Privacy policy for clients, suppliers and “bounters” in accordance with Article 13 of EU Regulation no. 2016/679 on personal data protection


  • Introduction

According to Article 13 of EU Regulation n. 2016/679 (hereinafter “GDPR”), Sgame S.A. (hereinafter “Company”), with premises in 6900 Lugano (Switzerland), via Balestra no. 33, VAT no. CHE-455.786.719, which may be contacted for the exercise of the rights envisaged by the valid laws at the address of the premises or via the e-mail, in its capacity of Data Controller of personal data, already communicated or being communicated in the future, and where the personal data have been or will be collected, wishes to inform you that the data concerning you may be processed, in accordance with the above-mentioned provisions, by the Company with reference to pre-contractual and/or contractual relations existing with you or which will be existing in the future.

  • Source of the personal data

The personal data, collected or being collected in the future with reference to contractual or pre-contractual relations, are being collected directly from the data subject. All collected personal data are processed in accordance with the valid provisions and, in any case, with the due confidentiality.

  • Nature of collection

For the execution and fulfilment of the contractual relation, the collection of personal data has also  obligatory nature as tax and law fulfilments need to be complied with; the refusal to communicate such data will entail the impossibility to have any relation with the Company. The relevant processing does not require the consent of the data subject.

  • Purposes of processing and legal basis for the processing

The collection or the processing of personal data has the exclusive purpose of complying duly with the legal obligations related to the carrying out of the economic activity of the Company and in particular:

– carrying out pre-contractual activities and collecting preliminary information aimed at the execution of the agreement;

– managing the contractual relation and any administrative, operative, managing and accounting activities related to the agreement;

– managing litigation, contractual non-fulfilment, warning letters, settlements, arbitral proceedings, in-court litigation, etc.;

– fulfilment of obligations set forth by laws, regulations, EU legislation and by provisions of the public authority.

The processing of data is carried out by virtue of the fulfilment of pre-contractual and/or contractual and legal obligations concerning the relation established by you with the Company, according to Article 6, para. 1, letter b) of GDPR.

  • Modalities of processing

The personal data processing will be carried out lawfully and fairly and, in any case, in accordance with the above-mentioned provisions, with the purpose of granting its safeness and confidentiality, and may be carried out also by electronic means aimed at memorizing, managing and forwarding such data.

The processing will be carried out, primarily, by the internal organization of Company, under the direction and the control of the responsible persons of the company and for the afore-mentioned also by other companies of the group or by third persons, as identified under Article 7 below.

The personal data storage will be carried out in a way allowing the identification of the data subject for a time period not exceeding the one necessary for the purposes for which they are collected and processed.

  • Duration of processing

The personal data subject to processing will be stored for the time strictly necessary with regard to the contractual relation, as well as, subsequently, for the fulfilment of all legal obligations related to or deriving from the agreement executed by you with the Company.

  • Recipient of personal data

Without prejudice to the communications provided in compliance with the obligations envisaged by law, regulations or EU provisions and intra-group obligations, the communication of personal data concerning you may be carried out to the following subjects:

  1. a) entities, supervisory bodies, public authorities or institutions;
  2. b) physical or legal persons performing specific services, which include – without limitation – data processing, logistic and post services, survey of the grade of satisfaction of the Clients, legal, administrative, tax and/or accounting advice, organisation of fairs and communication events, etc.;
  3. c) commercial broker, banks and credit institutions, financial intermediaries, physical or legal persons responsible for credit recovery, audit and or certification of the balance sheet and of quality systems, self-employed collaborators of Company, agents, insurances and brokers, etc.;

The subjects under a), b), and c) operate as independent Data Processors.

We assure you that, in any case, to the mentioned subjects are exclusively transferred, if not personal data aggregated and in anonymous form, the personal data necessary for and pertinent to the purposes of the processing for which they are responsible.

The list of such third parties shall be constantly updated and accessible by you upon request to the Company. By virtue of the existence of connections to them via telematic/electronic means or via correspondence, the personal data may be made available abroad, also in extra-EU countries subject to the relevant authorization or standard contractual clauses.

In any case, the personal data shall not be broadcasted.

  • Rights of the data subject

It is understood that you have the right of access to the references, indicated in the introduction, to the personal data provided under Article 15 GDPR and the rights foreseen by Articles 16, 17, 18, 21 GDPR regarding the rectification, cancellation, limitation of processing and the right to object, under the conditions envisaged by Article 12 GDPR.

  • Right to lodge a Complaint according to Article 77 GDPR

In case our Company does not provide you a feedback by the term envisaged by the laws or if the response to the exercise of your rights is undue, you are entitled to lodge a complaint with the Swiss Privacy Supervisory Authority (Federal Data Protection and Information Commissioner) with the following contact details: website, email,  phone number +41 (0)58 462 43 95.

  • Further information

Further information concerning the processing and communication of personal data may be requested to the Company.

In case a Data Controller (in accordance with Article 37 GDPR) is appointed, its contact information will be published on the website   

The updated list of Data Controllers, in case they are appointed, is available at the Company’s offices.


Last update: December 12th 2018