Privacy Policy

1. Who We Are

PTC (Pedro Torres Cobas), based in Basel, Switzerland, is the creator and owner of the intellectual property, content, frameworks, methodologies, programs, and services offered under the PTC brand and through ptorrescobas.com.

Commercial operations associated with PTC, including sales, marketing, commercial management, billing, events, and the delivery of certain products and services, are carried out in whole or in part by:

ONCKY GmbH Oetlingerstrasse 75A 4057 Basel Switzerland

ONCKY GmbH acts as an authorized commercial and operational partner of PTC.

2. Data Controller

Depending on the activity, service, and specific purpose involved, personal data may be processed by PTC (Pedro Torres Cobas), ONCKY GmbH, or both within the scope of their respective functions.

The determination of who acts as the data controller depends on who determines the purposes and essential means of the relevant processing activity.

Privacy and data protection contact:

Email: hello@ptorrescobas.com Telephone: +41 78 222 32 84 Postal address: Oetlingerstrasse 75A, 4057 Basel, Switzerland

Privacy-related inquiries may be directed to this contact point regardless of which entity is involved in the specific processing activity.

3. Scope of This Policy

This Privacy Policy applies to the processing of personal data in connection with:

• ptorrescobas.com, its subdomains, and landing pages
• forms and registrations
• email communications, newsletters, and messaging
• marketing and advertising campaigns
• events, workshops, seminars, and webinars, whether online or in person
• digital products, programs, memberships, and advisory services
• sales processes, customer service, and commercial management
• any other interaction with PTC or ONCKY where we determine the purposes and means of processing personal data

4. Personal Data We Collect

4.1 Data You Provide Directly

Depending on your interaction with us, we may collect:

• first and last name
• email address
• telephone number
• country and address
• professional information, such as company, position, or business activity
• interests, goals, or other information you choose to share
• registration information for events, webinars, workshops, or programs
• information relating to purchases, contracts, and billing
• messages, inquiries, and support requests
• responses to forms, surveys, or assessments

Complete payment card details are normally processed by specialized payment service providers and are not stored directly by us.

4.2 Data Collected Automatically

When you visit our websites or interact with our digital services, we may collect, depending on your location, settings, and privacy preferences:

• IP address
• approximate location derived from your IP address
• browser and device information
• operating system and technical information
• pages visited and actions performed
• approximate date, time, and duration of interactions
• referring page or URL
• cookies and similar technologies
• analytics and measurement data
• pseudonymous identifiers where applicable

The availability and extent of this information depend, among other factors, on applicable law, regional configuration, and your privacy preferences.

4.3 Marketing Attribution Data

When you access our websites through a campaign, link, advertisement, or other identifiable source, we may process attribution information to understand the origin of the visit or registration.

This information may include:

• utm_source
• utm_medium
• utm_campaign
• utm_content
• utm_term
• referring page or URL

When you voluntarily submit a form or register for one of our services, this attribution information may be associated with your record in our commercial management and CRM systems.

We use this information to identify the origin of registrations and conversions, evaluate the performance of campaigns and channels, improve our commercial and marketing activities, and make decisions regarding advertising investment.

We seek to limit this information to what is necessary for these purposes and to avoid adding additional technical identifiers where they are not required.

4.4 Optional Data

We may also process:

• information from public professional profiles when you interact with us through those platforms
• voluntary survey responses
• testimonials
• photographs, video, or event-related materials where applicable

We do not intentionally request sensitive personal data unless it is necessary for a specific purpose and an appropriate legal basis exists.

5. How We Use Your Personal Data

We may process personal data to:

• provide resources, content, or information you request
• manage registrations, accounts, and forms
• deliver programs, events, workshops, services, and advisory services
• process purchases, payments, and billing
• manage our relationships with customers and prospective customers
• respond to inquiries and provide support
• send newsletters and marketing communications where permitted
• measure the operation and use of our websites
• analyze the performance of content, campaigns, and channels
• attribute registrations and conversions to marketing campaigns or sources
• conduct and measure advertising campaigns
• improve our products, services, and digital experience
• protect our systems and prevent fraud or misuse
• comply with legal, tax, accounting, and regulatory obligations

Depending on the jurisdiction and the specific processing activity, we may rely on performance of a contract, steps taken prior to entering into a contract, consent, legitimate interests, legal obligations, or other legal grounds recognized by applicable law.

We do not currently use solely automated decision-making systems that produce legal effects or similarly significant effects on individuals.

6. Cookies, Analytics, and Similar Technologies

We use cookies and similar technologies to provide essential functionality, remember preferences, analyze the use of our websites and, where applicable, measure and optimize advertising campaigns.

These technologies may include services provided by:

• Google, including analytics and advertising services
• Meta
• LinkedIn
• YouTube
• Cloudflare
• other technology providers necessary to operate, analyze, protect, or promote our services

This list represents the main categories and providers that we use or may use and may change as our technology infrastructure evolves.

Strictly necessary technologies may be used for the operation, security, and delivery of the website.

Analytics and advertising technologies are managed according to applicable law, your location, and your privacy preferences.

More detailed information is available in our Cookie Policy, and you may modify your preferences at any time through Cookie Settings.

7. Analytics and Advertising

We use analytics tools to understand how our websites are used, measure their performance, and improve our content, products, and services.

We may also use advertising and measurement technologies to:

• measure campaigns
• attribute conversions
• understand advertising performance
• optimize campaigns
• create or manage audiences where legally permitted
• conduct remarketing or personalize advertising where applicable

We treat Analytics and Advertising as separate purposes.

The fact that an analytics tool may be permitted does not automatically mean that advertising, remarketing, or personalization technologies are authorized.

Technologies used or planned within our infrastructure include Google Analytics, Google Ads, Meta Pixel and related Meta technologies, LinkedIn Insight Tag, and other equivalent tools.

Their activation and operation may vary depending on your region and privacy preferences.

8. Processing According to Your Location

Privacy and tracking technology rules may vary depending on the location from which you access our services.

Switzerland

For certain statistical analytics activities, we may use a model based on transparent information and an effective opportunity to object, in accordance with applicable Swiss law.

Advertising technologies, profiling, and other processing activities that require consent are managed separately.

European Economic Area (EEA)

Where applicable law requires prior consent for analytics, advertising, or other non-essential technologies, those technologies remain disabled until you make the relevant choice.

United Kingdom

We apply an equivalent prior-consent approach where required by UK law for non-essential cookies and technologies.

United States

For visitors from the United States, we may use certain analytics technologies with transparent information and mechanisms to opt out, subject to applicable federal and state laws.

Certain states may provide additional rights relating to privacy, targeted advertising, or the sale or sharing of personal data.

Where such rights apply to our processing activities, you may exercise them in accordance with the applicable law.

Other Regions or Unknown Location

Where necessary, we apply a conservative configuration until we can determine the appropriate processing approach or receive your privacy preferences.

Location is determined reasonably using technical mechanisms and may not always be accurate, for example because of VPNs, corporate networks, or intermediary services.

9. Global Privacy Control and Privacy Preferences

Our systems recognize compatible Global Privacy Control (GPC) signals.

When we receive a technically valid GPC signal, we treat it as an indication of objection or opt-out for processing activities to which such a signal is legally applicable.

The specific effect of the signal may depend on the jurisdiction and the type of processing involved.

You may also manage your privacy preferences directly through Cookie Settings available on our website.

You may subsequently change or withdraw your preferences.

10. Service Providers and Recipients

To operate our services, we may use external service providers in categories such as:

• analytics and advertising
• CRM and commercial management
• email marketing and communications
• payment processing
• web hosting and cloud computing
• CDN, security, and fraud prevention
• video, meetings, and streaming
• productivity, storage, and collaboration
• accounting and administration

We may also disclose personal data, where necessary, to:

• legal, tax, and accounting advisers
• professional service providers
• administrative or judicial authorities where legally required
• other parties where necessary to establish, exercise, or defend legal rights

We require our service providers to process data in accordance with the contractual and legal obligations applicable to them.

We do not sell personal data.

11. International Data Transfers

Our service providers, collaborators, and technology infrastructure may involve the processing or storage of data outside Switzerland, including in the European Economic Area, the United Kingdom, the United States, and countries in Latin America.

Where personal data is transferred to a country that does not provide a level of protection recognized as adequate under applicable law, we use, where required, recognized mechanisms to protect the transfer, which may include:

• Standard Contractual Clauses
• recognized contractual safeguards
• applicable official transfer mechanisms
• supplementary technical and organizational measures
• legally permitted exceptions where appropriate

We assess international transfers in accordance with applicable legal requirements.

12. Data Retention

We retain personal data for as long as necessary for the purposes for which it was collected and to comply with our legal obligations.

As a general reference:

• newsletter contacts: while you remain subscribed or until you unsubscribe
• customer and commercial relationship data: during the relationship and thereafter where necessary to comply with legal obligations or defend legal rights
• contracts, invoices, and certain accounting records: in accordance with applicable statutory retention periods, which may extend to 10 years in Switzerland
• event and support records: for as long as necessary to manage the relationship and any related issues
• analytics data: according to the settings and retention periods established in the relevant tools

When personal data is no longer required, it is deleted, anonymized, or retained only where a legal obligation or other lawful basis requires or permits continued retention.

13. Your Rights

Depending on applicable law and your place of residence, you may have the right to:

• request information about the processing of your personal data
• access your personal data
• request correction of inaccurate data
• request deletion where applicable
• request restriction of certain processing activities
• object to certain processing activities
• object to direct marketing
• withdraw previously given consent
• request data portability where applicable
• exercise rights relating to certain forms of targeted advertising, sale, or sharing of personal data where applicable law provides such rights
• lodge a complaint with a competent data protection authority

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

To exercise your rights, contact:

hello@ptorrescobas.com

We may request information reasonably necessary to verify your identity before responding to certain requests.

Residents of Switzerland may also contact the Federal Data Protection and Information Commissioner (FDPIC/EDÖB). Where the GDPR or the law of another jurisdiction applies, you may also contact the relevant competent authority.

14. Communications and Direct Marketing

We may send communications relating to products, programs, events, content, or services where a legal basis exists to do so.

You may unsubscribe from newsletters and promotional communications through the unsubscribe mechanism provided in the relevant communication or by contacting us directly.

Communications necessary for a contractual relationship — such as purchase confirmations, event information, invoices, or service communications — may continue to be sent regardless of your marketing preferences.

Where we use messaging services or third-party platforms, the privacy policies of those providers may also apply.

15. Children

Our services are not primarily directed at children under the age of 16.

We do not intentionally collect personal data from children where such processing is not legally permitted.

Where applicable law requires parental consent or establishes a different age threshold for certain digital services, we will apply the relevant requirements.

If you believe that a child has provided us with personal data inappropriately, please contact us.

16. Security

We apply reasonable technical and organizational measures appropriate to the risk to protect personal data against unauthorized access, loss, alteration, disclosure, or misuse.

These measures may include:

• encryption during transmission
• access controls
• authentication
• permission management
• backups
• infrastructure security measures
• confidentiality obligations
• internal data management procedures

No technology system can guarantee absolute security.

17. Events, Recordings, and Testimonials

Our online or in-person events may include photographs, audio recordings, or video recordings.

Where we make recordings or use testimonials in a manner that requires specific information or consent, we will inform the individuals concerned and obtain consent where required.

18. Third-Party Links, Platforms, and Services

Our websites may contain links, embedded videos, social buttons, or other services provided by third parties.

When you choose to interact directly with those services, the relevant provider may process data under its own terms and privacy policies.

We do not control the independent privacy practices of third parties.

19. Changes to This Privacy Policy

We may modify this Privacy Policy to reflect changes in our services, technology infrastructure, business activities, or legal requirements.

The current version will be published on ptorrescobas.com and will indicate the date of the latest update.

Where a change is material and applicable law requires it, we will provide additional information or request consent again where appropriate.

20. Contact

For any questions regarding this Privacy Policy or the processing of your personal data:

ONCKY GmbH PTC / Pedro Torres Cobas Oetlingerstrasse 75A 4057 Basel Switzerland Email: hello@ptorrescobas.com Telephone: +41 78 222 32 84