Privacy Policy of www.tlr-sa-ch
This Application collects personal data from its users.


Policy summary

Personal Data is gathered for the following purposes and using the following services:

  •  Statistics
  • Google Analytics
    Personal Data: Cookies and Usage data


Contact Information
Data Protection Holder
dlcom Sagl
Via Cortivallo 29
CH-6900 Lugano
Data protection holder’s e-mail address:


Complete Policy

Data Protection Holder
dlcom Sagl
Via Cortivallo 29
CH-6900 Lugano
Data protection holder’s e-mail address:


Types of data collected
The personal data gathered by this Application, independently and through third parties, includes: Cookie and usage data.
Complete details on each type of data collected are outlined in specific sections of this privacy policy or through specific informative texts visualised before the gathering of the data itself.
Personal data either can be directly provided by the clients or, in the case of the Usage data, be gathered automatically during the usage of this Application.
If not specified otherwise, all data requested by this Application are mandatory. If the user refuses to share them, it could be impossible for this Application to provide the Service. In case this Application indicates some optional data, the Users are free to abstain from sharing it, without it having any consequences on the availability of the Service or its operability.
Users who might have doubts regarding which data is optional are encouraged to contact the Data protection holder.
The possible usage of Cookie – or other tracking instruments – from this Application or from the Data protection holders of third party services used by this Application, if not otherwise stated, has the purpose of providing the Service requested to the user, as well as the other purposes described in the present document or in the Cookie Policy, if available.
The User assumes the responsibility of third parties’ personal data obtained, published or shared through this Application and guarantees the right to communicate or share them, therefore freeing the Data protection holder from any responsibility toward third parties.


Mode and place of processing of data collected
Mode of processing
The Data protection holder adopts appropriate security measures in order to impede unauthorised access, sharing, modifying or destruction of personal data.
The processing is carried out through computer and/or telematics instruments, with organisational modalities and logics strictly correlated to the indicated purposes. In addition to the Data protection holder, in some cases, other individuals involved in the organisation of this Application (administrative, commercial, marketing, legal personnel and system administrators) as well as external individuals (such as suppliers of services, third party technicians, postal courier, hosting providers, computer companies, communication agencies), also called, if necessary, Data Protection Holder by the Owner, could have access to the data. The updated list of the Officials can always be requested from the Data protection Holder


Legal Basis of the processing
The Data protection holder will process the User’s personal data in the following situations:

  • the User has granted permission for one or more specific purposes; Note: in some systems the Data protection holder can be authorised to process personal data without the user’s consent or any of the legal basis here specified, until the User decides to opt-out from such processing. However, this is not applicable whether the processing of personal data is regulated by the EU data protection legislation;
  • the processing is necessary for the implementation of a contract with the User and/or for the implementation of precontractual measures;
  • the processing is necessary to fulfil a legal obligation to which the Data protection holder is subject;
  • the processing is necessary for the implementation of a task of public interest or for the exercise of public authority in which the Data protection holder is invested;
  • the processing is necessary for the pursuit of the legitimate interest of the Data protection holder or of third parties.

It is however always possible to request clarifications on the legal basis of processing to the Data protection holder and, in particular, to specify whether the processing is based on the law, established by a contract or necessary to conclude a contract.


The Data is processed at the operative locations of the Data protection holder and in any other location in which the parties involved in the processing are based. For further information, contact the Data protection holder.
User’s personal data could be transferred to a country different from the one in which the User is located.
To obtain further information on the location of the processing, the User can refer to the section related to the details on personal data processing.
The User has the right to obtain information regarding the legal basis of the transfer of data outside the European Union or to an international organisation with public international law or constituted by two or more countries, for example ONU, as well as regarding security measures adopted by the Data protection holder in order to protect the data.

In case any of the above transfers take place, the User can refer to the respective sections of this documents or request information from the Data protection holder by contacting him/her using the information provided at the beginning of the document.


 Data Retention Period
Data is processed and retained for the period of time needed for the purposes for which it was collected.

  • Personal data collected for purposes connected to the implementation of a contract between the Data protection holder and the User will be held until the completion of the implementation of such contract.
  • Personal data collected for purposes attributable to the legitimate interest of the Data protection holder will be held until fulfilment of the interest. The User can obtain further information regarding the legitimate interest pursued by the Data protection holder in the related sections of this document or by contacting the Data protection holder.

When the processing is based on the User’s consent, the Data protection holder can hold on to personal data for a longer period of time, until such consent is revoked. Moreover, the Data protection holder could be obligated to retain personal data for a longer period of time in compliance with a legal obligation or because of an authority orders.

At the end of the period of retainment personal data will be cancelled. Therefore, at the expiry of such period, the right of access, cancellation, rectification and the right to data portability will not be exercised any longer.


Purpose of the processing of collected data
User’s data is gathered in order to allow the Data protection holder to provide its Services, as well as for the following purposes: Statistics.
To obtain further detailed information about the intent of processing and on personal data, relevant for each purpose, the User can refer to the relative sections in this document.


Details on personal data processing
Personal data is collected for the following purposes and utilising the following services:

The services included in the present section allow the Data protection holder to monitor and analyse the traffic data and are needed to keep track of the User’s behaviour.

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises personal data collected with the purpose of tracing and examining the usage of the Application, filling out report and sharing them with the other services developed by Google.
Google could utilise personal data to contextualise and personalise advertisements of its own publicity network.
Personal data gathered: Cookie and Usage data
Processing location: USA – Privacy PolicyOpt Out.

User’s Rights
Users can exercise specific rights regarding the data processed by the Data protection holder.
In particular, the User has the right to:

  • Revoke the consent at every moment. The User can revoke the processing of his/her personal data consent previously expressed.
  • Oppose the processing of his/her data. The User can oppose the processing of his/her data when this happens on a different legal basis than the one specified in the consent. Further details on the right of opposition are indicated in the section below.
  • Access to personal data. The User has the right to obtain information on the data processed by the Data protection holder, on specific aspects of the processing and to receive a copy of the data being processed.
  • Verify and request the rectification. The User can verify the accuracy of his/her personal data and request the update or the correction of it.
  • Obtain limitations on data protection. In specific situations, the user can request the limitation of his/her personal data processing. In such case, the Data protection holder will not process the data for any other purpose than for its preservation.
  • Obtain the cancellation or removal of personal data. In specific situations, the User can request the cancellation of his/her personal data to the Data protection holder.
  • Receive personal data or transfer it to a different data protection holder. The User has the right to receive his/her personal data in an organised format, commonly used and legible by an automatic device and, where technically possible, to obtain the transfer without obstacles to a different Data protection holder. This instruction is applicable when the data is processed with automatic instruments and the processing is based on the consent of the User, specified in a contract which either includes the User directly or includes contractual measures related to the User.
  • File a complaint. The User can file a complaint to the authority in charge of controlling the protection of personal data or act in a court of law.

Details on the right of opposition
When personal data is processed in the public interest, in exercise of public authority, in which the Data protection holder is invested or in order to pursue a legitimate interest of the Data protection holder, the Users have the right of opposition to the processing for reasons related to their particular situation.
It is important for the Users to note that in case their personal data was going to be used for direct marketing purposes, they could oppose the processing without providing any justification. In order to find out if the Data protection holder is processing data with direct marketing purposes the Users can refer to the related sections in this document.

How to exercise rights
In order to exercise the User’s rights, the Users can send a request to contact details of the Data protection holder indicated in this document. The requests are deposited free of charge and handled by the Data protection holder in the shortest amount of time possible (or as soon as possible), or otherwise within a month.


Cookie Policy

Cookies consist of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes for which Cookies are installed may also require the User’s consent.

Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document.


Technical Cookies and Cookies serving aggregated statistical purposes

  • Activity strictly necessary for the functioning of the Service

This Application uses Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of this Application, for example in relation to the distribution of traffic.


  • Activity regarding the saving of preferences, optimization, and statistics
    This Application uses Cookies to save browsing preferences and to optimize the User’s browsing experience. Among these Cookies are, for example, those used for the setting of language and currency preferences or for the management of first party statistics employed directly by the Owner of the site.

Other types of Cookies or third parties that install Cookies
Some of the services listed below collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.

If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

How to provide or withdraw consent to the installation of Cookies
In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies.
Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google ChromeMozilla FirefoxApple Safari and Microsoft Internet Explorer.

With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party’s privacy policy, or by contacting the third party.

Notwithstanding the above, the Owner informs that Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.


Further information on data processing
Defence of judgement
User’s personal data can be used by the Data protection holder in the verdict or in the preparatory phases of his/her potential intraduction for the defence from abuses in the usage of this Application or of the Services connected by the user.

The User declares to be aware of the fact that the Data protection holder could be obligated to reveal data by the order of public authorities.

Specific Information
At the request of the User, in addition to the information included in this privacy policy, this Application could provide additional and contextual information to the user regarding specific Services, or the collecting and processing of personal data.

System log and maintenance
Due to necessities connected to functioning and maintenance, this Application and the potential third parties’ services it uses could gather system log, that is files that register interactions and that can contain personal data, such as the User’s IP address.

 Information not included in this policy
Further information related to personal data processing can be requested at any moment from the Data protection holder by using the contact information provided.

Answer to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To find out if the possible utilised services provided by third parties support them the User is invited to consult the respective privacy policy.

Modifications to this privacy policy
The Data protection holder reserves the right to modify the present privacy policy at any moment, giving information to the Users on this page and, if possible, on this Application as well as, if technically and legally possible, sending a notification to the Users through one of the contact information, which the Data protection holder possesses. Please regularly consult this page by paying careful attention to the latest modification date indicated at the bottom.

In case, the modifications are related to data processing of which the legal basis and the consensus, the Data protection holder will provide for the new collection of the User’s consensus, if necessary.


Definition and legal references
Personal Data (or Data)
Personal Data refers to any information that, directly or indirectly, also in connection with any other information, such as s personal identification number, makes a physical person identified or identifiable.

Utilisation Data
This is the information automatically collected through this Application (also through third party applications integrated in this Application), including: IP addresses or domain name of the computers utilised by the User that connects with this Application, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method utilised to send the request to the server, the dimension of the file received in response, the numerical code indicating from the server response (success, error, etc.), the country of origin, the characteristics of the browser and of the operative system utilised by the visitor, the different temporary connotations of the visit (for example the time spent on each page) and the details related to the itinerary followed within the Application, with particular emphasis on the sequence of the pages consulted, the parameters related to the operative system and the IT environment of the User.

The individual that utilises this Application that, if not otherwise specified, coincides with the relevant person.

Relevant person
The individual to whom the personal data is connected

Responsible of the processing
The physical or legal person, the public administration or any other entity that processes personal data on behalf of the Data protection holder, following what is stated in the present privacy policy.

Data protection holder
The physical or legal person, the public authority, the service or other organisation that, singularly or together with others, determines the purposes and the means of personal data processing and the instruments used, including security measures related to the functioning and fruition of this Application. The Data protection holder of the processing, if not otherwise specified, is the owner of this Application.

The Application
The hardware or software instrument through which Users’ personal data is gathered and processed.

The Service
The Service provided by this Application, defined by the relative terms (if present) on this site/application.

European Union (or EU)
If not otherwise specified, any reference to the European Union included in this document is to be intended as extended to all the present member states of the European Union and in the European Economic Space.

A small portion of data stored inside the User’s device.

Legal references
The present privacy policy is drafted on the basis of multiple legislative systems, including art. 13 and 14 of the Regulations (EU) 2016/679.
If it is not otherwise specified, this privacy policy refers exclusively to this Application.

Latest update: August 29, 2018