Privacy Policy

1. Introduction

This Privacy Policy describes how we collect, use, and process your personal data when you visit our website or engage our services. We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the General Data Protection Regulation (GDPR).

2. Data Controller

The entity responsible for processing your data is: Lumaya SA, located at Rue de Gruyères 106, 1630 Bulle, Suisse, isabelle@lumaya.ch

3. Data Collection and Purpose

We collect personal data that you provide to us and technical data generated during your visit.

Contact Information: Name, email, phone number, and company details.
Identity & KYC Data: To ensure the qualification of potential buyers and comply with professional standards, we collect identity verification documents (KYC).
Contractual Data: Information related to the digital signing and management of Non-Disclosure Agreements (NDAs) required to access confidential business dossiers.
Technical Data: IP address, browser type, and cookies for website functionality and analytics.

Purposes of processing:

To provide our financial advisory and business brokerage services.
To verify the identity of potential counter-parties (KYC) before disclosing sensitive information.
To manage and enforce confidentiality obligations via NDAs.
To communicate regarding your inquiries.
To comply with legal and professional obligations.

4. Data Sharing and International Transfer

We do not sell your personal data. We may share data with third-party service providers (IT hosting, CRM, KYC verification, or legal advisors) who are contractually bound to confidentiality. Data is primarily stored in Switzerland or the EU. If data is transferred to a country without adequate protection, we ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.

5. Data Retention and Deletion

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected:

KYC Documents: Identity documents provided for buyer qualification are stored for a maximum period of 90 days after the verification process is complete, unless specific legal negotiations require a longer duration.
NDAs and Business Records: Signed NDAs and records of business transactions are retained for 10 years, in accordance with Swiss statutory retention periods for contractual documents.
General Inquiries: Data from general inquiries is deleted once the communication is concluded, provided no contractual relationship is established.

6. Your Rights

Under the FADP, you have the following rights:

The right to access the data we hold about you.
The right to rectify inaccurate data.
The right to request the deletion of your data.
The right to object to data processing or request a restriction.
The right to data portability.

To exercise these rights, please contact us at isabelle@lumaya.ch

7. Cookies and Analytics

Our website uses cookies to enhance user experience. You can manage your cookie preferences through your browser settings.

8. Security

We implement appropriate technical and organizational security measures to protect your data against unauthorized access, loss, or misuse.

9. Changes to this Policy

We reserve the right to update this policy at any time. The version published on our website is the current version.

10. Supervisory Authority

The competent authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

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