Effective date: July 26th, 2018


Wullschleger Martinenghi Manzini Holding SA, Lugano, Switzerland (“us”, “we” or “our”), operates the www.wmm-group.com website (“The Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service.

By using the Service, the user agrees to the collection and use of information in accordance with this policy.




The Service is the www.wmm-group.com website operated by Wullschleger Martinenghi Manzini Holding SA, Lugano, Switzerland.

Personal Data

Personal Data refers to the information about a natural person, which can be used to identify him or her which is already in our possession or which we might subsequently acquire.

Usage Data

Usage Data are the data (such as, for example, the length of your visit to a page) which are collected after they have been automatically generated when using the Service or by the Service Infrastructure.


Cookies are files with a small amount of data, which are being memorized by a certain device (a computer or a portable device).

The Controller

The Controller refers to the natural or legal person who is individually or jointly in cooperation with others responsible for the determination of the purposes and means by which the personal data are or shall be processed.

For the purposes of this policy, we are responsible for the processing of the personal data.

The Person Responsible for the data processing (or service provider)

The Person Responsible for the data processing (or service provider) is any natural or legal person who is processing data on behalf of the Controller.

We may employ several services providers so as to process your data in a more effective way.

The User

The User is a natural person who is using the Service and to whom the personal data relate.


Information: Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you. Namely, we collect data so as to be able to send you information about our activity and our services, which is to say, trustee, wealth and asset management and real estate management consulting services.


Types of Data collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • E-mail address
  • First name and last name
  • Telephone number
  • Address, Country/Nation, canton/region/province, postal code, town
  • Cookies and Usage Data

We may also use your personal data to reach you by newsletter, or to send promotional or marketing material and some other information you may find of interest. You may decide you do not want to receive some or any of all this information we provide by clicking the cancellation link, or following the instructions provided in any of the e-mails we send, or getting in touch with us.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), the browser type, the browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking and Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies, or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.


Use of Data

Wullschleger Martinenghi Manzini Holding SA uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
  • To provide you with news and general information about the services and event we offer, unless you have decided not to receive such information

Lawfulness of data processing pursuant to the General Data Protection Regulation (GDPR)

If you have your place of residence in the European Economic Area (EEA), Wullschleger Martinenghi Manzini Holding SA’s legal basis for the collection and usage of the personal data described by this policy depends on the type of Personal Data we collect and the specific context into which they are being collected.

Wullschleger Martinenghi Manzini Holding SA is authorized to process your personal data because:

  • You have given us consent to do so, or
  • processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract, or
  • processing is necessary for the purposes of our legitimate interest, except where such interest is  overridden by your interests or fundamental rights and freedoms which require protection of your personal data, or
  • processing is necessary for compliance with a legal obligation to which we are subject


Personal data storage

Wullschleger Martinenghi Manzini Holding SA shall not keep your personal data for longer than it is necessary for the purposes stated in this policy. We shall hold and use your personal data to the extent necessary to fulfil our legal obligations (for example, if we are requested to hold your personal data to comply with applicable law), settle disputes and implement our agreements and our legal rules of conduct.

Wullschleger Martinenghi Manzini Holding SA shall also hold Usage Data for the purpose of internal analysis. Usage Data are usually held for a shorter period of time, except when these data are used for enhancing safety, or to improve the functionality of our Service, or when we are legally required to hold these data for longer periods of time.


Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state/country, canton/region/province, or other governmental jurisdiction where the data protection laws may differ from those utilized in your jurisdiction.

If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Switzerland and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Wullschleger Martinenghi Manzini Holding SA will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.


Disclosure of Data

Disclosure by law enforcement

There are certain circumstances, for example if it is provided for by Law, or in response to valid requests from the authorities, in which Wullschleger Martinenghi Manzini Holding SA may be required to disclose the User’s Personal Data.

Legal Requirements

Wullschleger Martinenghi Manzini Holding SA may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Wullschleger Martinenghi Manzini  Holding SA
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability


Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we strive to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, not being however able to guarantee its absolute security.


Your rights on Data Protection pursuant to the General Data Protection Regulation (GDPR)

If your place of residence is in the European Economic Area (EEA), you have certain rights in relation to the protection of Personal Data. Wullschleger Martinenghi Manzini Holding SA aims at obtaining reasonable measures to allow the user to correct, rectify, erase or limit the use of his or her Personal Data.

Please do not hesitate to contact us if you are willing to be informed about the Personal Data of yours we are holding and if you want to have such information erased.

There are certain circumstances in which you have rights in relation to Data Protection. These rights are:

The right of access to update or erase the information we have about you.

The right of rectification. You have the right to rectify the information about you, if this information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your personal data.

The right to restriction of processing. You have the right to ask that we restrict the processing of your Personal Data.

The right to data portability. You have the right to receive copy of the information we have about you in a structured, commonly used and machine-readable format.

The right to withdraw consent.  You have also the right to withdraw consent on which Wullschleger Martinenghi Manzini based its processing of your personal data anytime.

The right to notify a violation of your personal data.

Please be aware that we might ask you to verify your identity before answering these requests.

You have the right to file a formal privacy complaint with an Authority for the protection of Personal Data about our collection and use of your Personal Data.

For further information, you can contact the local authority for the protection of Personal Data in the European Economic Area (EEA).


Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We mainly refer to

  • Google Analytics: Google Analytics is a free web analytics service offered by Google that tracks and reports website traffic. It allows you to analyse detailed statistics on the visitors to a website. Using Google Analytics you can find out the most popular or viewed pages of a website, where the viewers come from (referrer), how long they have been staying on a website and localize them.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

  • Vimeo: Vimeo (http://vimeo.com) is a website whose users can load, share and visualize videos provided by Vimeo Inc.

For more information on the privacy and cookie policy at Vimeo, please visit Vimeo Web page on privacy: http://vimeo.com/privacy and the Vimeo Cookies policy: http://vimeo.com/cookie_policy.


Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


Changes to This Data Protection Policy

We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the new Data Protection Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Data Protection Policy.

You are advised to review this Data Protection Policy periodically for any changes. Changes to this Data Protection Policy are effective when they are posted on this page.


Contact Us

If you have any questions about this Data Protection Policy, please contact us: