This cookie policy ("Cookie Policy") is part of the technical and organisational measures implemented by Banco Oro 9999 SA domiciliated Via Cantonale 1, 6900, Lugano, Switzerland (hereinafter the "Company", "we", "us", "our") to ensure its processing of personal data is performed in accordance with the Swiss Federal Data Protection Act 2020 ("FDPA"), Article 45c of the Telecommunications Act ("TCA"), as well as the guidelines issued by the Federal Data Protection and Information Commissioner ("FDPIC") on January 22, 2025 (the "Guidelines") with respect to the use of cookies on the Company's website available at the following address: https://orobanco.com/ (hereinafter the "Website").
1. What is a Cookie?
A 'cookie' is a small text file that is delivered by our Website server onto your computer whilst you visit our Website, which can generally be used by the website to identify particular devices and thereby remember your website preferences and login details. Most cookies will not collect information that identifies you and instead will collect more general information such as how you arrived at and used our Website, or your general geographical location.
2. Why Are Cookies Needed?
Cookies make websites work better and they are a standard part of most modern websites. For example, they remember the items you've placed in your online shopping cart so that the items appear at the checkout when you make your purchase. Another example would be when you login to webmail services such as Hotmail or Gmail: on such occasions a cookie is generated that confirms you are logged in and when you log off, the cookie is deleted. This means if someone goes back to your webmail address on your computer, you will still be logged out – and they won't be able to read your emails.
3. Types of Cookies
Cookies can be classified based on several specifications that help to understand their nature and function:
Issuer of cookies:
First-party cookies: these are created and managed directly by the owner of the website that the user is visiting. Their installation occurs directly from the domain that the user has chosen to access.
Third-party cookies: in contrast, these cookies are set by domains external to the website the user is visiting. This happens because the website contains elements that reside on servers different from that of the visited website, allowing third parties to collect data during browsing.
Duration of cookies:
Session cookies: these cookies are temporary, tied to the user's browsing session, and are automatically deleted when the browser is closed. They do not retain any type of information about the user in the long term.
Persistent cookies: these types of cookies remain on the user's device for a predefined period, even after the browser is closed. They are used to remember the preferences or actions of the user for future visits, providing quicker and more convenient navigation.
We exclusively use first-party cookies, ensuring that no cookie data is shared, transmitted, or disclosed to third parties. All cookies, along with any personal data collected in association with them, are securely stored on our self-hosted infrastructure within Swiss territory. Additionally, we utilize both session cookies and persistent cookies, as detailed in Section 4 below.
Purpose of cookies:
Technical cookies: essential for navigating within a website and using all its features, such as accessing restricted areas. Without these cookies, some necessary operations, like logging into the website could not be performed.
Analytics cookies: these cookies collect information about users' use of a website, such as the most visited pages and any error messages received. The information is collected aggregately, without identifying individual users, to improve the functioning of the website.
Profiling cookies: they aim to create user profiles in order to send advertising messages in line with the preferences shown during browsing. These cookies can be used to present more relevant content or limit the number of times content is viewed. Generally, they are cookies managed by third parties.
We employ only technical cookies for statistical purposes (as described in Section 4 below) for monitoring, as a way of example, the streams of visitors on the Website. Therefore, we justify the use of such cookies in accordance Article 31 par. 2 letter e) of the FADP and point 3.8.2. of the Guidelines namely we ensure the following:
- all personal data collected is anonymised as soon as the user lands on the Website;
- if the matter involves sensitive personal data, we shall disclose such data to third parties in such a manner that the data subject is not identifiable; if this is not possible, it must be guaranteed that the third parties only process the data for purposes unrelated to the data subject's person; and
- the results are published in such a manner that data subjects are not identifiable.
In general, many websites employ other kind of cookies including but not limited to:
Marketing Cookies:
For example, the use of Google Analytics helps website managers improve their websites by collecting and reporting information on how users interact with them. However, such cookies can be configured to collect information in a way that does not directly identify individuals.
Social Media Cookies
Social media cookies allow users to interact more easily with social media, such as Facebook, Twitter, LinkedIn, Instagram, YouTube etc. Please refer to the relevant social media platforms privacy policies for information about this kind of cookies.
4. What Cookies Do We Use?
We collect your data automatically via cookies when you visit our Website, in line with the cookie settings in your browser.
We use cookies to track your activity to help ensure you get the best possible experience when visiting our Website.
We do not make any attempt to discover the identities of anyone who visits our Website, and we will not associate any of the data gathered from our Website with any personally identifiable information from any source. If we do want to collect personally identifiable information through our Website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
The Website employs technical and analytical cookies, ensuring uninterrupted browsing, examining traffic volume and user engagement, as well as for system management purposes. The gathered information is processed anonymously.
The Website does not use cookies for profiling activities.
5. Turn Off Cookies
You can turn off cookies for a particular website or several websites, by adjusting your browser settings to prevent it from accepting cookies. You can follow the links below:
It's important to note that turning off cookies is likely to limit the functionality of not only our Website, but also the functionality of a large number of the world's websites, and accordingly, your experience of ours and other websites may be impaired because data is no longer being captured about your interactions.
It may be that your concerns around cookies relate to so called "spyware" and in which case, rather than switching off cookies in your browser, you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.
There are other methods to reduce the risk of online tracking, including using the "private" or "anonymous" browsing functionality of your browser (if available), which prevents cookies from being retained on your device after browsing.
6. Changes to Our Cookie Policy
The content of both this 'Cookie Policy' and of the 'Cookie Banner' will be reviewed regularly by the Company, and the information contained therein shall be updated where necessary to reflect the true use of cookies by the Company.