The processing of personal data carried out by Flower & Klein SA is done in compliance with the Federal Act on Data Protection (FADP) and EU Regulation 679/2016, following principles of fairness, lawfulness, transparency, purpose limitation, data minimization and accuracy, and the protection of integrity and confidentiality. This Privacy Policy is intended for the website (hereinafter "Site")

The Data Controller is Flower & Klein SA.
To request further information on the processing of personal data or to exercise your rights, you can contact us:
·       In writing to:   Flower & Klein SA
Via S. Balestra n. 10 6900
Lugano (Switzerland )
·       By email:
1.       What are personal data and what is processing
Personal data are information that identifies or can identify, directly or indirectly, a natural person and can provide information about their characteristics, habits, personal relationships, etc. Personal data includes, but is not limited to: name, surname, address or other contact details, an identification number, or an online identifier. Processing is any operation performed with or without the aid of automated processes and applied to personal data. Processing includes, but is not limited to: collection, recording, organization, storage, modification, consultation, deletion, or destruction of data.

2.       What personal data are processed
a.     Navigation data
The computer systems and software procedures used to operate the site acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site; URI addresses (Uniform Resource Identifier) of the requested resources; the time of the request, and other parameters related to the user's operating system and IT environment. These data are used solely to obtain anonymous statistical information on the use of the site to check its proper functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical IT crimes against the Data Controller or third parties.
b.    Data provided by the user
The optional, explicit, and voluntary sending of emails to the addresses indicated on this site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.
Personal data such as name, surname, email, phone, and company are collected by the Data Controller when filling out the "Request for Information" Form.

3.       Purpose of processing User
 Personal data will be processed for the following purposes:
3.1               To respond to User requests by providing general information about the services of        Flower & Klein SA;
  3.2        To respond to job applications submitted by Users;
3.2              To fulfill obligations provided by law, by a regulation, and to satisfy requests from  competent authorities;

4.      Legal basis for the processing of User data
      Data Each processing is justified by one of the following legal bases:
·       The processing is necessary to fulfill User requests. In this case, the provision of personal data is mandatory; 
·       The processing is necessary to comply with a legal obligation. In this case, the provision of data is mandatory;
·       The processing is necessary for the pursuit of the legitimate interest/prevailing interest of the Data Controller, Provided that it does not override the interests or fundamental rights and freedoms of the User requiring the protection of personal data. In this case, the provision of data is optional;
·       The processing follows the expression of consent by the User. In this case, the provision of data is optional and consent can be withdrawn at any time by communicating it to the Data Controller.

5.       Who the data might be shared with
In the context of Flower & Klein SA's activities and for the purposes specified above, the User's personal data may be shared with:
·       Data Processors duly appointed who provide specific processing or accessory services on behalf of the Data Controller and under its instructions; the User can request the updated list of Data Processors at any time; •
·       Independent Data Controllers to whom data might be communicated by law or by order of Authorities; • Persons authorized by the Data Controller to process personal data necessary to carry out activities strictly related to the provision of services who have assumed a confidentiality obligation (e.g., employees and/or collaborators of the Data Controller);
·       Clients/Principals of the Data Controller;
·       Depending on the geographical scope of service execution, personal data may be shared between Flower & Klein SA, the Operational Headquarters in Chiasso, and Flower & Klein Americas Inc in the USA.

6.      Where the data is stored
Personal data is stored electronically on servers located in Switzerland and the USA.

7.       How long data is stored
User personal data is stored in compliance with current regulations for the period necessary to achieve the purpose for which it was collected.
CVs and job application information from Users who submitted a "job application" will be stored for no longer than 24 months from receipt; contact details and other information related to the application may be stored for a longer period, subject to consent. This consent can be withdrawn by the User at any time by writing to the contacts provided in the Introduction.

8.      User rights
The User can request, at any time, confirmation of whether their personal data is being processed and has the right to:
·       Request access to data to obtain information on the purposes pursued with the processing, on the recipients to whom the data might be communicated, the duration of the processing (if possible), and the consequences of processing basedon profiling;
·       Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; • Request the rectification of personal data if it is found to be inaccurate or incomplete; •
·       Request the deletion of data if it is no longer necessary for the purposes for which it was collected, it is inadequate for the processing purposes, the User has withdrawn their consent, or the data has been processed unlawfully; •
·       Request the limitation of data processing, in cases provided by law; •
·       Request the transfer of data to another Data Controller, in a commonly used format readable by an IT device, without hindrance from the current Data Controller; •
·       Object to the processing of their data and, specifically, has the right to object to decisions concerning them if based solely on automated processing of their data, including profiling; •
·       Lodge a complaint with the competent Authority if they believe that the processing concerning them violates current data protection regulations. To exercise their rights, they can use the contact details provided in the INTRODUCTION.

9.      Automated decision-making
The User is not subject to decisions based on automated processing.

10.   Links to third-party websites and services
Our site may contain links to third-party websites. Flower & Klein SA is not responsible for the processing of personal data and information by these third parties. If the user provides information on third-party sites, the personal data protection provisions and the terms of use of the services on third-party sites will apply, which we invite you to read. We also assume no responsibility regarding the collection, use, disclosure, and data security policies and procedures of other companies such as Facebook, Twitter, Google, LinkedIn, or any other application developer, application provider, social media platform provider, operating system provider, service provider.
11.   Changes
Flower & Klein SA reserves the right to modify or simply update the content of this Privacy Policy, in whole or in part, even due to changes in applicable legislation. Such changes will be binding as soon as they are published on the Site. If the User continues to access or use the service after such publication, it is presumed that they have expressly accepted these changes. Therefore, Flower & Klein SA invites the User to regularly visit this section to be aware of the most recent and updated version of the Privacy Policy to always be updated on the data collected and how Flower & Klein SA uses it.
Date: 10.05.2024