At Reynov Financial Solutions (referred to as “RFS,” “we,” or “us”), this Privacy Policy outlines how we collect and handle personal data. Please note that this document does not cover all possible scenarios of data processing. In certain cases, other privacy policies may apply.

For the purposes of this Privacy Policy, “personal data” refers to any information that can identify, or reasonably be used to identify, a natural person.

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If you share personal data belonging to third parties (e.g., family members or colleagues), please ensure they are informed about this Privacy Policy. Only share such information if you have the necessary authorization and ensure its accuracy before providing it to us.

This Privacy Policy adheres to the EU General Data Protection Regulation (GDPR) and the Swiss Data Protection Act (DPA). However, the relevance of these laws is determined by the specific circumstances of each case.

 

Data Controller

 

The entity responsible for data processing as outlined in this Privacy Policy (referred to as the "controller") is:

 

Reynov Financial Solutions
Albisriederstrasse 30
8003 Zurich
Switzerland
 

Sergey Reynov  

+41 44 508 13 89
sergey@reynov.ch

 

Should you have any inquiries about the processing of your personal data or any other data protection-related concerns, please feel free to reach out to us using the contact information provided above.

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Purpose of Data Processing and Legal Bases

 

The primary purpose of collecting and processing data is to enter into and fulfill agreements with our clients, business partners, and employees. This includes delivering financial services to our clients and managing the procurement of goods and services from suppliers and subcontractors. Additionally, we process personal data to meet legal obligations both domestically and internationally.

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Where permitted by law and when appropriate, personal data may also be processed for the following purposes:

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• Enhancing and providing our products, services, websites, apps, and other platforms in which we participate.

• Communicating with third parties and managing their inquiries (e.g., job applications, media requests).

• Conducting advertising and marketing activities (including organizing events), provided you have not objected to such use of your data. If you are a client and receive advertising materials, you may opt out at any time, and your details will be added to a suppression list to prevent further advertising communications.

• Asserting legal rights and defending against disputes, litigation, or official proceedings.

• Investigating and preventing criminal activities or other forms of misconduct.

• Maintaining the functionality and security of our IT systems, websites, apps, and other infrastructure.

 

 

Collection and Processing of Personal Data

 

Reynov Financial Solutions primarily processes personal data collected directly from clients, business partners, and other individuals during the course of business relationships. We also gather data from users while they interact with our websites, apps, and other digital platforms.

 

When allowed, we may also obtain personal data from publicly available sources (e.g., debt registries, land registries, commercial registries, press, or online platforms) or from third parties such as affiliated companies, authorities, or intermediaries (e.g., business introducers or custodian banks).

 

In addition to data you provide directly, we may receive the following categories of data from external sources:

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• Information from public registries.

• Data acquired in administrative or legal proceedings.

• Details regarding your professional role or activities (e.g., necessary for contracts involving your employer).

• Information obtained through correspondence or discussions with third parties.

• Data provided by individuals connected to you (e.g., family members, consultants, or legal representatives) to facilitate contracts or transactions (e.g., powers of attorney).

• Information related to compliance with legal obligations (e.g., anti-money laundering checks).

• Bank account details.

• Information about you from media outlets or internet sources, where applicable (e.g., for job applications, media reviews, or marketing purposes).

• Your contact details and address.

• Data associated with your use of our websites, such as IP address, MAC address (from your smartphone or computer), device and settings data, cookies, timestamps, visited content and pages, used applications, referring website, and location information.

 

In general, we retain personal data for up to 12 months following the fulfillment of its processing purpose. However, retention may be extended if required for legal, contractual, or evidentiary purposes.

 

 

Cookies, Tracking, and Information Related to Website Usage

 

Technical Data
 

When you access our website, we collect and analyze user-specific information (e.g., IP address, browser type, operating system) and technical data (e.g., accessed URLs, search queries performed) in an anonymized format. This data is used to enhance system security, ensure stability, conduct error and performance analysis, and for internal statistical evaluations, enabling us to continuously optimize our website.

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If you subscribe to content, submit a contact form, or log in to a customer account, we process the data necessary to deliver the requested service. Depending on the service, this data may include:

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• Email address

• First and last name

• Salutation

• Full address

• Subject and message details

 

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Communication Data

When you reach out to us via contact form, email, phone, chat, letter, or other communication channels, we process the exchanged information, including your contact and communication details. Should we record or monitor phone calls or video conferences for training or quality assurance purposes, you will be notified beforehand. Such recordings are made and utilized in compliance with our internal policies and applicable laws.

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We generally store this data for 12 months following the last interaction. However, retention periods may be extended to meet evidentiary requirements, legal or contractual obligations, or for technical reasons:

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• Emails in personal mailboxes and written correspondence are typically retained for at least 10 years.

• (Video) conference recordings are generally stored for 24 months.

• Chat records are usually retained for 2 years.

 

Cookies and Their Usage

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To better tailor our services to your needs, we utilize "cookies" on certain occasions. Cookies are small files stored on your computer or mobile device when you access or use our websites. They do not perform any independent operations but rather store specific settings via your browser and gather data about your interactions with the site. When activated, a cookie is assigned a unique identifier that recognizes your browser and allows the stored data to be utilized.

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There are two main categories of cookies: temporary cookies and permanent cookies.

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• Temporary cookies are automatically removed from your device at the end of your browser session.

• Permanent cookies store user preferences, such as language settings or auto-login options, and remain on your device for an extended period before being automatically deactivated.

 

You can configure your browser to reject cookies, accept them only for a single session, or delete them prematurely. While most browsers are preset to accept cookies, blocking them may result in limited functionality for certain features (e.g., language preferences, shopping cart, or order processes).

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We also allow partner companies that support RFS services or are integrated into our website to use cookies, provided they are technically necessary and their usage is proportionate. However, RFS does not control the use of cookies beyond our own website.

By continuing to use our website and/or accepting this Privacy Policy, you consent to the use of cookies and the collection, storage, and usage of personal browsing data, including through the use of permanent cookies after the session ends. You may revoke this consent at any time by adjusting your browser settings to reject third-party cookies.

 

Google Analytics and Comparable Services

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To design and optimize our website in line with user needs, we may utilize Google Analytics or similar tools. These analytics services are offered by third-party providers, which could operate from any country globally. In the case of Google Analytics, the provider is Google Ireland Ltd. (Ireland), which uses Google LLC (USA) as its sub-processor (collectively referred to as "Google"). More information about Google can be found at www.google.com.

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These tools help us analyze website usage in an anonymized manner by employing permanent cookies set by the service provider. To protect your privacy, we configure Google Analytics to truncate IP addresses of visitors within the EU/EEA before transmitting the data to the United States, rendering the data untraceable to individual users. Additionally, we have disabled the "Data Sharing" and "Signals" options in our configuration.

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While we believe the shared information does not constitute personal data for Google, it is possible that Google could deduce visitor identities based on the collected data, build personal profiles, and associate this information with registered Google accounts for its own purposes. If you are logged into your Google account while browsing, Google will know your identity. In such cases, the service provider processes your personal data in accordance with its own privacy policies.

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It is important to note that the service provider shares only anonymized usage statistics with us, and no personal data about you is transmitted.

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Creation of Pseudonymized User Profiles and Data Analysis

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When using our website, pseudonymized user profiles are generated through the use of small text files, known as cookies, which are stored on your computer. The data collected by these cookies about your website activity is transmitted to servers operated by our service providers, where it is processed on our behalf. In addition to the data outlined previously, the following information may also be collected:

 

• Navigation path taken by the visitor within the website.

• Time spent on the website or specific subpages.

• The subpage from which the visitor exits the website.

• Geographic location of access (country, region, or city).

• Details about the visitor’s device (e.g., type, version, color depth, screen resolution, browser window dimensions).

• Information on whether the visitor is new or returning.

 

The tools and services we employ for analyzing web behavior include Google Analytics, Google Tag Manager, Google Ads, YouTube (embedded videos), Userlike, and MailChimp.

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For instance, when using Google Analytics, information (including your IP address) generated by the cookie is transmitted to a Google server in the United States. Google evaluates this data to generate reports on website usage and activity, and provides related services to us as the website operator. Google may share this data with third parties if legally required or if such third parties process the data on Google’s behalf. Importantly, Google does not associate your IP address with any other data it holds.

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You can manage or block the installation of cookies through your browser settings. However, please note that certain features of our website may not function optimally if cookies are disabled. By continuing to use this website, you consent to the processing of the data collected about you in the manner and for the purposes outlined above.
 

Integration of Social Media Plug-ins

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Our website includes plug-ins from various social media platforms, such as LinkedIn, YouTube, and others. These plug-ins can be identified by their respective icons or symbols. By default, these elements are deactivated on our website. If you choose to activate them by clicking on the corresponding icon, the operators of the respective social media platforms may collect data, including information about your visit to our website and the specific pages accessed. This information may be used by the social media providers for their own purposes.

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Please note that the processing of your personal data in this context is managed solely by the respective platform operator and is subject to their individual privacy policies. We do not receive any information about you or your activity from these social media providers.

 

 

Data Sharing with Third Parties and International Transfers

 

As part of our business operations and in accordance with the purposes of data processing outlined earlier, we may share data with third parties when permitted and necessary for processing data on our behalf or for their own purposes. The following categories of recipients may be involved:

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• Service providers (e.g., Risk Management & Compliance, IT providers, CRM system)

• Domestic and international authorities, government agencies, and courts

• Parties involved in ongoing or potential legal proceedings

• Custodian banks or brokers

• Business introducers

• Authorized individuals with power of attorney or information access rights

 

Some recipients are based in Switzerland, while others may be located in various countries around the world. This includes countries in Europe and the United States where our service providers operate, such as Microsoft.

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If a recipient is based in a country without adequate data protection laws, we require them to comply with data protection standards, typically through the use of the European Commission’s updated standard contractual clauses (accessible here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?). Exceptions to this requirement may apply in certain situations, such as legal proceedings abroad, overriding public interest, contractual disclosure obligations, your consent, or when data is publicly available, and you have not objected to its processing.

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Data Retention Period

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We will process and retain your personal data only for as long as necessary to fulfill our contractual obligations, comply with legal requirements, or for the specific purposes outlined in our data processing activities. This may extend through the duration of our business relationship and beyond, depending on legal retention periods and documentation obligations.

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In certain cases, personal data may be retained for as long as claims can be made against our company, or if we are legally required to do so, or if legitimate business interests require it (e.g., for evidence or record-keeping purposes). Once the data is no longer necessary for these purposes, we will delete or anonymize it to the extent possible. For operational data (e.g., system logs), retention periods of 30 days or less may apply.

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Data Security

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We have implemented appropriate technical and organizational measures to safeguard your personal data from unauthorized access and misuse. These measures include providing instructions, staff training, IT and network security solutions, access controls and restrictions, as well as encrypting passwords, data storage devices, and transmissions, and applying pseudonymization techniques.

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Please note that while we take every precaution, we cannot guarantee the absolute security of data transmitted over the internet. When transmitting data by email, there is a risk that third parties may gain unauthorized access.

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Your Rights

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As per applicable laws, you have the right to access, correct, or delete your personal data. You may also request a restriction of processing or object to the processing of your data, particularly for direct marketing, profiling related to direct marketing, or other legitimate processing purposes. You are also entitled to receive certain personal data for transfer to another controller (data portability).

Please note, however, that statutory restrictions may apply, such as the requirement to retain certain data or when we have an overriding interest or need the data for legal claims.

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You have the right to withdraw your consent at any time. Keep in mind that exercising your rights may affect your contractual obligations and could lead to consequences such as early termination of the contract or associated costs. If this is the case, we will notify you unless otherwise agreed in the contract. Generally, to exercise your rights, we may require proof of your identity (e.g., a copy of your ID) if your identity cannot be verified in another way. To assert your rights, please contact us using the details provided above.

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Additionally, every data subject has the right to bring a case to court or file a complaint with the relevant data protection authority. In Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

 

 

Profiling

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We may process certain personal data about you automatically for the purpose of evaluating particular personal characteristics (profiling). Profiling helps us provide more targeted advice and recommendations regarding products that may be relevant to you. To do so, we may use tools that enable us to communicate with you and offer tailored advertisements, including for market research and opinion surveys.

 

 

Changes to this Privacy Policy

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We reserve the right to modify this Privacy Policy at any time, without prior notice. The most current version will always be available on our website. If this Privacy Policy forms part of a contractual agreement with you, we will notify you of any changes through email or other suitable means.​