Privacy Policy

Respecting your privacy is important to us. As data controller, GOLD Business Time Sàrl undertakes to process the personal data that you communicate to us in complete transparency and in compliance with applicable law.

GOLD Business Time Sàrl, hereinafter referred to as “GBT”, “we” or “our”, is a limited liability company registered in the commercial register and having its registered office at avenue de la Gare 39, 1260 Nyon, Switzerland.

Our representative in the EEA is [ to be completed ]. [BL1] The following guidelines apply to any data you provide to GBT.

This privacy policy (the “Policy”) is dated [ to be completed ]. It may be revised at regular intervals (see article 11).

By accessing the website www.buyinggold.ch (the “Site”), which we operate, you expressly agree that we process your data in accordance with the Policy.

For any request relating to the Policy or the use of your data, we invite you to contact us at the following address: [email protected] or by telephone at +41 (0)22 362 01 01.

We also invite you to consult our Terms of Use as well as our General Terms of Sale. [BL2]

1.    What is meant by personal data?

Personal data (the “Data”) means any Data that relates to an individual. Such Data may either allow you to be identified directly (for example, your first and last name, your email address or your social security number) or indirectly by cross-referencing various information about you (for example, the IP address of your computer, your credit card or telephone number).

2.    What type of Data do you communicate to GBT?

The Data that GBT automatically collects when you access the Site [BL3] or that you voluntarily communicate when creating your account or subsequently when placing orders are as follows (the fields preceded by an asterisk are necessary and the additional fields may be communicated at the user’s discretion, on an optional basis):

has.       *your name;

b.       *your first name;

c.       *if applicable, the name or business name of the company you represent;

d.       *your home address, or the head office of the company you represent;

e.       *your date of birth;

f.         *Your email address ;

g.       *your phone number;

h.       *your credit card number, which is however immediately deleted once the transaction has been completed;

i.         any personal information that you spontaneously communicate to us during email exchanges;

j.         *identification and authentication data, particularly when using our online stores (technical logs, computer traces, information on security and use of the terminal, IP address); [BL4]

k.       [all other Data collected by cookies, and the web server ]. [BL5]

You will find more information about Data collected automatically in Article 10 of the Policy.

3.    Why does GBT collect this Data?

We process your Data only on the basis of legitimate grounds, among those clearly identified below, or on the basis of your consent:

has.       your first and last name and, if applicable, the name of the company you represent, to create your account and then allow you to access the Site and order the products we offer you there. This Data is necessary for the execution of the contract;

b.       your date of birth to ensure that you are of legal age and thus allow you to validly enter into contracts with us. This Data is processed on the basis of our legitimate interest in verifying your capacity to enter into a contract with us;

c.       your address, email address and telephone number so that we can contact you. This Data is necessary for the sale of products. When used to send you our newsletter or any other advertising communication, this use is based on your consent;

d.       your credit card number in order to validate that you have paid the price of the products ordered. This Data is necessary for the execution of the contracts concluded with you;

e.       Data transmitted by the Site’s cookies for internal analysis and statistics [BL6] . This Data is processed on the basis of our legitimate interest in improving our services and for advertising purposes, and with your consent when required by applicable law;

f.         All Data transmitted may be processed in order to comply with our legal obligations and other legal requirements.

For all cases where the above reasons cannot be considered a legitimate reason, you consent to the processing of Data for the purposes described above by approving this Policy .

Further data that does not allow you to be identified, including in an aggregated or anonymized manner, may be used to manage the services, improve customer relations, establish a diagnosis and manage problems of a technical nature as well as obtain demographic data in an aggregated form.

4.    Who can GBT share your Data with?

GBT may share your Data in the following ways:

has.       to any third party to whom we are required to communicate this Data following an injunction issued by a judicial or governmental authority or in accordance with our legal obligations;

b.       to any third party whose involvement is necessary to enable the proper performance of the services (for example our employees and affiliated companies, payment providers or logistics companies, our host and our IT specialists); [BL7]

c.       in the context of any merger, acquisition or restructuring operation in any form whatsoever, as well as in the event of any bankruptcy proceedings, your Data could be transferred to third parties as an asset of GBT. In this event, we will endeavor to the fullest extent possible to inform you of such transfers before they take place, but without being able to guarantee that you will have the possibility to oppose such a transfer.

In certain circumstances, in particular for technical or functional reasons, or in the context of relations with our subcontractors, your Data may be transferred outside Switzerland or the European Union. In this case [BL8] , the third parties to whom the Data are transmitted provide sufficient guarantees as to the implementation of appropriate technical and organizational measures so that the processing meets legal requirements and guarantees the protection of your rights.

By accessing the Site and transmitting Data to us, you expressly agree to such transfers.

5.    Where is your Data hosted?

The Data collected by GBT is hosted in Switzerland and processed by [ INFOMANIAK GROUPE SA ].

6.    How does GBT process your Data?

We may process your Data in an automated or non-automated manner, and in all cases take appropriate security measures.

We process your Data in accordance with applicable law, in particular Swiss Data Protection Law, and adopt appropriate security measures to prevent unauthorized access, disclosure, modification, alteration or destruction of your Data.

We may process your Data in order to remove any information that can identify you (anonymisation) and then use this anonymous Data for purposes not contemplated by the Policy (including for benchmarking, campaign targeting or to develop and market new services).

Our Site is committed to combating money laundering and the financing of terrorism. In accordance with applicable Swiss legislation, we implement strict due diligence measures to identify and verify the identity of our customers and their potential beneficial owner(s) when purchasing gold. All transactions are monitored to detect suspicious behavior, and we reserve the right to report any activity deemed suspicious to the competent authorities. By using our service, you acknowledge and accept these conditions, and you agree to provide accurate and complete information when registering and during your transactions.

7.    How does GBT protect your Data?

GBT makes every effort to ensure the security of your Data and thus avoid any undue access, use, modification or disclosure of the latter.

GBT also endeavours, as far as possible, to ensure that any third party to whom your Data is communicated (as described above) processes it securely to ensure its confidentiality and integrity.

In order to protect the confidentiality of your Data, it is your responsibility to keep your identifiers in a safe place known only to you and not to disclose them to anyone. You are responsible for any use that may be made of the services offered on the Site using your identifiers. We invite you to inform us immediately by email of any suspected or proven abuse of your identifiers. Remember, however, that no security measure whatsoever is infallible.

8.    How long does GBT keep your Data?

GBT retains your Data only for the time required to fulfill the purpose for which the Data in question was collected, which is in principle for 3 years from your last contact with GBT.

Given our legal obligations, certain information relating in particular to the contractual relationship between us and you must be kept for at least 10 years.

In any case, you are free to ask GBT to keep your Data for the purpose of possible re-registration, or to the extent necessary to continue receiving our newsletter.

Instead of destroying or erasing your Data, GBT may, where appropriate, decide to permanently anonymize them so as to make your identification impossible.

9.    What are your rights in relation to your Data?

You have the right to know what Data we process about you and to request, under certain conditions, that it be deleted, corrected or updated.

Unless otherwise provided by applicable law, you have the right at any time to know whether we are processing Data concerning you and to exercise your right of access, in accordance with Art. 25 DPA. You can contact us to know the content of this Data, verify its accuracy, and to the extent permitted by applicable law, in particular Art. 32 DPA, request that it be completed, updated, rectified or deleted. You also have the right to ask us to stop any specific processing of Data that may have been obtained or processed in violation of applicable law, and to object to any processing of Data in the event of legitimate grounds.

If you would like us to delete your Data from our systems, you can send us a request using the contact details below, which we will comply with unless we are required to retain your Data for a legal or other legitimate reason.

When we rely on your consent to process your Data, we will obtain your freely given and specific consent by providing you with as much specific information as possible. You may revoke your consent at any time.

You also have the right to request the portability of your Data processed in an automated manner on the basis of your consent or contractual necessity, i.e. that the Data you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format, without hindrance from us, subject to our confidentiality obligations and within the limits of applicable law, in accordance with Articles 28 and 29 LPD.

For more information on the extent of your rights or to exercise them, we invite you to contact us at: [email protected].

You have no legal or contractual obligation to transmit Data to us. However, refusing to transmit certain Data or exercising the rights mentioned in this Article 9 of the Policy may, where applicable, no longer allow us to provide you with our products, including access to the Site.

10.    Cookies [BL9]

10.1.    What are cookies?

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website. Cookies may automatically process Data on your electronic device and/or transfer Data about you to the owner of the website or to third parties, including Google Analytics. This solution allows us to analyze the use of the Site and generate consultation statistics. Google’s privacy policy can be accessed at https://policies.google.com/?hl=fr&gl=fr .

10.2.    You can manage the cookies used by the Site

We ask you to expressly accept the use of cookies when you access the Site. You are free to refuse cookies while accepting this Policy. [BL10]

You can then manage cookies at any time, and therefore revoke your consent to them, via the settings of your internet browser and/or your electronic device.

We draw your attention to the fact that certain cookies are essential to the operation of the Site and that its use could be altered in the event of refusal or total blocking.

For more information, you can visit https://gdpr.eu/cookies/. You can also consult the help section of your internet browser or electronic device for more specific instructions on managing cookies.

10.3.    How and why do we use cookies?

We use cookies to improve the use and operation of our Site as well as for the use of the web application. Storing cookies on your computer is an easy and convenient way for us to personalize or improve your browsing on our Site and to make your next visit more enjoyable.

10.4.    What types of cookies are used? [BL11]

The cookies we use are:

The categories of cookies are explained below:

has.       Necessary cookies

These are the cookies that are strictly necessary for the operation of our Website. Without these cookies, our Site would not function properly.

b.       Functional cookies

These are cookies that are used to improve the functioning of our Site. For example, cookies that remember the content you have previously viewed on our Site or the email address and password you provided to register during a previous visit to our Site. The use of functional cookies can therefore allow us to provide personalized content based on your interests and save you time from having to register again or re-enter information when you visit our Site again. We also use cookies for the purposes of analyzing our Site or for advertising purposes.

c.       Statistical cookies

These cookies help us understand how visitors interact with our Site by providing information about the pages visited, the time spent on the Site, and any issues encountered, such as error messages. This helps us improve the performance of our Site.

d.       Third-party cookies

These are cookies that are set by third parties that we use for various services (for example, for Site analysis or advertising purposes). GBT uses Google Analytics cookies. [BL12]

Google Analytics uses cookies to provide information about what users do when they visit our Site. Cookies do not identify individuals; they are defined by a combination of computer, user account and browser. However, Google Analytics cookies do not collect Data about visitors to the Site. For more information about Google Analytics, please click on the following link: https://support.google.com/analytics/answer/6004245?hl=en.

11.    Update of legal information

We reserve the right to make any changes and corrections to these provisions. Please check this page regularly for changes and new information.

[BL1] To be discussed if necessary. We understand that only Swiss residents or legal entities with their headquarters in Switzerland will be able to order products on the Site. Please confirm.

[BL2] Provide links to the Terms of Use and the General Terms and Conditions of Sale.

[BL3] Please confirm if there is any data collected automatically in addition to the data provided by customers to create an account and/or place an order.

This could include the following data:

IP address

Activity on the site (e.g. via software that allows you to see where the customer left off in the ordering process)

If so, letter (j) covers these situations.

[BL4] Please confirm.

[BL5] Please confirm.

[BL6] Please confirm, and this is very important, that you do not use cookies that enable behavioral advertising. Indeed, from a GDPR perspective, advertising cookies that allow identification of the data subject can never be based on the legitimate interest of Art. 6 para. 1 lit. f GDPR (e.g. cookies that enable behavioral advertising).

[BL7] In accordance with Art. 19 para. 2 lit. c nLPD, the recipients or categories of recipients to whom personal data are transmitted should be listed.

[BL8] In accordance with Art. 19 para. 4 nLPD, it is necessary to specify in which countries personal data are shared and, if applicable, if the country is not on the list of countries offering adequate protection according to Annex I nOPD ( RS 235.11 – Ordinance of 31 August 2022 on data protection (OPDo) (admin.ch) ), it should be specified which guarantees are in place according to Art. 16 para. 2 nLPD.

[BL9] To be checked, completed and validated by your IT specialist.

[BL10] Please confirm that this is the case.

[BL11] Please confirm/modify the cookies used.

[BL12] Please confirm.