Data Protection

This Privacy Policy explains how Argo Consilium AG, 8712 Stäfa, and Argo Consilium AG, 8032 Zurich (hereinafter referred to as ARGO), collect and process personal data.

For the purposes of this Privacy Policy, “personal data” refers to all information that relates to an identified or identifiable natural person (hereinafter referred to as personal data or data).

“Processing” refers to any handling of personal data, including, in particular, the collection, storage, use, disclosure, and deletion of such data.

This Privacy Policy is not an exhaustive description; other privacy-related notices may govern specific matters.

Unless otherwise specified in individual cases, ARGO is responsible for the data processing activities described in this Privacy Policy. Data protection inquiries can be submitted to us by letter or email, including a copy of an ID or passport for user identification:

Argo Consilium AG, Klosbachstrasse 2, CH-8032 Zürich, info@argoconsilium.ch

We process personal data particularly in the following categories of processing:

• Customer data of clients for whom we provide or have provided services
• Personal data that we do not receive directly from you in the course of providing services, but from our clients or third parties
• When visiting our website https://www.argoconsilium.ch
• When using our newsletter and participating in marketing activities
• When attending one of our events
• During communication (in person, by email, letter, SMS, social media, etc.)
• During job applications
• In the context of any other contractual relationship (e.g. as a service provider, supplier, or other contractual partner)
• When we are required to do so by legal or regulatory obligations
• When we exercise our duties of care or other legitimate interests, such as avoiding conflicts of interest, preventing money laundering or other risks, ensuring data accuracy, assessing creditworthiness, ensuring security, or enforcing our rights

A detailed description of the personal data we process and further information can be found in section 5 of this Privacy Policy.

Depending on the purpose of processing, client segment, and areas of service, we collect various types of personal data (see section 3), which may in some cases include particularly sensitive personal data. In addition to your personal data, we may also process other information about you or about individuals who are connected to you.

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

• Contact Information
  e.g., name, first name, address, phone number, email, social media
• Personal Information
  e.g., date of birth, nationality, residence permit, marital status, profession, job title, passport/ID number, social security number (AHV), family relationship
• Risk Assessment Data
  e.g., credit information, commercial register data
• Financial Information
  e.g., bank account details
• Mandate Data (depending on the engagement)
  e.g., accounting data, tax data, employee data, articles of association, meeting minutes, contracts, project data, beneficial owners, ownership structures
• Website Data
  e.g., IP address, device information (UDI), browser information, website usage, etc.
• Application Data
  e.g., CV, employment references, qualifications
• Marketing Information
  e.g., newsletter subscription
• Security and Network Data
  e.g., visitor lists, access controls, network and email scanners, call logs

More detailed information can be found in the descriptions of the respective categories of processing (see section 5).

Where permitted, we also obtain certain data from publicly available sources (e.g., debt enforcement registers, land registries, commercial registers, press, internet) or receive such data from our clients and their employees, authorities, (arbitral) courts, and other third parties. In addition to data that you provide directly, the categories of personal data we receive from third parties about you include in particular:

• Information from public registers

• Information we obtain in connection with administrative and legal proceedings

• Information related to your professional roles and activities (e.g., so we can do business with your employer)

• Information about you provided in correspondence and discussions with third parties

• Credit ratings

• Information provided by people close to you (e.g., family members, advisors, legal representatives), so that we can enter into or process contracts with or involving you (e.g., references, delivery addresses, powers of attorney)

• Information to ensure legal compliance, such as anti-money laundering or export control requirements

• Information from banks, insurers, distributors, and other contractual partners regarding your use of or entitlement to services (e.g., payments made, purchases made)

• Information about you from media and online sources (where appropriate, e.g., in the context of job applications)

• Your address and, if applicable, your interests and other sociodemographic data (for marketing purposes)

• Data related to your use of our website (e.g., IP address, MAC address of your smartphone or computer, device and settings details, cookies, date and time of visit, pages and content accessed, features used, referring website, location information)

When providing services to our clients, we may also process personal data that we have not collected directly from the data subjects or personal data of third parties. These third parties are usually employees, family members, or individuals who have a relationship with the clients or data subjects for other reasons. We require this personal data in order to fulfill contracts with our clients. We receive this personal data from our clients or from third parties appointed by our clients. Third parties whose information we process for this purpose are informed by our clients that their data is being processed. Our clients may refer these individuals to this Privacy Policy.

The personal data of individuals who have a relationship with our clients typically includes the following information:

• Contact Information
  e.g., name, first name, address, telephone number, email, social media

• Personal Information
  e.g., date of birth, nationality, residence permit, marital status, profession, academic or professional title, job title, passport/ID number, social security number (AHV), family relationships, etc.

• Financial Information
  e.g., bank account details, investments or shareholdings

• Mandate Data (depending on the engagement)
  e.g., accounting data, tax data, employee data (e.g., salary, social insurance), articles of association, meeting minutes, contracts, project data, beneficial owners, ownership structures, etc.

• Particularly Sensitive Personal Data
  This may include particularly sensitive personal data such as health information, religious beliefs, or data related to social assistance measures—especially when we provide services in the areas of tax consulting, payroll processing, or accounting.

We process these personal data for the purposes described based on the following legal grounds:

• Conclusion or performance of a contract with the data subject or for the benefit of the data subject (e.g., when fulfilling our contractual obligations)

• Compliance with a legal obligation (e.g., when fulfilling our duties as auditors or when required to disclose information)

• Legitimate interests, in particular our interest in providing optimal services to our clients

Using our website does not require the disclosure of personal data. However, the server automatically collects a range of user information with each access, which is temporarily stored in the server’s log files.

The use of this general information does not involve any assignment to a specific individual. Collecting this information is technically necessary to display our website and to ensure its stability and security. This data is also collected to improve the website and analyze its usage.

This particularly includes the following information:

• Contact Information
  e.g., name, first name, address, telephone number, email

• Additional Information you provide to us via the website

• Technical information automatically transmitted to us or our service providers, as well as information about user behavior or website settings
  e.g., IP address, UDI, device type, browser type and version, number of clicks on the page, newsletter opens, link clicks, etc.

We process these personal data for the purposes described based on the following legal grounds:

• Legitimate interests (e.g., for administrative purposes, to improve our quality, analyze data, or promote our services)

• Consent (e.g., consent to the use of cookies)

Depending on the services we provide to you, we may inform you about relevant announcements and developments through our fiduciary newsletter. If you receive our newsletter, we use your contact information to send it to you. You can unsubscribe from the newsletter at any time by contacting info@argoconsilium.ch

If you attend an event organized by us, we collect personal data in order to organize and carry out the event and, if necessary, to send you additional information afterward. We also use your information to inform you about future events.
Please note that you may be photographed or filmed during these events, and we may use such images or recordings for internal or external publication.

This includes, in particular, the following information:

• Contact Information
  e.g., name, first name, address, telephone number, email

• Personal Information
  e.g., profession, job title, position, employer

• Images or Videos

• Payment Information
  e.g., bank account details

We process these personal data for the purposes described based on the following legal grounds:

• Performance of a contract with the data subject or for the benefit of the data subject, including contract initiation and potential enforcement (e.g., enabling participation in the event)

• Legitimate interests (e.g., organizing events, sharing information about our events, providing services, efficient event management)

• Consent (e.g., to send you marketing information or to create and use image or video material)

If you contact us (e.g., by phone, email, or chat) or if we contact you, we process the personal data necessary for this communication. We also process personal data when you visit us. In such cases, you may be required to provide your contact details either in advance or at the reception. This information is stored for a certain period to protect our infrastructure and information.

To conduct conference calls, online meetings, video conferences, and/or webinars (“online meetings”), we use the services Zoom, Microsoft Teams, or Skype.

In this context, we process in particular the following information:

• Contact Information
  e.g., name, first name, address, telephone number, email

• Communication Metadata
  e.g., IP address, duration of the communication, communication channel

• Recordings of conversations, e.g., during video conferences

• Other information provided, uploaded, or created by the user while using the video conferencing service, as well as metadata used for maintaining the provided service.
  Additional information about the processing of personal data by Zoom, Microsoft Teams, and Skype can be found in their respective privacy policies.

• Personal Information
  e.g., profession, job title, position, employer

• Date, time, and purpose of the visit

We process these personal data for the purposes described based on the following legal grounds:

• Performance of a contract with the data subject or for the benefit of the data subject, including contract initiation and potential enforcement (e.g., provision of a service)

• Legitimate interests (e.g., ensuring security, traceability, and the management and administration of client relationships)

You may submit your application for a position with us by mail or via the email address provided. All application documents and any personal data disclosed to us in this context are treated with strict confidentiality, are not shared with third parties, and are processed solely for the purpose of handling your application for employment with us. Unless you have given us permission to retain your documents, your application materials will either be returned to you or deleted/destroyed after the application process has been completed, provided there is no legal obligation to retain them. The legal basis for processing your data includes your consent, the performance of a contract with you, and our legitimate interests.

In this context, we process in particular the following information:

• Contact Information
  e.g., name, first name, address, telephone number, email, social media

• Personal Information
  e.g., profession, position, title, employer

• Application Documents
  e.g., cover letters, certificates, diplomas, CV/resume

• Assessment Information
  e.g., evaluations by recruitment consultants, reference checks, assessments

We process these personal data for the purposes described based on the following legal grounds:

• Legitimate interests (e.g., hiring new employees)

• Consent

When we enter into a contract with you for the provision of services, we process personal data of you or your employees. We need this data to communicate with you and to utilize your services. We may also process this personal data to check for potential conflicts of interest related to our role as an auditor and to ensure that our collaboration does not involve any unintended risks, such as those related to money laundering or sanctions.

In this context, we process in particular the following information:

• Contact Information
  e.g., name, first name, address, telephone number, email

• Personal Information
  e.g., profession, position, title, employer

• Financial Information
  e.g., bank account details

We process these personal data for the purposes described based on the following legal grounds:

• Conclusion or performance of a contract with the data subject or for the benefit of the data subject, including contract initiation and potential enforcement

• 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 your browser automatically creates and stores on your device (laptop, tablet, smartphone, etc.) when you visit our site.

Cookies store information related to the specific device being used. However, this does not mean that we directly learn your identity. The use of cookies serves to make your experience on our website more pleasant. For example, we use so-called session cookies to recognize that you have already visited certain pages of our website. These cookies are automatically deleted when you leave our site.

Additionally, we use temporary cookies to optimize user-friendliness, which are stored on your device for a specified period. When you visit our site again to use our services, it is automatically recognized that you have visited before and which inputs and settings you have made, so you do not need to enter them again. Furthermore, we use cookies to collect statistical data on the usage of our website and to evaluate it for the purpose of optimizing our offerings for you. These cookies allow us to automatically recognize that you have previously visited our site. These cookies are automatically deleted after a defined period.

The data processed by cookies are necessary for the purposes mentioned above. Most browsers accept cookies automatically. However, you can configure your browser to prevent cookies from being stored on your computer or to always display a notification before a new cookie is created. Please note that completely disabling cookies may prevent you from using all features of our website.

This website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as inquiries you send to us as the site operator. You can recognize an encrypted connection by the change in the browser’s address bar from "http://" to "https://" and by the lock symbol in your browser’s address bar.

When SSL encryption is enabled, the data you transmit to us cannot be read by third parties.

On our website, we use Google Maps (API) from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; for Europe, Google Limited Ireland is responsible, hereinafter “Google”). Google Maps is a web service for displaying interactive (land) maps to visually represent geographical information. By using this service, our location is shown to you and directions may be facilitated.

When you access the pages that contain the embedded Google Maps, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. This happens regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged into Google, your data will be directly associated with your account. If you do not wish this association with your Google profile, you must log out before activating the button. Google stores your data (even for users not logged in) as usage profiles and evaluates it.

For data transfers to the USA, Google has committed to signing and complying with the EU standard contractual clauses.

This website uses features of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access one of our pages that contains LinkedIn functions, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click the "Recommend" button on LinkedIn and are logged into your LinkedIn account, LinkedIn can associate your visit to our website with you and your user account. Please note that, as the provider of the website, we have no knowledge of the content of the transmitted data or its use by LinkedIn.

Further information can be found in LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy

We only share your data with third parties if this is necessary for the provision of our services, if these third parties provide services for us, if we are legally or officially obliged to do so, or if we have an overriding interest in sharing the personal data. We will also share personal data with third parties if you have given your consent or have requested us to do so.

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

• Headquarters, branch offices

• Service providers (e.g., IT service providers, hosting providers, suppliers, consultants, lawyers, insurers)

• Third parties within the scope of our legal or contractual obligations, authorities, public institutions, courts

We enter into 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 or, in exceptional cases, to other countries worldwide. If a data transfer to countries without an adequate level of data protection is necessary, this will be done based on the EU Standard Contractual Clauses (e.g., in the case of Google) or other appropriate instruments.

We process and store your personal data for as long as it is necessary to fulfill our contractual and legal obligations or for the purposes pursued by the processing. This means, for example, throughout the entire business relationship (from initiation and execution to termination of a contract) as well as beyond that in accordance with statutory retention and documentation obligations.

It is possible that personal data will be retained for the period during which claims can be made against our company (i.e., particularly during the statutory limitation period) and insofar as we are otherwise legally obliged or have legitimate business interests (e.g., for evidence and documentation purposes).

Once your personal data is no longer required for the aforementioned purposes, it will generally be deleted or anonymized wherever possible. For operational data (e.g., system logs), shorter retention periods generally apply.

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse. These measures include issuing guidelines, conducting training, implementing IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, and regular audits.

When you communicate with us via email, please note that this occurs over public, non-secure data transmission networks. Data communication over the internet cannot be guaranteed to be error-free or available at all times according to the current state of technology. ARGO expressly disclaims any liability for damages resulting from transmission errors, technical faults, disruptions, or unauthorized interference with the network operators’ systems.

We generally transmit your data (depending on the assignment, e.g., accounting data, tax data, personal payroll data, etc.) in a protected or encrypted form unless you have explicitly consented to unprotected and unencrypted transmission. This consent does not apply to particularly sensitive data of your employees or other related persons. Such data may only be transmitted unprotected and unencrypted if the affected person has given their explicit consent. These consent declarations can be revoked at any time in writing.

As part of our business relationship, you must provide the personal data necessary for the initiation and execution of the business relationship and the fulfillment of the associated contractual obligations (generally, you do not have a legal obligation to provide us with data). Without this data, we will not be able to enter into or process a contract with you (or the entity or person you represent). Likewise, the website cannot be used if certain information necessary to ensure data traffic (such as your IP address) is not disclosed.

You have the following rights in connection with our processing of your personal data:

• The right to access your personal data stored with us, the purpose of processing, the origin, as well as recipients or categories of recipients to whom the personal data are disclosed

• The right to rectification if your data is incorrect or incomplete

• The right to restrict the processing of your personal data

• The right to request the deletion of processed personal data

• The right to data portability

• The right to object to data processing or to withdraw your consent to the processing of personal data at any time without giving reasons

• The right to lodge a complaint with a competent supervisory authority, if legally applicable

To exercise these rights, please contact the address provided in section 2.

Please note that we reserve the right to invoke the legally permitted restrictions ourselves, for example if we are obliged to retain or process certain data, if we have an overriding interest in doing so (to the extent we are allowed to rely on this), or if the data is needed to assert claims. If any costs arise for you, we will inform you in advance.