This Privacy notice describes how CBSA (hereinafter referred to as “the Company” or “We“, or “Us”) collects, shares, protects and otherwise processes your Personal Data (as defined below) when you visit and/or register to our website. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal data in collected via our website. This Privacy Policy has been prepared in light of the EU’s General Data Protection Regulation (“GDPR“) and the applicable national legislations.
We are committed to follow the GDPR in all data processing operations in the European Economic Area, the UK and where it otherwise applies. We are also committed to follow the rules and principles of the applicable local personal data protection legislations.
- Who we are?
Cross-border Successions Alliance (hereinafter: “CBSA”), having its office at Route de Crassier 7 Eysins, CH-1262, Switzerland is a Swiss association (Swiss verein) providing the following services: (i) global organization and coordination of services, provided by qualified service providers, required as part of cross border successions (international inheritance), including, without limitation, tax advisory, legal advisory, estate planning, project management, real estate agency, (ii) making a sustained effort to improve cross-border succession service quality, (iii) establishing and implementing highest industry standards, (iv) enhancing experience and knowledge by sharing it within the industry, via forums for such activities, (v) promoting the use of modern technologies within the cross-border succession industry, and (vi) marketing and advertising the CBSA.
For any further information or clarification please contact Mr. Dušan Maksimović at dusan.maksimovic@cbsa.eu
CBSA does not itself engage in the practice of law, tax advisory, estate planning or other business. Such services are provided by the partner firms of the CBSA (hereinafter: “Partners” or, individually a “Partner”), who, themselves or with their entities, engage in a coordinated international advisory, tax advisory, legal services, estate planning practice, and other services. For details please see CBSA Standard terms of engagement at the website.
Therefore, “We”, “our” and “us” may refer to the CBSA or/and its Partner depending on your instructions, requests or needs expressed during the use of the website or later communication with CBSA representatives.
If you engage Partner to provide you any of the services and exchange with him/her data or documents, your Data Protection rights shall be regulated by the agreement and/or regulations (laws, codes of ethics, bylaws etc.) applicable to the relationship between you and the Partner. Such partner shall be solely responsible for the exchange and protection your Personal Data with CBSA, other CBSA Partners or third party.
- What information do we collect?
“Personal Data” refers to any information that may be used, alone or in combination with other information, to identify you. For purposes of this Privacy Policy, we consider all of the below information we collect about you “Personal Data“.
When ordering or registering on our website, as appropriate, you may be asked to enter your name, surname, email address, mailing address, phone number, identity authentication information (password), IP address, the country where you live and your location.
We may also process your other personal information, document or other details that would enable us to address your legal request and help you with your experience which with CBSA or CBSA Partner.
Generally, we do not process sensitive data, i.e. referred to as “Special Categories of Personal Data” i.e. personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning your health or data concerning your sex life or sexual orientation. In case processing of these data is necessary for addressing your legal requirement, they will be processed in line with the conditions described in the section below.
- Use of cookies and other technologies
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
- Understand and save user’s preferences for future visits.
- Keep track of advertisements.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, some of the features that make your site experience more efficient may not function properly. Some of the features that make your site experience more efficient and may not function properly.
- How We Use Your Personal Data?
To the extent permitted by applicable law, we use your Personal Data for the following purposes and based on the following legal basis.
Contractual necessity
We may process your Personal Data where it is necessary to enter into a contract with you for the provision of Our services or to perform Our obligations under that contract. For example, we may need to process your Personal Data:
- To register you and to enable you to use Our services;
- To send you important notices such as correspondence on changes to our services portfolio or to this Policy; and
- To keep internal records on software updates, technical services and other transactions to the extent necessary for the provision of Our services.
If you do not provide us with certain Personal Data for processing as described above, we may not be able to provide the service requested.
Legal obligation
We may be required by the law to collect and process certain Personal Data about you. For example, we may need to process and disclose your Personal Data when we have a good faith believe that doing so is necessary to comply with applicable law or to respond to a valid legal process, including from law enforcement or other government agencies.
Our legitimate interests
We may process your Personal Data where it is necessary for our legitimate interests, including to manage, promote and improve our services and manage our and our users’ risk. For example, we may process your Personal Data:
- To set up and administer your account at our website;
- To connect you with the person who can provide information you may need or you require by using our website;
- To personalize the content, business information or user experience;
- To inform you of any new product or service by sending notices, advertisements or pictures through e-mail, unless your consent is required for such communications (see below section Direct Marketing). If you would prefer not to receive these communications, simply follow the unsubscribe instructions in the promotional communications that you receive or contact us as described below;
- To detect, deter or otherwise address any fraud or security issues related to our services.
Your consent
Where required by applicable law, we will seek your separate consent to process your Personal Data for specific purposes. For example, we may seek your separate consent to send you direct marketing messages or to collect location data to offer location-based services.
If we have sought your consent to process your Personal Data, you may subsequently withdraw it at any time by contacting us using the contact details provided in this Policy, without affecting the lawfulness of processing based on consent before its withdrawal.
- Retention of Your Personal Data
Your Personal Data will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. If a deletion of your Personal Data would only be possible with unreasonable efforts, we will anonymize it instead of deletion. We will not collect Personal Data about you that is not necessary for the purposes it is collected for.
- Direct Marketing
We may use your Personal Data for marketing purposes, in particular to display to you or present you with advertisements and promotional materials.
We will ask you to expressly consent to receiving marketing material or product information before we send you any marketing or promotional material.
You can change your mind about your preferences in respect of direct marketing at any time by using the unsubscribe button on every marketing communication, by updating your user profile or account data or by contacting us. If you do so, note that we will not remove your Personal Data from our databases to the extent that this Personal Data is still required by us under the terms of this Privacy Policy or otherwise to continue to provide our Services to you.
- When do we share personal data?
We may share your Personal Data in accordance with applicable law in the following cases:
Third parties where required by law. We may disclose your Personal Data to a third party if it is necessary to comply with a legal obligation or the decision of a judicial authority, public authority or a government body, or if disclosure is necessary for national security, law enforcement or important public interest.
Service providers. We may disclose your Personal Data to the companies that provide services to us, such as companies that provide cloud computing services. The service providers are required to keep your Personal Data confidential and are not permitted to use your Personal Data for any other purpose than to carry out the services they are performing for us.
Other third parties with your consent. We may also share your Personal Data with other third parties when you consent to such sharing. For example, we would provide Partner with data necessary to contact you when you require the phone call from CBSA experts.
- Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising Policies.
They are put in place to provide a positive experience for users.
We use Google AdSense Advertising on our website.
Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.
We have implemented the following:
- Remarketing with Google AdSense
- Google Display Network Impression Reporting
- Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
- Where do we store and process personal data?
Your Personal Data will be processed by CBSA seated in the UK.
If you are registered client of CBSA, access to your data is provided to your legal counsel and the case manager of CBSA. We are securing that access to your Personal Data is limited to those persons for whom its necessary to have such access and are involved in providing services or assistance to you.
If your legal counsel, or our other service provider is located outside the European Economic Area (“EEA”), the UK, and Switzerland in countries with different laws for the protection of Personal Data than the laws in your country of residence, before transferring your Personal Data, we will take steps to ensure that such data will be afforded the same level of protection as under applicable data protection laws within the EEA, the UK and Switzerland. For data transfers outside of the EEA, the UK and Switzerland, the Company uses applicable safeguards, including the standard contractual clauses adopted by the European Commission, where appropriate, and will make available a copy to you upon request.
We will not make your Personal Data available to third parties for any purposes other than as described in this Privacy Policy and we will not sell your Personal Data.
- Security Measures Taken for Your Personal Data
The Company takes appropriate administrative, technical and physical measures to protect your Personal Data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.
We protect the security of your Personal Data by using encryption and password protection where appropriate, and limiting access to your Personal Data.
We do not use vulnerability scanning and/or scanning to PCI standards.
We do not use Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
- Your rights in relation to personal data
You have the following rights with respect to your Personal Data we process, subject to conditions set out in applicable law:
- to be informed on whether your Personal Data is processed by us and, if processed, to request a copy of your Personal Data and information relating to the processing of your Personal Data, including the purposes of processing your Personal Data and whether such data is used for intended purposes and the third-parties to whom your Personal Data is disclosed;
- to request the correction of any inaccurate or incomplete Personal Data;
- to request the erasure of your Personal Data or the restriction of the processing of your Personal Data;
- to object to any further processing of your Personal Data;
- to withdraw any consent you have given without affecting the lawfulness of processing based on consent before its withdrawal;
- to demand data portability;
- to lodge a complaint with a supervisory authority; and
- to contest certain automated decisions that have legal or otherwise similarly-significant consequences, in case we make such decision.
- How to contact us?
For all the information related to processing of your personal data, or exercising of your rights, in this regard, please contact:
By email
Mr. Dusan Maksimovic at dusan.maksimovic@cbsa.eu
By telephone
+41 (0) 22 595 12 09
CBSA address
Cross-border Successions Alliance
Route de Crassier 7 Eysins, CH-1262
Switzerland
