the information collected for this purpose about the use of a website is transmitted to the third-party provider's server through the use of cookies or similar technologies. Depending on the third-party provider, these servers may be located abroad.

 The transmission of the data normally takes place with shortening of the IP addresses, which prevents the identification of individual end devices. A transmission of this information by third-party providers only takes place due to legal regulations or in the context of order data processing.
 

6.1. Google Analytics

We use Google Analytics, the web analytics service of Google LLC, Mountain View, California, USA, responsible for Europe is Google Limited Ireland ("Google") on our websites. To deactivate Google Analytiscs, Google provides a browser plug-in at https://tools.google.com/dlpage/gaoptout?hl=de. Google Analytics uses cookies. These are small text files that make it possible to store specific information related to the user on the user's terminal device. These enable an analysis of the use of our website by Google. The information collected by the cookie about the use of our website (including your IP address) is usually transferred to a Google server in the USA and stored there. We would like to point out that on this website Google Analytics has been extended by the code "gat._anonymizeIp();" in order to ensure anonymised collection of IP addresses (so-called IP masking). If anonymisation is active, Google shortens IP addresses within member states of the European Union or in other contracting states of the Agreement on the European Economic Area, which is why no conclusions can be drawn about your identity. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google may associate your IP address with other Google data. For data transfers to the USA, Google has undertaken to sign and comply with the EU standard contractual clauses.

6.2. Google Maps

On our website we use Google Maps (API) from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; responsible for Europe is Google Limited Ireland, "Google"). Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. By using this service, our location is shown to you and a possible approach is made easier. When you call up those sub-pages in which the Google Maps map is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. This occurs regardless of whether Google provides a user account via which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not wish your data to be associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them.

 For data transfers to the USA, Google has undertaken to sign and comply with the EU standard contractual clauses. 

6.3. Social Media Plugins

So-called social media plugins ("plugins") from third-party providers are used on our website. The plugins are recognisable by the logo of the respective social network. Via the plugins, we offer you the opportunity to interact with the social networks and other users. We use the following plugins on our website: Facebook, Twitter, LinkedIn, YouTube. When you call up our website, your browser establishes a direct connection to the servers of the third-party provider. The content of the plugin (e.g. YouTube videos) is transmitted directly to your browser by the respective third-party provider and integrated into the page.

 The data transfer for the display of content (e.g. publications on Twitter) takes place regardless of whether you have an account with the third-party provider and are logged in there. If you are logged in to the third-party provider, your data collected by us will also be directly assigned to your account with the third-party provider. If you activate the plugins, the information will also be published on the social network and displayed to your contacts there. The purpose and scope of the data collection and the further processing and use of the data by the third-party providers as well as your rights in this regard and setting options for protecting your privacy can be found in the data protection information of the third-party providers. The third-party provider stores the data collected about you as a usage profile and uses this for the purposes of advertising, market research and/or designing its website to meet your needs. In particular, such an evaluation is also carried out for non-logged-in users for the display of needs-based advertising and to inform other users of the social network about your activities on our website. If you would like to prevent the third-party providers from assigning the data collected via our website to your personal profile in the respective social network, you must log out of the respective social network before visiting our website. You can also completely prevent the loading of the plugins with specialised add-ons for your browser such as "Ghostery" (https://www.ghostery.com/) or "NoScript" (http://noscript.net/)

 

We will only disclose your data to third parties if this is necessary to provide our service, if these third parties provide a service for us, if we are obliged to do so by law or by the authorities or if we have an overriding interest in disclosing the personal data. We will also disclose personal data to third parties if you have given your consent or requested us to do so.

Not all personal data is transmitted encrypted as standard. Unless explicitly agreed otherwise with the client, accounting data, salary administration data, salary slips and salary statements are transmitted unencrypted.

 The following categories of recipients may receive personal data from us:

• Branches, subsidiaries or affiliates.
• Service providers (e.g. IT service providers, hosting providers, suppliers, consultants, lawyers, insurance companies).
• Third parties within the scope of our legal or contractual obligations, authorities, state institutions, courts.

We conclude contracts with service providers who process personal data on our behalf, obliging them to ensure data protection. The majority of our service providers are located in Switzerland or in the EU / EEA. Certain personal data may also be transferred to the USA (e.g. Google Analytics data) or, in exceptional cases, to other countries worldwide. Should a data transfer to other countries that do not have an adequate level of data protection be necessary, this will take place on the basis of the EU standard contractual clauses (e.g. in the case of Google) or other suitable instruments).

We process and store your personal data for as long as it is necessary for the fulfilment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the time during which claims can be asserted against our company (i.e. in particular during the statutory limitation period) and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as a matter of principle and as far as possible. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less apply in principle.

We take appropriate technical and organisational security measures to protect your personal data from unauthorised access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymisation and controls.

In the context of our business relationship, you must provide such personal data as is necessary for the establishment and performance of a business relationship and the fulfilment of the associated contractual obligations (you do not generally have a legal obligation to provide us with data). Without this data, we will not be able to enter into or perform a contract with you (or the entity or person you represent). Also, the website cannot be used if certain information to secure traffic (such as IP address) is not disclosed.

You have the following rights in relation to our processing of personal data:

• Right to information about personal data stored by us about you, the purpose of processing, the origin and about recipients or categories of recipients to whom personal data is passed on.
• Right to rectification if your data is incorrect or incomplete.
• Right to restrict the processing of your personal data
• Right to request the deletion of the personal data processed
• Right to data portability
• Right to object to data processing or to withdraw consent to the processing of personal data at any time without giving reasons.
• Right to complain to a competent supervisory authority, where provided for by law.

To exercise these rights, please contact the address given in section 1.

Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to rely on this) or require it for the assertion of claims. If you incur costs, we will inform you in advance.
 

We expressly reserve the right to change this privacy policy at any time.
Last change: August 2023

This Privacy Policy is drawn up in German and English. For any interpretations and definitions, only the German version shall apply.