Privacy Policy

The data controller responsible for the processing of your personal data on this website is:

Carolina Newton Group
c/o Office LAB AG, Bahnhofplatz 8, 8400 Winterthur, Switzerland
UID: CHE-242.226.427
Email: [email protected]

Carolina Newton Group does not have a designated Data Protection Officer. For all data protection enquiries, please contact us directly at the email address above.

Data type	How collected	Purpose	Legal basis
Name, email, phone	Contact forms, booking widget	Responding to enquiries, scheduling calls	Legitimate interest / contract performance
Email address	Newsletter / lead magnet sign-up	Sending marketing communications	Consent (opt-in)
Message content	Contact form submissions	Responding to your enquiry	Legitimate interest
Basic usage data	GoHighLevel platform	Website functionality, form processing	Legitimate interest
Booking details	LeadConnector booking widget	Scheduling strategy calls	Contract performance

We do not use Google Analytics or other third-party tracking tools on this website. We do not use advertising cookies or retargeting pixels.

We use your personal data exclusively for the following purposes:

To respond to enquiries. When you contact us via a form or email, we use your name and email address to reply to your message. We do not add you to any marketing list without your explicit consent.

To schedule and manage calls. Booking data submitted via our LeadConnector widget is used solely to arrange and confirm strategy calls.

To send newsletters and updates. If you subscribe to our mailing list, we use your email address to send you content relevant to digital presence in finance. You may unsubscribe at any time via the link in every email.

To improve our services. We may use aggregated, anonymised data to understand how our services are used and to improve them. This data cannot be traced back to individual users.

To use AI-assisted tools for internal processes. Carolina Newton Group uses large language model (LLM) tools to assist with internal operations such as content drafting, summarisation, and workflow automation. Where such tools process personal data, we take care to use only anonymised or aggregated information and do not submit identifiable client data to third-party LLM providers without a legitimate basis to do so.

We only share your personal data with third parties in the following circumstances:

Platform providers. All data submitted via this website is processed through GoHighLevel (GHL), our CRM and marketing platform. GoHighLevel is a US-based provider. Data transfers to the USA are governed by appropriate safeguards in accordance with applicable data protection law.

Service delivery. If you become a client of Carolina Newton Group, we may share your data with specific third-party service providers required to deliver the service you have contracted. This may include content production partners, social media automation tools, or analytics platforms. You will be informed of any such sharing at the time of engagement and, where required, your consent will be obtained.

Legal requirements. We may disclose your data where required to do so by law or in response to valid requests from public authorities.

We do not sell, rent, or trade your personal data to any third party for marketing purposes.

Data category	Retention period
Enquiry and contact data	2 years from last contact, unless a client relationship is established
Client data	Duration of the engagement plus 10 years (Swiss statutory retention for business records)
Invoice and financial records	10 years (Swiss Code of Obligations, Art. 958f)
Newsletter subscribers	Until unsubscription or withdrawal of consent
Booking data	12 months from the date of the scheduled call

Under the Swiss Federal Act on Data Protection (nDSG) and, where applicable, the EU General Data Protection Regulation (GDPR), you have the following rights:

Right of access — You may request confirmation of whether we process personal data about you and, if so, obtain a copy of that data.

Right to rectification — You may request correction of inaccurate or incomplete personal data we hold about you.

Right to erasure — You may request deletion of your personal data where there is no legitimate reason for us to continue processing it.

Right to restriction — You may request that we restrict the processing of your data in certain circumstances.

Right to data portability — Where processing is based on consent or contract, you may request a copy of your data in a structured, machine-readable format.

Right to withdraw consent — Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

Right to lodge a complaint — You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

This website uses only technically necessary cookies required for the website to function correctly. These cookies do not track you across other websites and do not collect any personal data beyond what is strictly necessary for the operation of the site.

We do not use analytics cookies, advertising cookies, or any form of third-party tracking. You do not need to provide consent for technically necessary cookies under Swiss law.

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. All data submitted through this website is transmitted over encrypted HTTPS connections. Access to personal data within our organisation is restricted to those who need it to perform their duties.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically. Where changes are material, we will notify active subscribers by email.