PRIVACY POLICY

Anafyo Sagl (from now on, defined as “ANAFYO”) is a company that performs consultancy for AEC regarding the BIM methodology implementation, development, management and coordination of the BIM oriented processes, O&M project modelling or CDE configuration and starting. It assists and supports companies to prepare BIM tenders, to develop their team skills through customized trainings.

ANAFYO carries out the current personal data processing under the Federal Law on the data protection (LPD) and EU Regulation UE 679/2016, the principles of correctness, legality, transparency, purpose limitation and conservation, minimization, accuracy, protection of integrity and confidentiality.

1      The Data Controller

The Data Controller is Anafyo Sagl.

To request further information on the personal data processing or to exercise their rights, the User can contact us as follows:

2      What is a personal data and what is a processing?

Personal data is information that identifies or can identify, directly or indirectly, a natural person and that can provide information about his characteristics, habits, personal relationships, etc. Personal data, but not limited to name, surname, address or other contact details, an identification number or an online identifier are considered personal data.

A processing is any operation carried out with or without the aid of automated processes and applied to personal data. The following are considered processing, by way of example but not limited to the collection, registration, organization, storage, modification, consultation, cancellation, or destruction of data.

3      What are the personal data being processed?

We inform the User’s personal data being processed may consist of an identifier such as a name, a password, location data, or one or more elements characteristic of the physical, economic, cultural, or social identity of the User.

In particular, the data processed are as follows:

1. Browsing Data

The computer 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. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful,  error, etc.) and other parameters relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site to check the proper functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to establish responsibility in case of hypothetical computer crimes against the Data Controller or third parties.

1. Data provided by the User – Contact Area – Write us a message

The User’s data are collected by the Data Controller when filling out a form (from now on defined as “form”). The form requires to insert the following personal data: name, surname, telephone, e-mail.

4      Processing Purposes

The User’s personal data will be processed for the following purposes:

• Respond to an information requested by the User.
• To sign a contract for services provided by ANAFYO.
• Fulfil contractual, pre-contractual, administrative and tax obligations deriving from the relationship between the User and ANAFYO.
• Fulfil obligations established by law, by a regulation, and satisfy the requests coming from the competent Authority.

5      Legal basis of user’s data processing

Each processing is justified by one of the following legal conditions:

• The processing is necessary to execute the contract in place between the parties. In this case, the provision of personal data is optional, but its absence makes it impossible to conclude the contract and to execute the requested service.
• The processing is necessary to comply with a legal obligation. In this case, the provision of data is mandatory, and its absence makes it impossible to conclude the contract and to execute the requested service.
• The processing is necessary for the pursuit of the legitimate interest of the Data Controller, provided that the interests or fundamental rights and freedoms of the User that require the protection of personal data do not prevail. In this case, the provision of data is optional.

6      How ANAFYO discloses Personal Data?

As part of ANAFYO’s activity and for the purposes specified above, the User’s personal data may be shared with:

• Duly appointed Data Processors, who provide specific processing or ancillary services on behalf of the Data Controller and under your instructions (e.g., Web hosting, system administrators).
• Independent Data Controllers to whom the data may be communicated by virtue of legal provisions or orders of the Authorities, or e.g., to execute payments (Banks); to allow the Data Controller to exercise their rights (law firm); etc.
• Subjects authorized by the Data Controller to process the personal data necessary for the performance of activities strictly related to the provision of services and who have assumed an appropriate legal and contractual obligation of confidentiality (e.g., employees and / or collaborators of the Data Controller).

We do not sell or otherwise disclose your personal data to third parties.

7      What are ANAFYO’s storage practices?

All personal data is stored electronically on servers located in UE.

The Data Controller, if necessary, will have the right to transfer the data even outside UE. In this case, the Data Controller hereby ensures that the transfer of data outside UE will take place in accordance with the applicable legal provisions.

8      What are ANAFYO’s data retention practices?

In compliance with the principles of lawfulness, purpose limitation and data minimization, pursuant to Article 6 of the LPD and Article 5 of the GDPR, the retention period of the User’s personal data is established for a period necessary for the performance of the requested services and in compliance with current regulations regarding the conservation of tax, and contractual documentation.

9      What are Users rights?

The User may request, at any time, confirmation as to whether his personal data is being processed, and in relation to them he has the right to:

• request access to the data to obtain information on the purposes pursued with the processing, on the recipients to whom the data may be communicated, the duration of the processing (where applicable) and the possible consequences of a processing based on profiling.
• revoke the consent at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
• request the correction of personal data if they are inaccurate or incomplete.
• request the cancellation of the data if they are no longer necessary for the Data Controller for the purposes of the processing envisaged, are inadequate with respect to the purposes of the processing, the User has revoked his consent, or the data have been processed unlawfully.
• request the limitation of data processing, in the cases provided for by the law.
• request the transfer of data to another Data Controller, in a commonly used format readable by a computer device, without hindrance from the current Data Controller.
• oppose the processing of your data and, specifically, you have the right to oppose decisions that concern you if based solely on automated processing of your data, including profiling.
• complain to the competent Authority, if it considers that the processing concerning you violates current legislation on data protection.

To exercise your rights, you can use the contact details provided in paragraph 1 or access the website of the Federal Data Protection and Information Commissioner http://www.edoeb.admin.ch

10   Automated decision-making process

The User is not subject to decisions based on automated processing.

11   Changes

ANAFYO reserves the right to modify or simply update the content of this Privacy Policy, in part or completely, also due to changes in the applicable legislation. Such changes will be binding as soon as they are published on the Site and/or in the Application. If the User continues to access or use the service after such publication, it is assumed that he has expressly accepted such changes. ANAFYO therefore invites the User to visit with regularity this section to take cognizance of the most recent and updated version of the Privacy Policy to be always updated on the data collected and on the use that ANAFYO makes of it.