1. Definitions

  • Abilene Advisors
    • AAb” means Abilene Advisors
    • Abilene Advisors is a Private Limited Company located at Rue des Charpentiers 24A 1110 Morges Switzerland
    • Abilene AcademyTM  (“AAc”) is a registered brand of AAb
  • Legal basis
    • GDPR : European General Data Protection Regulation
    • FADP : Federal Act on Data Protection, 235.1, 1992/06/19
  • Data Controller : Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
  • Data Processor : Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.
  • Data Subject : Data Subject is any living individual who is using our Service and is the subject of Personal Data.

2. Principles of processing personal data

Our principles for processing personal data are:

  • Lawfulness, fairness, and transparency:
    • We process your personal data in strict adherence to the law
    • We process your personal data in a way you would reasonable expect based on what we express in this privacy policy
    • We are always open and transparent about our data protection practices
  • Purpose limitation:
    • We only process personal data for the specific reason we collected it and nothing else.
  • Data minimization:
    • We do not process any more data than we need.
  • Accuracy:
    • We make sure that any personal data we hold is adequate and accurate.
  • Storage limitation:
    • We do not store personal data for longer than we need to. As a general rule, we will hold your personal information for a period up to 7 years from the end of your relationship with AAb.
  • Integrity and confidentiality:
    • We always process personal data securely (see section 7).

3. What personal data we collect and process

AAb collect several different types of personal data. It includes :

  • Your email address
  • Your first and last name
  • Your phone number

We also collect cookies and other data in relation to the enhancement of your user experience.

4. Why and how we use your personal data

AAb uses your personal data for the following purposes :

  • to provide you with the latest information about our services
  • to notify you about changes to our services and products
  • to provide you with customer support
  • to gather information to be analyzed so we can improve our products and services

AAb uses your personal data in the following way :

  • building databases of prospects that we can analyze and consult for the purpose of including you in our marketing campaigns
  • analyzing trends and tracing user movements on our site

5. Legal basis for collecting and processing your data

AAb legal basis for collecting and processing the personal data presented in this Privacy policy is supported by

  • the need to enter in a contractual relationship with you, shall you decide to register as a user on our website
  • the consent you have given to us (see section 10 for your right to withdraw consent) when entering your personal data on our website
  • our legitimate commercial interest in accordance to the GDPR and the FADP
  • our necessity to comply with the GDPR and the FADP

6. Retention of your personal data

AAb will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy or until you decide to exercise your right to be forgotten.

AAb will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

7. Keeping your information secure

We take appropriate measures to ensure your personal data is held confidentially and with integrity in our systems. Our staff are trained in the correct procedures for managing and handling data and our processes are regularly reviewed. Our systems hold data securely – protecting your data in a range of ways including secure servers, firewalls and encryptions. Industry standard compliance requirements are followed. Data is held in restricted, password controlled access to information which is stored on our systems.

Where we work with third parties (data processors) who may store and process your data via a third party system (for example our email marketing tool or our external storage servers), we ensure our suppliers are compliant with the current regulations and have proper systems and processes in place to fulfil their legal and contractual obligations.

8. Sharing your information with other organizations

We may share, with your consent, your personal data with 3rd parties in order to fulfill the service specified in your request, as it is explained to you at the time we collect your information or you give us your explicit consent to.

We may also use suppliers known as ‘data processors’ to process data on our behalf, for example, to send out mailings and fulfil orders. When enlisting the services of such suppliers we ensure that they are under a contractual obligation to only use your information in accordance with our instructions and for no other purposes. Otherwise, you will have to provide your personal information to these 3rd parties in order to obtain the services they offer.

9. International transfer of your personal data

AAb stores your personal data in servers located in Switzerland and the EU exclusively. If you are a resident of a Member State of the European Union, Switzerland is considered as a secure 3rd country, from the GDPR standpoint. Secure 3rd countries are those for which the European Commission has confirmed a suitable level of data protection on the basis of an adequacy decision. In those countries, national laws provide a level of protection for personal data which is comparable to those of EU regulation (GDPR art. 45 & COMMISSION DECISION of 26 July 2000 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data provided in Switzerland).

If organizations who work on our behalf manage information outside the EU, we will make sure that we have a valid reason for doing so under current Data Protection legislation and have relevant agreements in place with them.

10. Data protection rights of the data subject

As a data subject under the data protection legislation, you have the right to access the information we hold about you. If you wish to exercise this right, please send a Subject Access Request through email to our DPO (see email address below section 11 and postal address section 1) and specify

  • Your complete name and address
  • Your email address
  • Your preferred response format (post of email)
  • Other names you could have been known to us (if applicable)
  • Your relationship with us
  • The description of your request, the data protection right you wish to exercise and any information helping us to locate your personal data

Please attach/enclose a proof of your ID (scan or photocopy of an ID document)

Your other data protection rights are :

  • right of rectification
    • you can ask us to erase or rectify inaccurate or incomplete data
    • in compliance with the Swiss FDPA and the GDPR, we will reply to your request within a month after receipt of your request
  • right to erasure (right to be forgotten)
    • if you exercise your right to withdraw consent or your right to object processing, we will completely remove your personal data from our databases
    • in compliance with the Swiss FDPA and the GDPR, we will comply to your request within a month after receipt of your request
  • right to object processing
    • you have the right to refuse that we further process your data (i.e. do any of the actions listed in section 4)
    • in compliance with the Swiss FDPA and the GDPR, we will comply to your request within a month after receipt of your request
  • right to withdraw consent
    • you have the right to withdraw a consent previously granted at any time
    • in compliance with the Swiss FDPA and the GDPR, we will comply to your request within a month after receipt of your request
  • right to lodge a complaint
    • see section 12 below

11. Data Protection Officer

Exercising any of the rights of the data subject listed in section 10 is performed by sending a Request at dpo(a)abileneadvisors.ch or contacting our Data Protection Officer (DPO) :

Mr. Henri Haenni (+41 21 802 35 54)
Abilene Advisors
Rue des Charpentiers 24A
1110 Morges
Switzerland

12. Complaints

If you have any complaints about how we handle your personal data, please contact us so we can resolve the issue, where possible (see above).

If you need to make a complaint, please send a complaint at our DPO (see above section 11). We will acknowledge and provide an initial response to your feedback within 5 working days of receiving it. Whilst we expect to be able to resolve most complaints within that timeframe, if we need to conduct a more in-depth investigation, we’ll aim to provide you with a full response within 30 working days. If we’re unable to meet that deadline due to exceptional circumstances, we’ll let you know.

You also have the right to lodge a complaint about any use of your information with the Federal Data Protection and Information Commissioner (FDPIC) :

Office of the Federal Data Protection and Information Commissioner FDPIC
Feldeggweg 1
3003 Berne
Switzerland
Phone: +41 58 462 43 95 (mon.-fri., 10-12 am)

Or with the :

Autorité de protection des données et de droit à l’information Vaud
Rue Saint-Martin 6
CP 5485
1002 Lausanne
Switzerland
info.ppdi(a)vd.ch
Phone : +41 21 316 40 64 (mon.-thu., 10.30-12.30 am