Privacy Policy

Data Controller

Within the meaning of art. 5 let. j of the Federal Act on Data Protection (nFADP), the data controller is:

Company DAVILA — La Galerie Numismatique Sàrl

Address Rue du Petit-Chêne 32, 1003 Lausanne, Switzerland

Email galnum@bluewin.ch

Data Protection Advisor [Name and contact details, if appointed]

Data Collected

We collect the following categories of data:

  • Identification data — name, first name, postal address, email, telephone
  • Transaction data — purchase history, invoices, auction orders
  • Payment data — processed exclusively by our service providers (Stripe, PostFinance, banks); the Gallery stores no banking data
  • Technical data — IP address, browser type, pages visited, visit duration
  • AML data — copy of identity document for transactions subject to art. 7 of the Anti-Money Laundering Act

Purposes and Legal Bases

Your data is processed for the following purposes:

  • Performance of contract (art. 31 para. 2 let. a nFADP) — processing of orders, deliveries, invoices, support
  • Legal obligation (art. 31 para. 2 let. b nFADP) — bookkeeping (10 years, CO art. 958f), AML, taxation
  • Legitimate interest (art. 31 para. 2 let. d nFADP) — site security, fraud prevention, service improvement
  • Consent (art. 6 para. 7 nFADP) — sending of the newsletter, new item alerts

No automated profiling is carried out within the meaning of art. 5 let. f nFADP.

Retention Periods

Client data 10 years after the last transaction (accounting obligation)

AML data 10 years (art. 7 para. 3 AMLA)

Newsletter Until withdrawal of consent

Technical logs 12 months maximum

Analytics cookies 13 months maximum

Transmission and International Transfers

Your data may be shared with our sub-processors: hosting provider, payment processors, carriers (DHL, FedEx), accountant, legal counsel. All are bound by a sub-processing agreement within the meaning of art. 9 nFADP.

In the event of a transfer outside Switzerland to a country not providing adequate protection (art. 16 nFADP), we implement the standard contractual clauses recognised by the FDPIC, or obtain your explicit consent. The list of adequate countries is published in Annex 1 of the DPO.

Your Rights

In accordance with arts. 25 to 29 nFADP (and the GDPR if you reside in the EEA), you have the following rights:

  • Right of access to your data (art. 25 nFADP)
  • Right of rectification and updating (art. 32 nFADP)
  • Right to erasure subject to statutory retention obligations
  • Right to object to processing and to prospecting
  • Right to data portability (art. 28 nFADP)
  • Right to withdraw consent at any time

Any request may be sent to galnum@bluewin.ch. We will respond within 30 days. A copy of an identity document may be requested to verify your identity.

Supervisory Authority

If you believe that the processing of your data infringes the nFADP, you may file a complaint with:

Authority Federal Data Protection and Information Commissioner (FDPIC)

Address Feldeggweg 1, 3003 Berne, Switzerland

Website www.edoeb.admin.ch

If you reside in the EEA, you may also contact the data protection authority of your country of residence.

Security

We implement appropriate technical and organisational measures (art. 8 nFADP), including TLS encryption, daily backups, access controls, staff training and two-factor authentication for sensitive accounts. As no system is entirely infallible, we cannot however guarantee absolute security against all threats.