I. Purpose of this privacy policy

The purpose of this privacy policy is to inform users of the website
https://www.great-o-legacy-distribution.ch (hereinafter the "Site") about how Great O Legacy Distribution & Co SA (hereinafter "we") collects, processes, and protects personal data in the course of its activities.

Great O Legacy Distribution & Co SA is engaged in the B2B distribution of cigars, exclusively to professional customers based in Switzerland.

This policy applies in particular to customers, business partners, suppliers, visitors to the Website, and contact persons acting on behalf of customer or partner companies (hereinafter "you").

This policy is not exhaustive. Additional information may be provided in contracts, forms, specific communications, or special conditions.

If you provide us with personal data concerning third parties (collaborators, representatives, employees), you confirm that you are authorized to do so and that you have informed the persons concerned.

II. Data controller

The data controller is:

Great O Legacy Distribution & Co SA
Route de Divonne 46
1260 Nyon
Switzerland

📧 info@great-o-legacy-distribution.ch

No formal data protection officer has been appointed.
Any requests relating to data protection can be sent to the above address.

III. Legal basis for processing

Data processing is subject to the Swiss Federal Act on Data Protection (FADP).

As the Website is intended exclusively for professional customers in Switzerland, the European Union's GDPR is not considered applicable.

Personal data is processed on the following bases:

  • execution or preparation of B2B contractual relationships
  • compliance with legal obligations (accounting, tax, retention)
  • legitimate interests (operation of the Website, security, communication, B2B marketing)
  • consent, when required (particularly for non-essential cookies)

Data is retained only for as long as necessary for the purposes described and in accordance with legal obligations.

IV. Rights of data subjects

Under Swiss law, you have the following rights:

  • right to access your personal data
  • right to correct inaccurate data
  • right to erasure, within legal limits
  • right to object to certain processing
  • right to withdraw consent with effect for the future

Exercising these rights may require verification of your identity.
We reserve the right to limit or refuse a request where permitted by law.

You also have the option of contacting the Federal Data Protection and Information Commissioner (FDPIC).

V. Categories of data processed

a. Data provided directly

We handle, in particular:

  • full name
  • company, function
  • business address
  • work email address
  • phone number
  • data related to orders, billing, and business relationships

b. Technical and connection data

When visiting the Site, certain data is collected automatically:

  • IP address
  • connection date and time
  • browser, operating system
  • pages viewed and navigation path
  • data from cookies and similar technologies

This data is used for security, stability, and analysis purposes.

c. Data from third parties

In a B2B context, we may receive data:

  • business partners
  • service providers
  • publicly accessible records
  • in the context of professional communications

VI. Purposes of processing

Personal data is processed in particular for:

  • communication with customers, suppliers, and partners
  • B2B customer account management
  • preparation, conclusion, and execution of contracts
  • order management, deliveries, and billing
  • payments by invoice or card
  • technical operation and security of the Site
  • improvement of our services and user experience
  • B2B marketing and commercial communication
  • compliance with legal and accounting obligations
  • defense of our rights in the event of a dispute

No job applications are processed via the Site.

VII. Cookies, tracking, and similar technologies

The Site uses cookies and similar technologies.

We use, in particular:

  • cookies strictly necessary for the functioning of the Site
  • analytical cookies (Google Analytics)
  • tag management tools (Google Tag Manager)
  • tools related to email marketing and CRM

Non-essential cookies are subject to your consent via a cookie banner on your first visit.

You can change your preferences at any time via the banner or your browser settings.

VIII. Data security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or unlawful processing.

Our service providers act solely on our instructions and are contractually bound to respect confidentiality and data protection.

Despite these measures, no transmission over the Internet can be guaranteed to be completely secure.

IX. Recipients of the data

Personal data may be transmitted, when necessary, to the following categories:

  • IT and hosting providers (including Infomaniak)
  • CRM and email marketing providers
  • payment providers
  • logistics providers (Swiss Post)
  • legal, tax, or accounting advisors
  • authorities or courts when required by law

X. Data transfers abroad

We work with international service providers, particularly in the fields of IT, analytics, and communications.

When data is transferred abroad, we ensure that appropriate safeguards are in place to ensure an adequate level of protection in accordance with Swiss law.

XI. Shelf life

Personal data is stored:

  • as long as necessary for the business relationship
  • in accordance with legal retention obligations
  • or until consent is withdrawn, where applicable

The data is then deleted or anonymized.

XII. Changes to the Privacy Policy

We reserve the right to modify or supplement this privacy policy at any time.
The version in force is the one published on the Site.

Last update: January 2026