Privacy Policy
1. Purpose
This policy applies to all processing of personal data by HGroup SA and aims to inform the user about how HGroup SA processes personal data (including details on the type of personal data collected and the purpose of the processing) and about the user’s rights related to their personal data.
2. Contact – How can I get in touch?
If I have any questions regarding the privacy policy, the user may contact HGroup SA by the following means:
• The registered office is located at: Ch. Pré-Du-Puits 16b – 1273 Arzier CH
The user may establish direct and effective communication with HGroup SA in writing by sending a communication to the address provided or by sending an email to: info@hgroup-services.com. In addition, the information of the controller of your personal data is provided below:
• Name: HGroup SA
• Identity of the controller: Patrick Holzapfel
• Address: Art Investment & Banking Advisory, Ch. Pré-Du-Puits 16b – 1273 Arzier CH
• Email: info@hgroup-services.com
3. Identification of the processing – How do we collect personal data?
In accordance with applicable data protection regulations, in particular:
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the “GDPR”).
HGroup SA collects the personal data in its possession when the user:
(i) Fills out the forms on https://hgroup-services.com/ (“Site”);
(ii) Subscribes to the newsletter;
(iii) Responds to a survey or completes an online form;
(iv) Completes a printed form;
(v) Sends an email or communicates by telephone, which is then uploaded to the corresponding forms;
4. Personal Data Collected – What Personal Data Do We Collect?
HGroup SA collects information when you visit its website, primarily by completing its registration forms.
The following data is collected: full name, company name (optional), and email.
Generally, when personal data is required to use a service or access certain content, its provision is not mandatory, except in cases where it is specifically stated that it is required for the provision of the service. In this case, the user may freely choose not to register and/or contract the services. The user represents and warrants that all information provided is true and accurate and agrees to keep it up to date. Any changes may be communicated to the Data Protection Officer or to the address indicated in paragraph 2 above.
The user also acknowledges that the information requested by HGroup SA is necessary, adequate, and not excessive to achieve the purposes set out in paragraph 5 above, which would be impossible to achieve without the provision of such information.
Any false or inaccurate statements resulting from the information and data provided, as well as any damages that such information may cause, will be the user’s responsibility.
5. Purpose – What is the purpose of the personal data we collect?
The personal data requested from the user will be used for the following purposes:
• To provide our Service and respond to your requests. We use your information to provide and maintain our Service, to process and respond to your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you sign up for a newsletter, we may use your personal information to send you an email newsletter.
• Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to access one of our registration or login portals, we use your login information to authenticate your identity.
• Personalization. We use your information to tailor the content and information we may send or display to you, to offer location-based customization, personalized help and instructions, and to otherwise personalize your experience while using the Service. For example, if you allow us to collect geolocation data, we use that information to deliver content around your specific location and identify business locations/listings around your location.
• Marketing and promotional purposes. We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information we think may be of interest to you. We may also use your information to display advertisements to you on our Site (including to sell advertising space on the Service) and on other unaffiliated websites and services.
• Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the educational products, services, and information we provide. Survey responses may be used to determine the effectiveness of our service, various types of communications, advertising campaigns, and/or promotional activities.
• Combine information. We (and our third-party business partners on our behalf) may merge, mix, or otherwise combine information, including your personal information, to pursue the purposes described above.
• Comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including to comply with requests from law enforcement or government authorities and to participate in compliance audits.
• To protect ourselves and others. We may use your information when we believe it is necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person, or to otherwise enforce this Policy, our Terms of Service, and the integrity of the Service.
• Anonymized Data. We may also de-identify or anonymize your data so that you cannot reasonably be re-identified by us or any other party, and we may use this anonymized data for any purpose permitted by applicable law. To the extent we anonymize data originally based on personal information, we will store and use this data in an anonymized form and will not attempt to re-identify the data.
The data processed will not be used for purposes other than those mentioned above and for which it was collected. Notwithstanding the foregoing, it is hereby specified that the recorded data may be used, in addition to the purposes for which they were expressly collected, for statistical purposes, incident management or market research. However, in the event that personal data is processed for purposes other than those initially specified when such data was collected, a compatibility analysis will be carried out by HGroup SA in accordance with applicable regulations. Processing will only be permitted if the initial purpose is compatible with the new purpose or permitted in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or the legal justification for processing their data. We remind the user that they can object to the sending of commercial communications (unsubscribe) and no longer receive emails from HGroup SA, by reliably informing HGroup SA, which will proceed with the interruption as soon as possible after receiving such communication. To do so, you can send an email to the address indicated in Section 2, a letter to the address indicated in Section 2 above, or directly follow the unsubscribe instructions detailed at the end of each HGroup SA email.
6. How do we use your information?
We will use the information we collect about you for the following purposes:
• Creation of user accounts
If we wish to use your information for other purposes, we will ask for your consent and will only use your information with your consent and only for the purpose(s) for which you provided your consent, unless otherwise required by law.
We will retain your personal information for an indefinite period after user accounts are no longer active, or for as long as necessary to fulfill the purposes for which it was collected, as detailed in this Privacy Policy.
7. Consent
By providing personal data to HGroup SA, the user declares that they fully and unconditionally agree to its processing by HGroup SA. The user hereby grants their free, express, and informed consent to HGroup SA to use the collected data for the purposes indicated in Section 5 above, as well as to its inclusion in an HGroup SA database. HGroup SA carries out the processing of the user’s data legitimized by: (i) the conclusion of a HGroup SA service contract by the user, in accordance with the terms and conditions that are made available to the user at the end of the completion of the service request form (before possible hiring) and that the user (after having read them), and if they agree, can accept by checking the box that has been included for this purpose; and (ii) the free, informed and unequivocal consent of the user, given after reviewing this Privacy Policy where HGroup SA informs the processing that it will carry out with your data, and if you agree, by checking the box that has been included for this purpose in the service request form. The processing of data that is not covered by any of the legal bases indicated above, will be carried out if HGroup SA deems it necessary to protect a legitimate interest and only if they do not infringe the fundamental rights and freedoms of the user.
8. Expiration – How long do we keep it?
Data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes detailed in Section 5 above. In particular, personal data will be retained for as long as the business relationship is in effect (and unless the user has previously requested its deletion) and for the period during which obligations, compensation, and/or liabilities may arise in connection with the business relationship or the services provided. HGroup SA informs us that it will retain the information essential to identify the origin of the stored data for the duration of the customer relationship with HGroup SA and/or the revocation of the user’s consent in accordance with the information provided in Section 5 of this Privacy Policy and/or for the duration required by applicable law.
9. Confidentiality / Assignment / International Transfer – Do we disclose data to third parties?
HGroup SA will keep the personal data collected private and confidential and will not use it for purposes other than those set out in Section 5 above. HGroup SA requires its employees and third parties providing services that access the database content to sign confidentiality and personal data processing agreements (or include such obligations in the service agreements it signs with such providers, as set out in the following paragraph).
The user’s personal data collected by HGroup SA will not be transferred, sold, exchanged, transmitted, and/or disclosed to third parties outside of HGroup SA without the user’s consent, except as required by law and/or for the purpose of providing the services to the user. This does not include certain employees and service providers who enable HGroup SA to maintain the website, comply with the purposes set out in Section 5 above, and/or provide services to the user. These employees have assumed an obligation to maintain the confidentiality of the data provided and undertake to comply with applicable personal data protection regulations at the time of hiring. Contracts with service providers stipulate the purpose, scope, content, duration, nature, and purpose of data processing, the type of personal data, the categories of data owners, and the obligations and responsibilities of HGroup SA and the contracting third parties.
In particular, HGroup SA may share the personal information provided with controlling companies, subsidiaries, affiliated companies, related companies, and/or intermediaries connected to HGroup SA.
HGroup SA may share certain personal information provided by the user internally within HGroup SA, with certain departments, such as administration, marketing, or IT. Finally, you should be aware that HGroup SA may (and HGroup SA reserves the right to) disclose your information in the following circumstances:
• Business Transfer: If we or our subsidiaries are acquired, merged, or invested in by another company, or if any of our assets are transferred or may be transferred to another company, whether as part of bankruptcy or insolvency proceedings or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain information about you to lenders, auditors, and external advisors, including lawyers and consultants.
• Compliance with Law: We may disclose your personal information to comply with the law, a judicial proceeding, a court order, or other legal process, such as in response to a court order or a subpoena.
• Protection and facilitation of rights: We may disclose your personal information when we believe it is appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations that may pose potential threats to the safety of any person, or violations of human rights. our terms and conditions or this policy. This disclosure may also include using your personal information as evidence in litigation in which we are involved. In addition, we may disclose your personal information when necessary to help you exercise your rights under ROCONSEIL’s terms and conditions and this privacy policy.
• Reasons related to public safety, national defense, or public health: In situations where there are legitimate reasons related to community safety, national defense, or public health, your personal information may be disclosed.
• Aggregated, anonymized, or de-identified information: We may disclose aggregated, anonymized, or de-identified information about you for any purpose permitted by applicable law.
• Consent: We may disclose your personal information with your consent.
10. Security – How do we ensure data security?
HGroup SA declares its intention to adopt the necessary technical and organizational measures to guarantee the security, integrity, and confidentiality of data in accordance with the provisions of the GDPR, in order to prevent its alteration, loss, access, or unauthorized processing.
HGroup SA does not guarantee absolute privacy in the use of the website, as unauthorized third parties may gain access to it. The user acknowledges that existing technical security measures are not impenetrable and that even with the adoption of all reasonable security precautions, manipulation, destruction, and/or loss of information may occur. In the event of detection of a security incident involving a significant risk to the data owner, this event will be promptly reported to the competent supervisory authority, along with the corrective and remedial measures implemented and/or to be implemented.
HGroup SA is not responsible for the loss or deletion of data by users. Likewise, HGroup SA accepts no liability for any damage caused by computer viruses.
Finally, users must also take steps to protect their information. HGroup SA urges you to take every precaution to protect your personal information when using the Internet. At a minimum, you are advised to change your password periodically, using a combination of letters and numbers, and to ensure you use a secure browser.
11. Data Owner Rights and Procedures for Exercising Them – What Rights Do I Have as a Data Owner?
A data owner may exercise their rights of access, rectification, cancellation, opposition, restriction of processing, portability, confidentiality, and deletion regarding their personal data at any time, in accordance with the provisions of Articles 15 et seq. of the GDPR, as applicable. The exercise of these rights can be carried out by the user himself by email to info@hgroup-services.com, or by one of the means provided for by the applicable regulations mentioned above. HGroup SA may request the data necessary to validate the identification of the data owner.
Certain data will not be deleted when it could harm the rights or legitimate interests of third parties, or when there is a legal obligation to retain the data.
If you reside in the UK or the EEA and are subject to national or local legal exemptions, you have certain data protection rights in certain circumstances. Please contact us if you wish to exercise any of these rights.
• Withdraw consent at any time. Users have the right to withdraw their consent if they have previously given their consent to the processing of their personal data.
• Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to know whether their Data is being processed by the Owner, to obtain information about certain aspects of the processing, and to obtain a copy of the Data undergoing processing.
• Verify and request rectification. Users have the right to verify the accuracy of their data and to request that it be updated or corrected.
• Restrict the processing of their data. Users have the right to restrict the processing of their data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their personal data deleted or otherwise removed. Users have the right to obtain the erasure of their data from the Owner.
• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without hindrance.
• File a complaint. Users have the right to file a complaint with their competent data protection authority.
12. Training – Do we receive training?
HGroup SA staff whose duties involve processing personal data are trained to ensure better protection of personal data and the rights of its owners.
13. Links to Third Parties – Does our Site contain links to other sites?
The Site may contain links to third-party sites, with or without advertising content, whose privacy policies are not those of HGroup SA. The linked sites are not affiliated with HGroup SA, and their existence in no way implies any suggestion, invitation, or recommendation to visit the destinations, or any link or association between HGroup SA and these sites. HGroup SA is not responsible or liable for the content, use, or activities of these linked sites, nor for any actual or potential damages, whether material or moral, direct or indirect, suffered by users and resulting from the information contained on these sites or from the relationships that users may establish with third parties whose services have been published on the site. However, any feedback on these linked sites will be useful to HGroup SA in order to improve its services and/or ensure the integrity of the site. HGroup SA undertakes to do everything possible to prevent the existence on its site of links to sites with illegal content.
14. Children’s Privacy
At HGroup SA, we recognize the importance of protecting children’s privacy. Our commitment to protecting the personal information of minors is unwavering. We may collect and process personal information from children under 13, but only in compliance with all applicable laws and regulations, including obtaining parental or guardian consent, where required.
If you are a parent or guardian and you believe we have collected personal information about your child without proper consent, please contact us immediately, and we will take prompt action to remedy the situation.
For California residents: We do not sell the personal information of California consumers aged 16 or younger unless we have obtained prior parental consent. If your child is under 13, we insist on obtaining parental or guardian consent for the collection and processing of their personal information. If your child is between the ages of 13 and 16, they may choose to allow the sale of their personal information. Our websites and services designed for children will incorporate age verification and ensure that necessary consents are obtained.
For EU residents: We do not collect or process personal information from anyone under the age of 16 in the EU without the explicit consent of a parent or guardian. Our websites and services directed at children will include age verification and require appropriate consent.
15. Cookies – Do we use cookies?
When you visit the website, HGroup SA may store information on your computer in the form of a “cookie” or similar file. The website uses cookies to (i) track advertising, (ii) collect data on website traffic, and (iii) improve the user experience while using the website.
You should be aware that to browse the website, you do not need to authorize the installation of cookies sent by the website. This may only be required for certain services. The user can erase cookies from their hard drive, prevent access to their computer, either through their browser or by selecting the corresponding option when asked if they wish to use cookies for these purposes, in accordance with HGroup SA’s Cookie Policy.
Cookies are information files that the website or the provider of certain services on the website transfers to the user’s computer hard drive via the browser. Cookies themselves cannot personally identify the user (although they may contain the user’s IP address), but they do allow the user to recognize the user’s browser and capture and store certain data (user’s operating system, domain name of the website from which the website was linked, among others). HGroup SA reserves the right to contract the services of third parties to analyze and understand the website’s users, who may not use the information collected for any purpose other than to improve HGroup SA’s services.
16. Consent
Use of the Site by the user implies full knowledge and approval of the HGroup SA Privacy Policy and the HGroup SA General Terms and Conditions, as applicable. Likewise, the user accepts the HGroup SA Privacy Policy and the HGroup SA General Terms and Conditions by completing the service request.
17. Changes – Is this the most recent version?
This is the current version of the HGroup SA Privacy Policy, updated on October 9, 2025.
HGroup SA may modify this Privacy Policy at any time and without prior notice. These changes will be effective upon publication on the Site or upon communication to users by any means, whichever occurs first. The user must keep informed of the terms included herein by periodically accessing it.
