Scope
This policy covers the www.familylegacy.tech website: the presentation of the project, the waiting list and the contact, demonstration request and booking forms.
The platform, available at app.familylegacy.tech, is governed by its own privacy policy: app.familylegacy.tech/confidentialite
Article 1 – Data controller
The controller of the personal data collected via the Site is:
FamilyLegacy Sàrl, Route de Flumeaux 48, 1008 Prilly, Switzerland · dpo@familylegacy.tech
Article 2 – Applicable legal framework
Data processing is carried out in accordance with:
- The revised Swiss Federal Act on Data Protection (FADP);
- Regulation (EU) 2016/679 (GDPR), where applicable.
Article 3 – Categories of data collected
Within the scope of the Site, the waiting list and the forms, the categories of data likely to be collected include in particular:
- Email address;
- Name, role and phone number, where the form asks for them;
- The content of a message sent through a form;
- IP address and technical browsing data.
Article 4 – Purposes of processing
Personal data is processed for the following purposes:
- Managing the waiting list;
- Communication regarding the platform launch;
- Sending marketing information related to FamilyLegacy’s activities;
- Technical and security improvement of the Site.
Article 5 – Legal basis for processing
Processing is based on:
- The explicit consent of the data subject (Art. 6(1)(a) GDPR);
- FamilyLegacy Sàrl’s legitimate interest in developing and improving its services.
Consent may be withdrawn at any time.
Article 6 – Retention period
Data is retained:
- For the waiting list: a maximum of 24 months in the absence of interaction;
- For marketing communications: until consent is withdrawn;
- For technical data: in accordance with the legal obligations applicable in Switzerland.
Article 7 – Processors
FamilyLegacy Sàrl uses the following processors:
- Website hosting: Infomaniak Network SA, Switzerland;
- Email delivery and contact management: Brevo, France;
- Platform hosting: Exoscale, Geneva, Switzerland.
These providers are contractually required to ensure an adequate level of data protection. The Site uses no audience measurement tool and no non-essential tracker.
Article 8 – International transfers
Data collected through the Site is processed in Switzerland and in the European Union (Brevo, France). No data is transferred to the United States.
Where a transfer outside Switzerland takes place, it relies on Switzerland's recognition of an adequate level of protection within the European Economic Area and, where necessary, on the Standard Contractual Clauses adopted by the European Commission.
Article 9 – Security
FamilyLegacy Sàrl implements appropriate technical and organisational measures in accordance with Art. 32 GDPR and the revised Swiss FADP.
Wealth and family data entered in the platform is hosted in Switzerland (Exoscale, Geneva) and protected by encryption mechanisms compliant with prevailing industry standards. It is governed by the platform privacy policy.
As no IT system can guarantee absolute security, FamilyLegacy Sàrl cannot rule out all residual risk.
Article 10 – Rights of data subjects
Every data subject has the following rights:
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to object;
- Right to restriction of processing;
- Right to data portability where applicable.
Requests may be sent to dpo@familylegacy.tech.