WISE Sàrl

PRIVACY AND COOKIES POLICY APPLICABLE TO THE WEBSITE AND SOCIAL NETWORKS

October 11, 2023 version

1. Preamble

The protection of your privacy in the processing of your personal data, as well as the security of all personal data, is one of our major concerns. This privacy and cookies policy applicable to the website and social networks (the "Privacy Policy") describes how your information is processed in connection with the site accessible at https://www.wise.net (the "Site" or "Website") and with our pages available on the following social networks: LinkedIn, Vimeo and YouTube, all of which are managed by WISE Sàrl (the "Company", "WISE", "we", "us", "our"), whose registered office is at Place de Cornavin 2, 1201 Geneva, Switzerland.

Please read this Privacy Policy carefully before using the Website and our social network pages. This Privacy Policy explains how information relating to an identified or indentifiable person ("Personal Data") is collected, used and protected in accordance with the legal obligations arising from the Data Protection Act of 25 September 2020 ("DPA") and other relevant legal bases, including the European Data Protection Regulation (EU) 2016/679 ("GDPR") of 27 April 2016, to the extent applicable.

If you access our pages available on social networks, as well as other third party websites from our Website, the information you communicate will be subject to the confidentiality policy of the third party concerned.

By browsing the Website, you acknowledge and agree to the processing of your Personal Data as described in this Privacy Policy. If you do not agree to your Personal Data being processed in accordance with the terms of this Privacy Policy, please do not use the Website or our pages available on social networks.

2. Data controller

WISE Sàrl, whose registered office is at Place de Cornavin 2, 1201 Geneva, Switzerland, acts as data controller for the processing of Personal Data collected via its website and its dedicated pages on social networks.

3. General principles

3.1       Our Website and our pages available on social networks contain the following information and services:

  • (i) information about the Company, its team and ecosystem, and its various activities, illustrated in particular by several case studies;
  • (ii) information on the ancillary services offered by the Company, such as conferences and training courses organised and books published, in particular the Family Philanthropy Navigator, as well as other types of derivative products
  • (iii) articles in the form of case studies written by the Company or in collaboration with third parties, particularly in the form of testimonials;
  • (iv) promotional videos of our activities uploaded from the dedicated YouTube and Vimeo platforms;
  • (v) various ways of contacting us, in particular by e-mail, telephone or interest or registration form for our events and training courses, such as the Foundation Board Academy or the NextGen Bootcamp;
  • (vi) links to other third-party websites.

3.2       This Privacy Policy does not apply to offline services.

4. The personal data we collect and the purposes for which it is collected

A. Sources of data

4.1.      The Personal Data that we collect via our Website and our pages available on social networks fall into two categories:

  • (i) Cookies (infra B.) ;
  • (ii) Personal data that you communicate to us (infra C.).

B. Cookies

1. What are cookies and what information do they collect?

4.2. Cookies are files containing a small amount of data that are sent from a website to your browser and stored on your device (computer or mobile device). Other tracking technologies, such as beacons, tags and scripts (the "Similar Technologies"), may also be used to collect and track information and to improve and analyse our Website.

4.3. By means of Cookies and Similar Technologies, we may collect Personal Data when you visit our Website or our pages available on social networks. In particular, we may identify certain usage data when you browse or click on content.

4.4. The following information and Personal Data are collected by means of Cookies and similar Technologies:

  • (i) the IP address of the device capable of connecting to the Internet and requesting the connection;
  • (ii) the date and time of the connection;
  • (iii) the location, if activated on the device;
  • (iv) the resources you access on the Website;
  • (v) the name and URL of the file accessed;
  • (vi) the website/application from which the connection was established (reference URL);
  • (vii) the browser you are using and, if necessary, the operating system of your device capable of accessing the Internet, as well as the name of your access provider.

4.5. To control/limit the collection of this information, you may:

  • (i) where available, set your browser to refuse all Cookies and similar Technologies or to indicate when a Cookie or similar Technology is being used; or
  • (ii) delete Cookies and similar Technologies and clean up your browsing data directly from your browser settings.

If you do not accept certain Cookies or similar Technologies, you may not be able to access certain features of our Website, in particular the various videos available on it.

4.6. List of Cookies and similar Technologies we use on the Website:

  • Designation: "wisecc", "wiseec" and "i18n_redirected".
    Supplier: wise.net
    Function: Recording of the user's language preferencesExpiration: No expiration, are deleted when the cookies are deleted in the browser
    Type: Necessary/functional cookies
    Country : Switzerland
  • Designation: "VISITORINFO1LIVE" and "YSC
    Supplier: youtube.com
    Function: Playback of videos downloaded from the platform
    Expiration: When the videos are deleted from the platform (6 to 13 months for the two types of Cookies indicated opposite)
    Type: Optional Cookies
    Country: United States
  • Designation: "_cfbm", "vuid", "hasuploaded", "vimeogdproptin", "authredirect", "player", "language", etc.
    Supplier : vimeo.com
    Function: Plays videos downloaded from the platform
    Expiration: For temporary cookies, when the browser is closed; For persistent cookies, until they expire or the cookies are deleted in the browser settings.
    Type: Optional cookies
    Country: United States

2. For what purposes do we collect information using Cookies (purposes)?

4.7. We use Cookies and similar Technologies that we collect in order to:

  • (i) authorise access to our Website and ensure the proper functioning of the latter;
  • (ii) make available certain features of our Website and to provide you with additional functionality;
  • (iii) to improve the Website and our pages available on social networks;
  • (iv) to ensure the security of the Website;
  • (v) to create statistics on the use of our Website in order to improve it.

3. Reason for treatment

4.8. With regard to Cookies and similar Technologies that are necessary for the operation, maintenance and security of our Website, the grounds on which we justify the processing of your Personal Data is our overriding private interest in the operation of our Website and its functionalities.

4.9. With regard to Cookies and similar Technologies used for statistical purposes in connection with our Website, the basis on which we justify the processing of your Personal Data is your consent, obtained by means of the Cookies banner displayed on the Website.

C. Personal data you provide to us

1. What Personal Information do you provide to us?

4.10. We collect Personal Data from you on a voluntary basis when, through our Website, you:

  • (i) browse our Website ;
  • (ii) visit our dedicated pages on LinkedIn, YouTube and/or Vimeo;
  • (iii) fill in a form enabling you to contact us, such as an interest form and/or an event or training registration form;
  • (iv) complete a survey;
  • (v) contact us through a representative, advisor or other authorised person who provides us with information about you for the purpose of establishing a relationship;
  • (vi) make your personal data available in the public domain or when it is communicated to us by third parties.

4.11. This Personal Data may include your surname, first name, date of birth and nationality, e-mail and postal addresses (home and/or business; i.e. address, postcode, town and country), telephone number (private, home and/or business), the name of the organisation for which you work, the name of your employer and the position held (title and function), as well as your invoicing details.

2. For what purposes do we collect this Personal Data (purposes)?

4.12. We use the Personal Data you provide for the following purposes:

  • (i) marketing and communication about the activities and services offered by the Company, including the sending of documentation relating to a training course, event or conference organised by us, in particular a Save the Date, an invitation, information about the opening of registrations or a brochure;
  • (ii) registration (temporary, via an expression of interest, or firm) for a training course, event or conference organised by us;
  • (iii) distribution of our newsletter and/or addition to our mailing list;
  • (iv) downloading or ordering a WISE product, such as books.

3. Grounds for treatment

4.13. The grounds on which we justify the processing of your Personal Data are:

  • (i) marketing and communication about the activities and services offered by the Company, including the sending of documentation relating to a training course, an event or a conference that we organise, in particular a Save the Date, an invitation, information about the opening of registrations or a brochure: your consent;
  • (ii) registration (temporary, via an expression of interest, or firm) for a training course, event or conference organised by us: your consent;
  • (iii) distribution of our newsletter and/or addition to our mailing list: your consent;
  • (iv) downloading or ordering a WISE derived product, for example books: your consent or the existence of a contract or pre-contractual relationship.

5.1. This Privacy Policy does not cover how your Personal Information is handled by third parties when we link to their websites. We encourage you to read the privacy policies of the other websites you visit.

5.2. When you establish a connection with a social network or other website, your browser connects directly to the server of the service provider concerned. Through this connection, the website receives the information accessed by your browser on the corresponding page of our Website or on our pages available on the social networks. This information (including your IP address) is transmitted from your browser directly to the service provider's server and stored there. If you interact with our pages available on social networks, for example by clicking on the "Like" or "Share" icon, this information will also be transmitted directly to the server of the provider of the social network concerned and stored there.

5.3. Please refer to the privacy policy of the social network or website concerned for any information relating to the purpose and scope of the collection of Personal Data by the service provider concerned, the subsequent processing and use of such Personal Data by the service provider concerned, as well as the rights associated therewith and the adjustment options to enable the protection of your Personal Data.

6. Communication of your personal data to third parties

6.1. We may give access to the Personal Data that you have communicated to us through our Website or our pages available on social networks to certain independent co-contractors and affiliated companies in order for them to assist us in the operation of said Website or said pages available on social networks. To date, these co-contractors are as follows:

  • (i) third parties duly appointed to assist us in the performance of service mandates, located in Switzerland and Italy in the context of mandates requiring the intervention of a communications agency;
  • (ii) multiple partners for training, events or conferences, located in Switzerland;
  • (iii) companies that we appoint to maintain the security of the personal data that we collect, manage and store, in particular the company Aminima, located in Switzerland, or the trustee in charge of the accounts, located in Switzerland.

6.2. We take all necessary steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and applicable law. All our co-contractors undertake to protect Personal Data using procedures similar to ours, unless otherwise provided for in this Privacy Policy.

6.3. The purpose of sharing your Personal Data with the aforementioned third parties is to operate our business and to maintain and seek to constantly improve our Website and the services offered to our users. Thus, the justification for this processing is that of our overriding private interests.

7. Communication of your personal data to the authorities

7.1. We may disclose your Personal Information (including your communications) if we consider this necessary for security reasons, to investigate a potential breach or other violation of this Privacy Policy and/or to prevent harm to other users of our Website or social network pages. Consequently, we may need to communicate your Personal Data in order to investigate, respond to or resolve a complaint or dispute in relation to our Website or one of our pages available on a social network.

7.2. We may be required to disclose your Personal Information where we are required to do so by law or where we believe in good faith that such disclosure is necessary in order to:

  • (i) to investigate, prevent or take action in relation to potential or actual illegal activities or to assist administrative enforcement authorities;
  • (ii) perform any agreement between us and you; or
  • (iii) to investigate and defend ourselves against a complaint or allegation from a third party;
  • (iv) to protect the security and integrity of our Website or our social networking pages; or
  • (v) exercise and protect the rights and safety of our users, employees or others.

7.3. We will endeavour to notify users of third party requests for their Personal Data where this is appropriate in our view and where it appears technically feasible to do so, except where we are prohibited from doing so by law or by a decision of an authority or where the request is urgent. We may contest such requests where, in our sole discretion, we consider that they are too broadly worded, too vague or unfounded, but we do not guarantee to contest any request.

7.4. The purpose of sharing your Personal Data with the above-mentioned authorities is to meet our obligation to comply with a legal obligation to which we are subject.

8. No communication of your Personal Data for commercial purposes

8.1. We do not sell your Personal Data to third parties. We do not share or otherwise make available your Personal Information to third parties, except as otherwise provided in this Privacy Policy.

9. Cross-border communication of personal data

9.1. If, as a result of certain services provided by third parties, we are required to transfer your Personal Data to one of their databases outside the European Economic Area, and/or Switzerland, potentially to a State which does not have a level of protection of Personal Data comparable to that prevailing in Switzerland or the European Economic Area, unless otherwise provided for in this Privacy Policy, we undertake to enter into an agreement with the third party service provider in order to ensure an adequate level of protection of your Personal Data.

10. Protection of your personal data and notification of a personal data breach

10.1. We undertake to use all commercially reasonable means to prevent any exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (including administrative, physical and technical measures) to manage cases of unauthorised disclosure or exposure of your Personal Data.          

10.2. In the event of an actual or suspected Personal Data breach, we will (i) use our best efforts to notify you without delay, where technically feasible, and (ii) cooperate with you in investigating and resolving the breach, including but not limited to providing reasonable assistance in notifying affected third parties. We undertake to give you access, without delay and within the limits of a reasonable request, to our files relating to the breach of your Personal Data, provided however that this does not give you access to files which belong to other users or which could compromise their security.

10.3 In the event of an actual or suspected breach of Personal Data, we undertake to notify the competent authority under the applicable law.

11. Management of your personal data (your rights)

11.1. Right to access, update and delete your Personal Data: As far as possible, you may access, update or request the deletion of your Personal Data by contacting us by sending an e-mail to the following address: contact@wise.net.

11.2. Right of rectification: You have the right to obtain rectification of your Personal Data if it is inaccurate or incomplete.

11.3 Right to object: Within the limits of the law, you have the right to object to the processing of your Personal Data.

11.4. Right to limit processing: Within the limits of the law, you have the right to obtain a limitation of the processing of your Personal Data.

11.5. Right to portability of Personal Data: You have the right to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format.

11.6 Right to withdraw consent: Within the limits of the law, you have the right to withdraw your consent at any time where the processing of your Personal Data is based on your consent. It should be noted, however, that such withdrawal: (i) does not affect the lawfulness of any processing carried out prior to such withdrawal and based on your consent; and (ii) may result in you no longer being able to use certain features of the Website or our pages on social networks.

11.7 Right to complain to an authority: You have the right to complain to any competent authority about the collection and use of your Personal Data.

11.8. We may ask you to prove your identity before responding to a request based on the aforementioned rights or otherwise related to your Personal Data.

12. Retention of your personal data

12.1. We retain the Personal Data you provide to us to the extent required to access and use our Website and our social network pages and the features on them (such as interest forms or registration forms for training, events or conferences), as well as to the extent necessary to comply with our legal obligations (for example if we are required to retain your Personal Data under applicable law), to resolve a dispute or to enforce our agreements and internal policies.

12.2. The retention period for Cookies and similar Technologies depends on their purpose and is always the same regardless of who the Personal Data relates to.

12.3. We reserve the right to retain data in a de-identified (i.e. anonymous) form after the deletion of your Personal Data.

13. Security of your Personal Data

13.1. We attach great importance to the security of your Personal Information. However, no method of communication over the Internet or method of electronic storage can guarantee 100% security. Consequently, although we endeavour to use commercially acceptable technical and organisational means to protect your Personal Information, we cannot guarantee its absolute security.

14. Personal Data relating to children

14.1 We do not provide services specifically aimed at children via our Website and we do not proactively collect Personal Data relating to them.

15. Changes to this Privacy Policy

15.1 We may change this Privacy Policy at any time by posting a new version on this page or on a deeper page without prior notice. If we do so, we will notify you by posting a notice on the home page of our Website. By continuing to access or use our Website or our pages available on social networks after the entry into force of this modification, you acknowledge and accept the processing of your Personal Data in accordance with the revised Privacy Policy. If you do not agree to these changes, please do not use our Website or our pages available on social networks.

15.2. We undertake always to process your Personal Data in accordance with the Privacy Policy in force at the time the Data is collected.

15.3. The new version of the Confidentiality Policy comes into force on the day of its publication, the day mentioned at the top of this Confidentiality Policy corresponding to the date of entry into force.

16. Question ?

16.1. Please do not hesitate to contact us by e-mail at contact@wise.net if you have any questions in relation to this Privacy Policy.

16.2. You may also contact us by post at the following address: Place de Cornavin 2, CP 2124, 1211 Geneva 1.