General Data Protection Policy

APTELIS Consulting SA

Based in Geneva and active in Switzerland since 2018, APTELIS Consulting SA (hereinafter APTELIS) advises a clientele of entrepreneurs, start-ups and wealthy families wishing to perpetuate their wealth in an optimal way through the generations.

The relationship of trust established with its customers over the long term is a source of satisfaction and daily motivation that allows APTELIS to maintain a high level of service.

APTELIS handles all types of issues, ranging from seemingly simple tax analyses to the most complex tax and legal planning issues.

Responsiveness, personalization, precision and reliability are the key words for long-term tax planning.

APTELIS and its employees are committed to respecting the privacy of its customers.

The purpose of this General Data Protection Policy is to describe how the personal data (hereinafter “Data”) that APTELIS collects or holds about its Clients is used and to whom this Data may be disclosed.

The processing of Data by APTELIS is subject to the applicable data protection laws in force in Switzerland, in particular the new Federal Act on Data Protection (hereinafter referred to as “nFADP”).

APTELIS is committed to:

  • use the Data only for the purposes indicated;
  • collect only the Data that is necessary for these purposes;
  • not to retain the Data for longer than is necessary for these purposes;
  • communicate the Data only to authorized bodies or persons who need it in the context of APTELIS’ activities;
  • inform its Clients in a clear and transparent manner about APTELIS’ use of the Data and their rights.


Patrick Renaud is the controller of the Personal Data concerned by this Policy and can be contacted by email at


APTELIS processing personal information, as described herein, will generally take place on one of the following legal bases:

  • Consent;
  • A contractual relationship with the client or a relevant party (e.g. mandate);
  • Legitimate business interests;
  • Compliance with legal obligations.


Customer Data is collected for the following purposes:

  • Offer and manage our products and services;
  • Comply with and apply applicable legal requirements, contractual obligations, and our policies and terms (Privacy Policy and other terms of use);
  • Maintain and improve the security of our products, services, network services, information resources, and employees.


The data collected includes:

  • Surname
  • Name
  • Date of birth
  • Gender
  • Cytizenship/s
  • Marital status
  • Telephone number
  • E-mail address
  • Tax and social security information such as taxpayer number, AHV number, salary certificates
  • Personal information necessary for the processing of a legal and tax advice file, including sensitive data (convictions/criminal offences, health)


Under the nFADP, Customers have the following rights:

Right of access – the Customer has the right, at any time and without giving reasons, to request copies of its Data from APTELIS.

Right to information – the Customer has the right to be informed about how their Data is being used. This policy, together with any additional information, is intended to provide that information.

Right to withdraw consent : where Data is processed on the basis of consent, consent may be withdrawn at any time.

Right to rectification – the Client has the right to request APTELIS to rectify inaccurate Data and complete incomplete Data.

Right to restriction of processing – the Customer may request to restrict the processing of the Data, if permitted by law

Right to erasure/deletion – the Customer has the right to request APTELIS to erase or delete the Data, unless there is a legal basis or APTELIS’ legitimate interest that obliges or authorizes it to retain the Data.

Right to object to processing – the Client has, at any time, the right to object to the processing of their Data.

Right to delivery or transmission of Data – the Client has the right to request the delivery or transmission of Data in a portable format when the processing of the Data is done in an automated manner, on the basis of consent or contract.

Right to lodge a complaint : if the Customer is not satisfied with the way in which the Data is processed, the Customer may apply to the courts or the Federal Data Protection Authority.

The exercise of these rights is free of charge. Any request relating to the processing of Data must be made to the following address


APTELIS may disclose Data to its employees, contractors, consultants and suppliers only in order to perform its tasks and provide its services and insofar as the legal conditions are met.

To protect the privacy and security of its Customers, APTELIS may take reasonable steps to verify their identity before granting access or making corrections.


Customer Data is only processed in Switzerland and is not transferred abroad.


Marketing communications (e.g., newsletters) from APTELIS relating to APTELIS activities may be sent to the Client, where the Client has opted in to receive them.

APTELIS marketing communications will always include the option for the Customer to unsubscribe from receiving any further marketing communications.

Customer may unsubscribe at any time by sending an email to  and requesting that its name be removed from APTELIS’ marketing lists.


APTELIS uses cookies and other technologies on its website to enable the collection of certain information from its Customers’ web browsers. Cookies are widely used on the Internet.

Cookies are small text files that are placed on the Customer’s computer by the websites visited. They are used to make websites work, or to make them work more efficiently, as well as to provide information to the owners of the site.

APTELIS may collect information about the Customer’s computer, including, where available, the Customer’s IP address, operating system and browser type for system administration. This is statistical data about APTELIS actions and browsing patterns and does not identify an individual.

Cookies help APTELIS improve its services and provide a more personalized service. They also help APTELIS to ensure that the Client has read any relevant legal information and to analyze how the APTELIS website is used.


APTELIS is committed to ensuring the permanent security of the Data.

Customers’ data is protected against unauthorised processing by organisational and technical measures in line with international standards, quality standards and technical progress, in particular against the risks of falsification, destruction, theft, loss, copying and other unlawful processing.

APTELIS takes reasonable and appropriate measures to maintain the confidentiality and integrity of the Data and prevent unauthorized use or disclosure of the Data in accordance with the nFADP.

This data, in particular its backups and data relating to Customer support activities, is hosted by a subcontractor in Switzerland.

APTELIS processes Data only in a manner compatible with the purpose for which it was collected.

To the extent necessary for these purposes, APTELIS takes reasonable steps to ensure that the Data is accurate, complete, current, and otherwise reliable with respect to its intended use.


APTELIS retains Data only for as long as necessary to achieve the purposes for which it was collected, to meet the needs of Customers and to comply with its legal obligations.

To establish the data retention period, APTELIS applies the following criteria:

  • for its services, APTELIS retains the Data for the duration of the services or the service contract;
  • if the Client has consented to receive marketing messages (e.g. Newsletters), APTELIS retains the Data until unsubscribed;
  • if cookies are placed on the Client’s computer, APTELIS retains the Data only for as long as necessary to achieve the purpose for which it was collected (e.g., during a session for registration-related cookies or session ID cookies);
    APTELIS may retain Data to fulfill APTELIS’ legal or regulatory obligations, and to allow APTELIS to exercise its rights (e.g. to bring an action in any court) or for statistical or historical purposes;
    When APTELIS no longer needs to use or retain the Data, APTELIS deletes it from its systems and files or anonymizes it so that it can no longer identify the Customer.


APTELIS reserves the right to change this policy at any time.

Any changes to this policy will be effective when APTELIS notifies its Customers and Business Partners.


In case of questions relating to data protection, an e-mail can be sent to the following address: or by writing to:

APTELIS Consulting SA
Rue du Marché 20
1204 Geneva


This policy was last updated on September 1, 2023