Last updated: 06/04/2025

This Privacy and Cookie Policy describes how Loyal Group GmbH (hereinafter “Loyal Group” or “we”) collects, uses, stores, and protects the personal data of its clients and visitors of the website www.loyalgroup.ch. Our personal data processing activities are carried out in accordance with the Swiss Federal Act on Data Protection (FADP).

1. Data Controller

  • Company Name: Loyal Group GmbH
  • Address: Sumpfstrasse 18, 6312 Steinhausen (ZG), Switzerland
  • Phone: +41 91 946 33 33
  • Email: info@loyalgroup.ch
  • Website: www.loyalgroup.ch

For any inquiries regarding data protection or to exercise the rights listed in this policy, you may contact us at the above email address.

2. Types of Personal Data Processed

Depending on the type of consultation requested, we collect and process the following categories of personal data:

  • Personal and contact information: name, surname, date of birth, address, email, phone number, nationality, residence permit, marital status, profession.
  • Identification and banking data: social security number (AVS), copies of identity documents, bank statement, income, assets, financial solvency information.
  • Contractual data: information related to current insurance or financial contracts (terms, expiration dates, etc.).
  • Health data: information on health status necessary exclusively for the conclusion and management of insurance contracts or for risk assessment as provided by the contractual terms. Such data, considered “particularly sensitive” under the FADP, is processed on the basis of contractual necessity and only to the extent strictly required to fulfill the agreed contractual or pre-contractual obligations. If the processing exceeds what is strictly necessary, explicit consent will be requested, which may be given in writing or verbally.

3. Purposes of Processing and Legal Bases

The personal data is processed for:

  1. Providing financial and insurance advice
    • Financial planning (analysis of assets and income)
    • Evaluation and proposal of insurance solutions
    • Establishing new relationships and concluding contracts with insurance/financial partners
  2. Management of contractual relationships and legal obligations
    • Execution of contractual and pre-contractual obligations
    • Administrative and accounting management
    • Compliance with legal or regulatory requirements (e.g., tax matters, anti-money laundering)
  3. Marketing activities and promotional communications
    • Sending newsletters and commercial communications
    • Telephone calls to present services, offers, or updates
    • Based on our legitimate interest to promote services to clients and prospective clients who have already requested advice or shown interest
  4. Website management and cookies
    • Analysis of visits and improvement of user experience
    • Use of tracking tools and third-party services (see section “Cookies and Tracking Tools”)

Main legal bases
· Contractual necessity: to conclude and execute the contract or for pre-contractual measures.
· Legal obligation: to comply with regulatory provisions (e.g., in the tax field, anti-money laundering).
· Legitimate interest: for marketing activities aimed at those who already have a contractual relationship or have requested advice.
· Consent: in specific situations or if required by law (especially if the processing of sensitive data exceeds what is strictly necessary).

4. Disclosure of Data to Third Parties

We share personal data exclusively with third parties in Switzerland or (if applicable) within the EU/EEA when necessary for the purposes indicated. In particular:

  • Insurance and financial partners: for the conclusion and management of insurance, banking, or investment contracts.
  • IT service providers: for the maintenance of the CRM and dedicated servers, located in Switzerland and accessible only by our team.

All third parties with whom we collaborate are bound by specific confidentiality agreements and process the data solely according to our instructions. We do not sell or transfer personal data to third parties for external marketing purposes.

5. International Data Transfers

We do not transfer personal data outside Switzerland or the EU/EEA, except for processing resulting from the use of third-party services (e.g., WhatsApp, as described in the dedicated section), which may store or route the data on servers located in countries that do not offer a level of protection equivalent to that of Switzerland or Europe. In such cases, the use of such services is based on the consent or informed choice of the data subject (for example, when the user chooses to communicate with us via WhatsApp), or within the framework of contractual clauses or other safeguards provided by applicable regulations.

6. Marketing Activities and Promotional Communications

Based on our legitimate interest, we may:

  • Send newsletters or email communications to those who have already used our services or requested them.
  • Make telephone calls or send messages to introduce new products or services.

These activities are based on our interest in promoting our services to existing or potential clients who have already requested advice, established a contractual relationship, or shown interest in our offers. This interest has been assessed by balancing our business objectives with the rights and expectations of the data subjects. Data subjects may object to such communications at any time, for example by using the unsubscribe link included in every email or by contacting us at info@loyalgroup.ch, without affecting the contractual relationship or the services provided.

7. Data Retention Period

We retain personal data for the period strictly necessary for the purposes for which it was collected, taking into account legal obligations or the need to protect our rights. Typically, the data is retained for a maximum period of 10 years from the end of the contractual relationship, unless:

  • Specific regulatory obligations require longer retention periods
  • Ongoing or potential litigation requires retaining the data until resolution

After this period, the data is deleted or rendered anonymous in an irreversible manner, unless further retention is required for legal reasons.

8. Rights of the Data Subjects

Data subjects may exercise the following rights, in accordance with the FADP:

  • Right of Access: to obtain confirmation that we are processing personal data concerning them and, if so, to receive a copy.
  • Right to Rectification: to request the correction of inaccurate or incomplete data.
  • Right to Erasure: to request the deletion of data, within the limits permitted by law.
  • Right to Object: to object to processing based on our legitimate interest, including direct marketing.
  • Right to Restrict Processing: under certain circumstances (e.g., if they contest the accuracy of the data), they may request a temporary restriction of data usage.
  • Right to Data Portability: if data is processed automatically within the context of a contractual relationship, they may sometimes request its transfer in a commonly used electronic format.

To exercise these rights, you may contact us by email at info@loyalgroup.ch.

9. Data Security

We adopt advanced technical and organizational security measures to protect personal data from unauthorized access, loss, alteration, or disclosure. The transfer of data between the user's browser and our servers is carried out exclusively via encrypted connections, using SSL (Secure Sockets Layer) certificates on all endpoints, with mandatory authentication to ensure the confidentiality and integrity of the transmitted information.

On our server, data is stored in a secure, externally inaccessible environment, thanks to a firewall configured to block unauthorized IP-level access. Administrative access to the machines is permitted only via certificate-based authentication, limiting entry to authorized personnel. Our systems are regularly updated to protect against known vulnerabilities and are periodically monitored to detect and prevent any anomalies or unauthorized access attempts.

Access to personal data is restricted solely to employees who have a legitimate need to access such data for the performance of their duties, in compliance with the principle of data minimization.

10. Contact Methods and Videoconferencing

We use various communication channels with our clients, including email, telephone, and WhatsApp (managed by Meta, with an operational entity in Europe). WhatsApp may store or route data on servers located outside Switzerland or the EU/EEA. We encourage those who desire a higher level of protection to use alternative channels (such as email or telephone). If a client does not wish to transmit sensitive data via WhatsApp, they may notify us at any time, and we will use only more secure methods.

For consultations and online meetings, we may use Microsoft Teams or Google Meet. In these sessions, we process only the personal data necessary to allow participation (e.g., the email address to send the invitation). These platforms may collect technical information (such as IP addresses) in accordance with their respective privacy policies.

11. Cookies and Tracking Tools

Our website uses technical cookies that are strictly necessary for its operation, which do not require the user’s consent. With explicit consent, obtained via a cookie management banner, we also use analytical and profiling cookies to:

  • Improve the user experience and navigation
  • Perform statistical analyses on visits and traffic
  • Offer personalized content or advertisements

The banner allows users to accept or reject each category of cookies in a simple manner. Consent can be revoked at any time through the banner or browser settings, without compromising access to the website or essential content.

What are cookies: Cookies are small text files stored on the user's device during browsing. They allow the visitor to be recognized, remember their preferences, and improve the user experience of the site.

Modification or deletion of third-party cookies: Should the user wish to modify or delete cookies set by third parties, they must refer to the respective privacy policies of the providers or contact them directly.

11.1 Analytics and Marketing Tools

11.2 Electronic Signature Services

We use the YouSign platform for the electronic signing of documents (such as advisory mandates). The personal data collected (name, surname, email, signature) is necessary to authenticate and validate the electronic signature and is processed by YouSign in accordance with its data protection policies.

12. Data Protection Officer (DPO)

We have not appointed a Data Protection Officer (DPO) as the personal data processing carried out by Loyal Group GmbH does not involve systematic large-scale monitoring nor extensive processing of particularly sensitive data beyond what is strictly necessary for contractual purposes. For any questions or requests regarding data protection, you may contact us at info@loyalgroup.ch, where a dedicated internal representative will promptly respond.

13. Updates to this Privacy and Cookie Policy

We reserve the right to modify or update this Privacy and Cookie Policy at any time. Changes will take effect upon publication on the website www.loyalgroup.ch. We encourage users to check this page periodically for any updates.

14. Language Versions and Prevalence of Italian

This Privacy and Cookie Policy is available in multiple languages to facilitate understanding by international visitors and clients. For the purposes of interpretation and in the event of any legal disputes, the Italian version shall be considered the official and prevailing version over any other translation.

For further information or clarification, you may contact us at info@loyalgroup.ch.