Privacy Policy.

1. Data controller

Galloni Holding SA, Route de Morges 36, 1162 St-Prex, Switzerland — registered with the commercial registry of Canton Vaud. Contact for any privacy matter: info@galloni-holding.ch.

2. Personal data we collect

We collect the data you provide directly (when you use the contact button, complete the SUM funnel for a domiciliation contract, or correspond with your advisor) and a limited set of technical data when you visit the site.

• Identification: name, professional title, company name, address
• Contact: email, telephone
• KYC: identity document, beneficial ownership, source of funds (only if a contract is concluded)
• Correspondence: the content of your messages and incoming postal mail you authorise us to handle
• Technical: IP address, browser type, pages visited, referrer — only after consent through the cookie banner

3. Purposes and legal bases

We process your data only for the following purposes, on a clear legal basis:

• Performance of the domiciliation contract — Art. 31 al. 2 let. a revFADP / Art. 6(1)(b) GDPR
• Compliance with Swiss legal obligations (KYC, tax, RC) — Art. 31 al. 1 revFADP / Art. 6(1)(c) GDPR
• Legitimate interest (security of the site, fraud prevention) — Art. 31 al. 1 revFADP / Art. 6(1)(f) GDPR
• Consent for analytics and Google Ads tracking via the cookie banner — Art. 31 al. 1 revFADP / Art. 6(1)(a) GDPR

4. Recipients and international transfers

Personal data is shared only with: our internal staff bound by confidentiality; the notary, fiduciary or counsel coordinated for your file (with your consent); and Google Ireland Limited for the Google Ads tag, when you have accepted the cookie banner. Google may transfer data to the United States under Standard Contractual Clauses approved by the European Commission and recognised by Switzerland.

5. Retention

Contractual data is kept for 10 years after the end of the engagement, as required by the Swiss Code of Obligations. Marketing data (analytics) is kept for 14 months. Correspondence is archived per the agreement (typically 12 months for opened mail, 36 months for contractual exchanges).

6. Your rights

You may exercise the following rights at any time by writing to info@galloni-holding.ch:

• Right of access to your data
• Right to rectification of inaccurate data
• Right to deletion (when no legal retention applies)
• Right to data portability
• Right to object to processing based on legitimate interest
• Right to withdraw consent at any time (cookie banner reopener in the footer)
• Right to file a complaint with the Federal Data Protection and Information Commissioner (FDPIC, Bern) or, for EU residents, your national supervisory authority

7. Cookies

Strictly necessary cookies (session, security) are set without consent. All other cookies — Google Ads conversion tag — load only after you accept through the banner. You may revoke your choice at any time via the cookie settings link in the footer; gtag will then revert to denied state and stop placing identifiers on subsequent pages.

8. Updates

This policy is reviewed annually. The current version is effective as of 1 January 2026. Material changes are notified by email to active clients.