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Privacy policy

Information pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council

This Privacy Policy provides information regarding the processing of personal data (“Personal Data” or “Data”) of users of the official website of Sesto Elemento SA (“HDEX”), www.hdex.ch (“Site”)

1. Personal Data collected

Registration Data: These Data are requested during the Site’s registration phase, including using computerized tools and procedures.

Navigation and 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.

Cookies: Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. When you access to the Site, you will be automatically notified that about the types of cookies we collect an how to restrict or disable certain cookies (please access our Cookies Preference Center) . Please note, however, that without functional cookies you may not be able to use all of the features of our website. In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our site and the IP address of the device you use to connect to the Internet.

Navigation, browsing data and cookies are not collected to be associated with identified Data Subjects, however by the very nature they could, through processing and association with data held by third parties, allow Users to be identified.

2. Purpose of Personal Data Processing

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

(i) allowing the User to access the Site within the limits of the relevant Terms and Conditions of use, including in particular for the registration of an account;

(ii) responding to requests for information submitted by the User and in general giving execution to a specific User request;

(iii) giving execution to any online-sale of products sold in HDEX e-commerce portal, as initiated by the User

(iv) obtaining anonymous statistical information on the use of the Site and to ensure its correct functioning;

(v) subject to the User’s express consent (such consent being implicitly given with the registration of an account with HDEX), sending commercial communications, personalized offers and advertising on HDEX products and services;

3. Data Recipients

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

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

4. Data Controller and Data Controller Representative within EU

The Data Controller is Sesto Elemento SA, with registered office in Via Generale Guisan, 6 CH 6900 - Paradiso, Tel. +41 (0)91 2083145; Email: info@hdex.ch.

5. Periods of Data Retention

The Data processed to provide the site access and services will be kept by HDEX for the period deemed strictly necessary to fulfil such purposes. However, HDEX may continue to store these Data for a longer period, as may be necessary to protect the company’s interests related to potential liability related to the provision of its service.

Data processed for marketing purposes and/or for sending commercial communications and advertising on HDEX products and services will be kept by the company from the moment you give consent until the moment you withdraw the consent. Once consent is withdrawn, Data will no longer be used for these purposes, although they may still be kept by the Company, in particular as may be necessary to protect Company’s interests related to potential liability related to this processing unless further clarification are provided by the competent Supervisory Authority in this regard.

6. Rights of Data Subjects

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

•right to access, means the right to obtain from HDEX whether their Data are being processed and, where applicable, have access to them;

•right to rectification and right to erasure, means the right to obtain the rectification of inaccurate and/or incomplete Data, as well as the erasure of Data when the request is legitimate;

•right to restriction of processing, means the right to request suspension of the processing when the request is legitimate;

•right to data portability, means the right to obtain Data in a structured format, ordinary used and readable, as well as the right to transfer Data to other controllers;

•right to object, means the right to object to the processing of Data when the request is legitimate, including when the Data are processed for marketing or profiling, if applicable;

•right to lodge a complaint with a supervisory authority in case of unlawful processing of Data.

Data Subjects can exercise the abovementioned rights by writing to Sesto Elemento SA, with registered office in Via Generale Guisan, 6 CH 6900 - Paradiso, Tel. +41 (0)91 2083145; or sending an email to privacy@hdex.ch.

7. Links to third party websites

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

To the extent any linked websites you visit are not owned or controlled by HDEX, the latter is not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

8. Applicable Law and Disputes Resolution

Alle Rechte und Pflichten sowie alle in dieser Datenschutzerklärung vorgesehenen Maßnahmen unterliegen dem schweizerischen Datenschutzrecht und, soweit anwendbar, der DSGVO.

Any dispute relating in any way 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).

9. Updating of the Privacy Policy; Contact

HDEX may update this Privacy Policy at any time, without the Users being given prior notice.

Users are asked to view the Privacy Policy, accessible through the link “Privacy Policy”, from time to time, before accessing the Site. WIf you have any questions regarding this Privacy Policy, please email us at info@hdex.ch.

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