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    Data Protection Statement

    1. Responsible for data processing

    Cofaktory Sàrl is a company incorporated in Switzerland. The protection of the personal data of our prospects and clients, as well as our partners, is essential to Cofaktory Sàrl and we are committed to treating the data collected with the utmost care. We offer professional training management service to any company, in particular financial intermediaries in Switzerland and abroad through this website. We process the personal data of our clients and our business relationships in accordance with the present declaration and any applicable regulations, the Swiss Federal Data Protection Act. Our services require the use of several websites operated by third parties, as well as the use of services provided by these third parties, which are described below and for which the conditions of use and data protection described by these service providers on their own websites apply. Our use of cookies and similar technologies is also described below.

    The data responsible can be contacted at the following address:
    Cofaktory Sàrl
    Responsible for data processing
    23C chemin des Buclines
    1223 Cologny (Switzerland)
    E-mail: service@cofaktory.com

    1. Data Source

    We collect and process the personal data provided by our clients, by our prospect and by our business relations in the context of contracts for the provision of services agreed by this website, in particular data concerning payment for services purchased or by any other means of communication (email, letters, contracts concluded in written form, etc.). We also process, with your consent, personal data that may have been transmitted to us by organizations with which our clients are affiliated or with which they have business relations.

    1. Collected data

    We collect the following data from people attending our training courses: surname, first name, private and/or business billing address, telephone number, e-mail address, other contact details, date of birth, data relating to your professional career and the diplomas you have obtained, any data useful for defining training needs, the company name of the company employing you, current professional activity, type of authorizations or affiliations relating to the professional activity and any other useful data in particular, we collect and process data relating to the means of payment used, such as the surname, first name, e-mail address and telephone number of the holder of the means of payment.

    When a training course is completed, we collect and process data relating to the learner’s completion of the course, its success or failure, and we issue a certificate containing the learner’s personal data, which is sent to the learner. In the case of group purchases, we draw up a training follow-up report which is sent to the learner’s employer.We collect information relating to connections to our website, such as IP address, date and time of connection, pages consulted, etc..

    1. Sources of personal data

    The personal data collected and processed are those entered by each client on the Cofaktory Sàrl website and on third-party sites (purchase form and payment form) or made available by any other means of communication, in particular email sent to Cofaktory Sàrl. In the case of group purchases, the personal data of third parties (employees of the company ordering the training courses, third parties commissioned by the client to order the training courses) is entered by the person in charge of the order on behalf of the client and is collected and processed. We also collect information when you connect to our website. Our cookie policy is described below.

    1. Motivation for data processing (Purpose of processing)

    We process your personal data in accordance with the Swiss Federal Data Protection Act, for the performance of our contractual obligations and for promoting our services.

    We process personal data within the framework of the service contract concluded with our customers and business relations as well as within the framework of pre-contractual measures for the purpose of setting up a service offer in order to conclude a service contract.

    The purpose of the data processing is :

    • To set up a training path adapted to the user, to offer services to employers for the training of groups of users, to set up a channel of information on the paths carried out by the users in favour of professional bodies, to follow the training paths of each user and to ensure the tracing and certification of the training followed, to propose new training options to each user or to all the users of the website (marketing) through personal communication or general advertising, to evaluate and improve the efficient conduct of the services provided through the website or by other means, to ensure the legal and contractual compliance of the activity of Cofaktory Sàrl and its collaborators and representatives.
    • To organize, prepare and deliver face-to-face training courses for learners, and provide services related to the delivery of these courses, such as maintaining lists of participants, issuing certifications, and sending reminders or personal invitations to certain participants.
    • In addition, certain non-personally identifiable aggregated data is used for marketing and service evaluation purposes for the sole benefit of Cofaktory Sàrl.
    1. Personal consent

    Personal data is processed on the basis of the consent of each individual to the processing of his or her personal data.

    All data collected and processed are provided by users of the site or by business relations with specific consent to the processing of personal data in accordance with this Data Protection Statement. When the user or his/her representative indicates that he/she is affiliated to a supervisory body, that he/she is registered in a professional register or that he/she is represented by a company, for example his/her employer, the user, by accessing the learning services, accepts and authorizes Cofaktory Sàrl to transmit his/her data to the indicated entity. The purpose of this transmission is to allow the client of the training services to benefit from a discount or specific services provided for in the agreement with Cofaktory Sàrl. Any consent granted may be revoked at any time with immediate effect by communication to the following e-mail address: service@cofaktory.com. The processing of personal data carried out prior to withdrawal of consent remains legal. Withdrawal of consent may make it impossible to provide the agreed services, with the agreed price remaining payable in full in all cases.

    1. Users’ rights

    The following rights are granted to the clients of Cofaktory Sàrl under the Swiss Federal Data Protection Act:

    • Right of access
    • Right to rectification and deletion
    • Right to Limitation of Treatment
    • Right of opposition
    • Right to restrict access to a third party or the right to request that access be given to a third party

    Our clients and prospects also have the right to lodge any data protection complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) – Feldeggweg 1 – CH-3003 Bern.

    In the event of a request to exercise a data protection right, Cofaktory Sàrl reserves the right to verify the identity of the person making the request by any appropriate means in order to ensure that our customers’ personal data is protected.

    1. Data access for Cofaktory Sàrl clients

    The employees, representatives and agents of Cofaktory Sàrl have access to the personal data of our clients and prospects in the context of the performance of their respective tasks.

    Each of them undertakes to comply strictly with applicable legislation and confidentiality obligations relating to users’ personal data arising from their contractual relationship with Cofaktory Sàrl.

    1. Transfer of your data in Switzerland or outside of Switzerland

    Where applicable, our clients’ personal data is transferred, with their prior consent only, to the professional organization to which our clients are affiliated and which they themselves have indicated at the time of purchase. By giving their consent to the collection and processing of data, our clients also give their consent to the transfer of their data as described below.

    Cofaktory Sàrl reserves the right to disclose, transfer and/or store personal data outside Switzerland to other service providers in connection with the conclusion or provision of services agreed with its clients for themselves or in the interest of a third party as described above (see collective purchase). Cofaktory Sàrl also reserves the right to transfer personal data abroad if such transfer is necessary to establish or defend against a claim or to cope with state proceedings in Switzerland or abroad. If the transfer outside Switzerland is made to a country that does not offer an adequate level of protection within the meaning of Swiss law on the protection of personal data, Cofaktory Sàrl undertakes to put in place the required guarantees, such as specific contractual clauses.

    List of subcontractors directly involved in providing services to our customers:

    Name Service Location (Transfer mechanism)
    Infomaniak Site hosting (URL), e-mails Switzerland
    Learn Amp* Learning Management system Hosting Ireland
    CV Trust Retentions of training certification EEE
    Office 365 e-mails, files, platform Teams, Cloud Switzerland
    Intuition Development and provision of e-learning content EEE, outside of EEE (see Intuition website)
    PostFinance System collection Switzerland
    Check out System of payment Switzerland, EU
    Google Analytics Statistics USA (clauses contractual type)
    Linkedin Marketing USA (clauses contractual type)
    BCDT SA Accountant Switzerland

    *The platform used by our clients to access our training courses is provided by an IT service provider, LearnAmp, based in Ireland. This provider is subject to the European Union’s personal data protection rules (European Data Protection Directive (GDPR). This supplier has also undertaken to Cofaktory Sàrl to strictly respect and apply all its obligations arising from the European Union legislation.

    **The platform for creating and storing “smart” digital certificates is provided by a supplier also located within the European Union and subject to the European Union’s personal data protection rules (European Data Protection Directive (GDPR). This supplier has also undertaken to strictly respect and apply all its obligations arising from the European Union legislation.

    List of Subcontractors involved only in the global promotion of Cofaktory Sàrl and its services:

    Google Analytics Statistics USA (clauses contractual type)
    Linkedin Marketing USA (clauses contractual type)
    1. Duration of retention of your data

    Our clients’ data is kept for as long as is necessary to achieve the defined purpose, in particular to provide the services agreed with each client. Accordingly, personal data is retained until clients terminate any contractual relationship with Cofaktory Sàrl in connection with the use of the services made available on this training platform. Personal data is retained beyond this point, insofar as this is required by law or regulation. We apply a strict internal policy for the retention and protection of personal data.

    Regarding the smartcertificate.com platform: digital certificates attesting to training remain accessible without time limit for clients and beyond the provision of services, so that clients can access their certifications and provide proof of their training. At any time, clients may decide to delete their account on this platform and their data will be deleted. In such a case, Cofaktory Sàrl disclaims all responsibility and will not be able to recreate or access said certificates.$

    1. Consequences in case of refusal to provide data

    As part of the provision of our training services through this platform, we create a personal user profile for each client based on the data provided to us. Our services include the follow-up of training courses carried out on the platform or face-to-face. For these services to be implemented, clients must provide us with personal data as requested at the time of registration and subsequently, and we must store this data as described in this Data Protection Statement.

    1. Cookies policy

    We use cookies to optimize the promotion of our services and to enhance the user experience.

    A cookie is a file recorded by a navigation tool such as a computer, telephone, etc. when a website (web domain) is consulted. The cookie is stored to enable rapid identification during subsequent contacts with the same web domain, and to immediately reproduce certain elements present on the site, such as the choice of language or the completion of a form. Some elements are necessary to perform the functions requested by the user or to establish communication. The recording of other elements, such as personal data recorded on a form by the user or a shopping cart, is not necessary for operation, but enables interaction to be improved.

    A site that uses cookies will display a message allowing you to accept or refuse cookies, or even to accept only those that are necessary for the execution of technical functions. Cookies are deposited either on the site consulted, or on different domains queried by the site consulted and not by the user. Some cookies are necessary for the proper functioning of the site, but they also enable us to know which pages of the site have been consulted, in order to collect information for marketing purposes. In principle, only cookies deposited on the site consulted provide access to personal data, the collection of which makes it possible to identify the user’s behavior.

    Users can deactivate cookies at any time by adjusting their browser settings according to their specific configuration.

    The cookies we use:

    Cookies (type) Provider Service Localization data
    Cookies techniques and necessary WordPress/Woocommerce Detection of spams and improve security Switzerland
    Linkedin Non classified USA (clauses contractual type)
    Cookies preferences WordPress/Woocommerce Spam, security, language Switzerland
    Linkedin Non classified USA (clauses contractual type)
    Cookies statistics WordPress/Woocommerce Spam, security, language Switzerland
    Linkedin Statistics USA (clauses contractual type)
    Google Analytics Statistics USA (clauses contractual type)
    Ln_or (linkedin) Statistics Ireland
    Cookies marketing Linkedin Marketing USA (clauses contractual type)
    Cookies WordPress/Woocommerce Spam, securtity, language Switzerland
    Postfinance Non classified Switzerland
    1. How do you contact us?

    Cofaktory Sàrl
    Responsible for data processing
    23c chemin des Buclines
    1223 Cologny (Switzerland)
    E-mail: service@cofaktory.com

    For more information

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