Privacy Policy
Last updated: 19 October 2026
This Privacy Policy describes how personal data is processed when you visit htlcnetwork.com or contact HTLC Network through it. It applies to this website only. Processing carried out in the context of client engagements is governed by the relevant engagement terms.
1. Controller
The controller responsible for the processing described in this policy is:
HTLC Network SA (UID CHE-174.439.777)
Corso San Gottardo 16, 6830 Chiasso, Switzerland
Telephone: +41 91 682 60 64
Email: sales@htlcnetwork.com
Data Protection Officer: Nicole Martin, nicole.martin@htlcnetwork.com
2. Applicable law
This policy is based on the Swiss Federal Act on Data Protection (FADP). Where the EU General Data Protection Regulation (GDPR) applies, in particular to visitors located in the European Union or European Economic Area, the processing is also carried out in accordance with the GDPR.
3. Personal data processed
Website visits. When you access the website, the web server records technical data required to deliver the pages and maintain security: IP address, date and time of access, page requested, referring URL, browser type and operating system. The contact form handler also records the technical outcome of each submission, with the IP address only in pseudonymised form, to protect the form against abuse. This data is not used to identify individual visitors.
Contact form. When you submit the contact form, the data you enter is processed: first and last name, business email, company, job title (optional) and the content of your message. Where you open the form from a specific page, for example the page on our HR software, the topic of your enquiry is recorded with it.
Email correspondence. When you write to HTLC Network directly, the data contained in your message and its metadata is processed.
Website statistics. Only if you consent through the cookie banner, Google Analytics 4 collects data on how the website is used: pages viewed, time on page, the source of the visit, the button that led you to the contact form and whether a form was submitted. Details are in the Cookie Policy.
The website is not intended to collect sensitive personal data. Please do not include such data in form submissions.
4. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Delivering the website and ensuring its security and stability, including protection of the contact form against abuse | Technical access data | Legitimate interest — Art. 6(1)(f) |
| Responding to enquiries and requests for a scoping call or quote | Form and email data | Steps prior to entering into a contract — Art. 6(1)(b); legitimate interest — Art. 6(1)(f) |
| Follow-up on a business enquiry you initiated | Form and email data | Legitimate interest — Art. 6(1)(f) |
| Measuring how the website is used | Usage data collected by Google Analytics | Consent — Art. 6(1)(a) |
| Compliance with legal obligations and defence of legal claims | Data relevant to the specific case | Legal obligation — Art. 6(1)(c); legitimate interest — Art. 6(1)(f) |
Under the FADP, processing is carried out in accordance with the principles of lawfulness, good faith, proportionality and purpose limitation.
Personal data is not sold, not used for automated decision-making and not used to build marketing profiles. HTLC Network does not send newsletters through this website.
5. Recipients
Personal data is accessible only to persons who require it for the purposes stated above. Recipients may include:
- HTLC Network group entities that handle the enquiry, depending on the country and service concerned: HTLC Network Group Holding AG, Chiasso, Switzerland, and other HTLC Network group entities [PLACEHOLDER: confirm the list].
- Hosting: [PLACEHOLDER: provider name or own infrastructure, server location].
- CRM provider: HubSpot. The contact form is sent by the website's own server to HubSpot's CRM, through which HTLC Network manages enquiries. The HubSpot account is hosted in the European Union.
- Email: form submissions are also delivered by email to HTLC Network's internal mailbox. [PLACEHOLDER: confirm the email service provider, e.g. Microsoft 365, and any email signature service].
- Statistics, only with your consent: Google Ireland Limited (Google Analytics 4, Google Tag Manager).
- IT service providers engaged for maintenance and support, bound by confidentiality and data processing agreements.
- Authorities, where required by law.
Service providers act as processors on behalf of HTLC Network under written agreements.
6. International transfers
Personal data may be transferred to countries outside Switzerland and the EU/EEA, in particular where group entities or service providers are located there. Transfers take place only to countries recognised as providing an adequate level of protection, or on the basis of appropriate safeguards such as the standard contractual clauses approved by the European Commission and recognised by the Swiss Federal Data Protection and Information Commissioner (FDPIC).
HubSpot, Inc. and Google LLC, the parent companies of the providers above, are certified under the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework; any transfer to them is based on these frameworks. [PLACEHOLDER: hosting provider country and transfer mechanism, if outside Switzerland]
7. Retention
- Technical access logs and contact form logs: up to 30 days, unless required longer for security investigations.
- Enquiries that do not result in an engagement: 24 months from the last contact.
- Enquiries that result in an engagement: retained in accordance with the engagement terms and statutory retention obligations (generally 10 years for business records under Swiss law).
- Website statistics (Google Analytics): 14 months.
Data is deleted or anonymised once the applicable period has expired.
8. Your rights
Subject to the conditions of applicable law, you have the right to:
- obtain information about and access to your personal data;
- request rectification of inaccurate data;
- request erasure of your data or restriction of its processing;
- object to processing based on legitimate interest;
- receive your data in a structured, commonly used format (data portability);
- withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of prior processing.
Requests can be sent to the Data Protection Officer at nicole.martin@htlcnetwork.com. Proof of identity may be requested.
You also have the right to lodge a complaint with a supervisory authority. In Switzerland this is the Federal Data Protection and Information Commissioner (FDPIC). In the EU/EEA it is the supervisory authority of your place of residence, place of work or place of the alleged infringement.
9. Security
HTLC Network applies technical and organisational measures appropriate to the risk, including encrypted transmission (HTTPS), access restriction and contractual obligations for service providers. No transmission over the internet can be guaranteed to be fully secure.
10. Cookies
Information on cookies and similar technologies is provided in the Cookie Policy.
11. External links
The website contains links to other websites, including the dedicated websites of group companies and the GSI2 platform. Their privacy policies apply once you leave htlcnetwork.com.
12. Changes to this policy
This policy may be updated to reflect changes in the website or in applicable law. The version published on this page applies, with the date of the last update shown at the top.