1. Data Controller

The data controller ("Manazelle", "we", "us") is [Manazelle legal entity name, e.g. Manazelle Sagl], with registered office at [registered address, Lugano, Switzerland], [CHE registration number]. For any questions regarding data protection, we can be reached at info@manazelle.com.

2. Scope of this Policy

This policy explains how Manazelle processes personal data of visitors to www.manazelle.com (the "Site"), whether simply browsing the Site or using the contact form, email or the phone number provided on the Site to enquire about our real estate and concierge services.

Where a client engages Manazelle for real estate, relocation or concierge services, any further processing connected to that engagement is governed by the relevant service agreement, which takes precedence for that specific relationship.

The Site may contain links to third-party websites. Manazelle is not responsible for the data processing carried out by those third parties, to which their own privacy policies apply.

3. Categories of Data Processed

In the ordinary course of operating the Site, our hosting and technical systems automatically collect certain data whose transmission is inherent to internet communication protocols: IP address; browser and operating system type and version, language settings; date, time and duration of the visit, pages viewed; referring site; status codes and technical data relating to the outcome of requests sent to the server.

Through the contact form, email or the phone number listed on the Site, you may provide us with: identification and contact details (full name, email address, phone number); the name of any company you represent and your role; and the content of your message, including a description of the real estate or concierge needs for which you are seeking a consultation.

In the course of providing real estate and concierge services, you may share with us additional information necessary to deliver the service (for example, property preferences, travel or lifestyle requirements, or introductions to third-party providers such as banks, schools or legal advisors). We process this data only to the extent necessary to deliver the requested service, and not for independent purposes.

4. Cookies and Similar Technologies

The Site uses only technical and strictly necessary cookies required for it to function correctly. It does not use cookies for advertising or profiling purposes.

You can configure your browser at any time to block or delete cookies; doing so may affect certain functions of the Site.

5. Purposes of Processing

Manazelle may process the data described above for the following purposes:

• operating and maintaining the Site;
• IT security, abuse prevention, and diagnosing or resolving technical issues;
• responding to enquiries and managing the related correspondence;
• presenting our real estate and concierge services and managing preliminary discussions ahead of a possible engagement;
• delivering the real estate and concierge services you have requested;
• complying with applicable legal obligations;
• establishing, exercising or defending legal claims.

Data collected through the Site is not used to send unsolicited promotional communications.

6. Legal Bases for Processing

We rely on the following legal bases: our legitimate interest in operating and securing the Site and in defending our legal rights; the performance of pre-contractual steps at your request, where your enquiry relates to a possible engagement of our services; our legitimate interest in responding to your enquiry, where it is not directed at an engagement; and compliance with legal obligations, where applicable.

7. Nature of Data Provision

The technical data described in Section 3 is collected automatically as an inherent part of operating the Site. Providing the data requested through the contact form is voluntary; however, without it we will not be able to respond to your enquiry.

8. Recipients

Your data is processed by authorised personnel and may be shared with: our hosting, IT infrastructure and website maintenance providers; our email and document management providers; and, where necessary to deliver the requested real estate or concierge service, trusted third-party partners such as banks, notaries, lawyers, schools or other service providers you ask us to introduce you to. We share such data only to the extent necessary and, where applicable, on your instruction.

Any provider processing data on our behalf does so under a contract requiring an equivalent level of data protection. We do not sell or disclose your data to third parties for their own marketing purposes.

9. International Data Transfers

Some of our providers (for example, hosting or email infrastructure) may process data outside Switzerland and the European Union. Where this occurs, transfers are made to countries recognised as offering an adequate level of protection or, failing that, on the basis of standard contractual clauses or other appropriate safeguards, a copy of which may be requested from us at the contact details in Section 1.

10. Retention Period

We retain: browsing and technical log data for 12 months; contact form data and related correspondence, absent a subsequent engagement, for 12 months from the last exchange; and, where an engagement follows, data relating to real estate and concierge services for the duration of that engagement plus any period required by law. Accounting records are retained for 10 years in accordance with Swiss law. Data is deleted or anonymised once these periods expire, unless a legal obligation or an ongoing legal claim requires longer retention.

11. Data Security

We adopt appropriate technical and organisational measures to protect the confidentiality, integrity and availability of personal data. Access is limited to those who need it to perform their role, and everyone involved in processing is bound by confidentiality obligations.

12. Automated Decision-Making

Manazelle does not make decisions based solely on automated processing that would produce legal effects concerning you or similarly significantly affect you.

13. Your Rights

Subject to applicable law, you may: request access to your data; request rectification or completion; request erasure, within the limits of any retention obligations; request restriction of processing; request data portability; object to processing based on legitimate interest; and withdraw any consent previously given.

Requests can be sent to info@manazelle.com. For security reasons, we may ask you to verify your identity before actioning a request. We aim to respond without undue delay and in any event within one month, which may be extended by a further two months for complex requests, with prior notice to you.

14. Complaints

In Switzerland, you may contact the Federal Data Protection and Information Commissioner (FDPIC). If you are resident in the European Union, you may also lodge a complaint with the supervisory authority of your own member state if you believe our processing infringes applicable data protection law.

15. Changes to this Policy

This policy may be updated from time to time. The applicable version is the one published on the Site, dated as shown above.