Privacy Policy


Last updated:

1. Data Controller

ASKO SA
Via Ceresio 43, 6963 Lugano, Switzerland
E-mail: privacy@twm.one

This Privacy Policy is drafted in accordance with the Swiss Federal Act on Data Protection (nLPD, RS 235.1) and, where applicable, the EU General Data Protection Regulation (GDPR – Regulation (EU) 2016/679).

2. Personal Data Collected

2.1 From the website

  • Full name, retained for up to 24 months from creation or last access, then deleted unless session renewed by the user
  • Email address, retained for up to 24 months from creation or last access, then deleted unless session renewed by the user
  • Session and consent cookie UUID, retained for up to 24 months or until consent revoked
  • Technical navigation logs (IP, timestamp, pages visited), retained for up to 6 months

2.2 From the TWM software

  • Machine ID (device identifier), retained until uninstall or deletion request
  • Trading order details sent to Trading Providers, deleted immediately after transmission

2.3 Not collected or stored

  • API keys, always stored locally on the user computer
  • Hardware data (CPU, RAM, GPU)
  • Account balances, wallets, or full financial history

4. Data Protection Officer (DPO)

No DPO has been appointed, as ASKO SA employs fewer than 250 people and does not carry out large-scale systematic monitoring (Art. 37 GDPR; Art. 10 nLPD).

ASKO SA reserves the right to appoint a DPO in the future if the scope or nature of the processing activities makes it necessary.

5. Data Protection Impact Assessment (DPIA)

A DPIA is not required for third-party analytical tools, as no internal large-scale systematic monitoring is carried out (Art. 35 GDPR).

Nevertheless, ASKO SA performs periodic privacy risk assessments to ensure that technical and organizational measures remain adequate to the processing context.

7. Retention, Deletion, and Administrative Costs

  • Registration and web profile data: retained for up to 24 months from creation or last access.
  • Technical logs: retained for 6 months.
  • Trading orders: deleted immediately after transmission.

Data deletion is carried out securely and irreversibly, both on digital and physical media. Retention periods may be extended to meet legal, accounting, or judicial obligations.

Deletion and portability rights are fulfilled upon request, with delivery in a common format.

Administrative fees: up to CHF 300 for disproportionately burdensome requests (Art. 19 OPDa).

8. Cookies and Tracking

8.1 Types of Cookies Used

8.1.1 Necessary Cookies

These cookies are essential for the website to function and cannot be disabled:

  • UserUUID: Technical identifier for consent management (12 months)
  • consent: Stores your cookie preferences (12 months)
  • site_mode: Stores the navigation mode selected or inferred during browsing, for example to keep the user within the standard homepage flow or the /start-trading flow when using shared navigation elements such as the site logo (up to 30 days)
  • .AspNet.Consent: Session consent indicator (1 year)
  • .AspNetCore.Cookies: Authentication and session management (1 year)
  • .AspNetCore.Antiforgery: Security against CSRF attacks (session)
  • .AspNetCore.Culture: Language preferences (1 year)

The site_mode cookie is used exclusively to preserve the user’s current navigation context across pages. It does not perform profiling, analytics, or advertising functions and is not used to identify the user personally.

Legal basis: Legitimate interest for technical functionality (Art. 6(1)(f) GDPR; Art. 14(1)(f) nLPD).

8.1.2 Functional Cookies

These cookies improve your experience but require your consent:

  • Google cookies for Maps integration and service personalization (LSOLH, COMPASS, ACCOUNT_CHOOSER, APISID, LSID, NID, SAPISID, __Host-GAPS)

Legal basis: Explicit consent (Art. 6(1)(a) GDPR; Art. 14(2)(a) nLPD).

8.1.3 Statistical/Analytical Cookies

Used for anonymous or pseudonymous website analytics and performance measurement:

  • Google Analytics 4: _ga, _gid, _gat (anonymized before processing where applicable)
  • Microsoft Clarity: CLID, MR, SM

Data collected through these tools are used to measure website usage, performance, and interactions, and may be processed in aggregated or pseudonymized form depending on the provider and configuration.

Legal basis: Explicit consent (Art. 6(1)(a) GDPR; Art. 14(2)(a) nLPD).

8.1.4 Marketing/Advertising Cookies

Used for personalized advertising, remarketing, campaign attribution, and cross-platform measurement:

  • Google DoubleClick / Google Ads: test_cookie, IDE, DSID, FLC, AID, TAID, ADS_VISITOR_ID, OTZ, __gads, __gac, NID, UULE
  • Google account and personalization cookies on embedded Google services: SAPISID, SID, SIDCC, SSID, HSID, SEARCH_SAMESITE
  • Microsoft Advertising: ANONCHK, MUID
  • Meta / Facebook: datr, fr, sb, xs
  • TikTok Advertising / Tracking: ttcsid, ttcsid_D5GFV53C77U3VC0C2T50, odin_tt, tt_chain_token, ttwid

These cookies may be used by their respective providers to recognize browsers, measure conversions, attribute campaigns, personalize advertisements, and support retargeting across websites or devices.

Legal basis: Explicit consent (Art. 6(1)(a) GDPR; Art. 14(2)(a) nLPD).

8.2 Consent Management

The cookie banner appears on the first visit and is renewed:

  • Every 12 months from last consent
  • When site or code changes introduce new cookies
  • After browser cache/cookies are cleared

You can manage consent through three options:

  • "Accept All": Accepts all cookie categories
  • "Accept Selected": Accepts only chosen categories (functional, statistical, marketing)
  • "Only Necessary": Only essential cookies (same as clicking "X")

Prior blocking: No tracking or marketing cookies are set before you give explicit consent. Scripts from Google Analytics, Google Tag Manager, Microsoft Clarity, and DoubleClick are blocked until consent is granted.

8.3 Withdrawal of Consent

You can withdraw consent at any time by:

  • Clicking the cookie icon at the bottom-left of the page
  • Accessing the Cookie Statement via the privacy policy
  • Clearing your browser cookies manually

Effect of withdrawal: When you revoke consent:

  • First-party cookies (_ga, _gid, etc.) are deleted immediately
  • Tracking scripts (Google Analytics, GTM, Clarity) are blocked
  • Third-party cookies (test_cookie, IDE) may remain temporarily but are no longer used or renewed
  • Third-party cookies expire automatically (e.g., test_cookie expires in 15 minutes)

8.4 Third-Party Data Controllers

8.4.1 Google LLC / Google Ireland Limited

Google services used on the website may include Google Analytics 4, Google Tag Manager, Google Ads, DoubleClick, Google Maps, YouTube embeds, and other Google-delivered content or security components.

Depending on the service and browser state, Google may set cookies such as _ga, _gid, _gat, IDE, NID, OTZ, AID, ADS_VISITOR_ID, SAPISID, SID, SIDCC, SSID, HSID, SEARCH_SAMESITE, UULE and related identifiers.

Google acts as an independent data controller for the data it collects through its own services. Data transfers may rely on the EU–US Data Privacy Framework and the Swiss–US Data Privacy Framework, where applicable.

Google's privacy terms: policies.google.com/privacy

Google Analytics opt-out: tools.google.com/dlpage/gaoptout

Google Ads settings: adssettings.google.com

8.4.2 Microsoft Corporation

Microsoft services may include Microsoft Clarity and Microsoft Advertising technologies. Cookies may include CLID, MR, SM, ANONCHK, MUID.

Microsoft acts as an independent data controller for the data collected through its services. Data transfers may rely on the EU–US Data Privacy Framework and the Swiss–US Data Privacy Framework, where applicable.

ASKO SA does not use these tools to identify users directly. Microsoft's privacy terms: privacy.microsoft.com

8.4.3 Meta Platforms Ireland Limited / Meta Platforms, Inc.

Meta services may be used for advertising, conversion measurement, or embedded social content. Cookies observed may include datr, fr, sb, xs.

These cookies may support browser recognition, fraud prevention, ad delivery, measurement, and personalization across Meta services and partner sites.

Meta acts as an independent data controller for processing carried out through its own services and technologies.

Meta privacy terms: facebook.com/privacy/policy

8.4.4 TikTok Technology Limited / TikTok Information Technologies UK Limited / ByteDance group entities

TikTok technologies may be used for campaign attribution, analytics, event measurement, and advertising optimization. Cookies observed may include odin_tt, tt_chain_token, ttcsid, ttcsid_D5GFV53C77U3VC0C2T50, ttwid.

These cookies may be used to measure site interactions, attribute visits and conversions, and support ad delivery or performance reporting across TikTok services.

TikTok acts as an independent data controller for processing performed through its own tracking and advertising technologies.

TikTok privacy terms: tiktok.com/legal/page/eea/privacy-policy/en

8.5 Cookie Lifespan and Storage

Cookie Name Type Duration Provider
UserUUIDNecessary12 monthsASKO SA
consentNecessary12 monthsASKO SA
site_modeNecessaryUp to 30 daysASKO SA
.AspNet.ConsentNecessary1 yearASKO SA
.AspNetCore.CookiesNecessary1 yearASKO SA
.AspNetCore.AntiforgeryNecessarySessionASKO SA
.AspNetCore.CultureNecessary1 yearASKO SA
_ga, _gid, _gatStatisticalVaries by cookieGoogle Analytics
CLID, MR, SMStatisticalVaries by cookieMicrosoft Clarity
IDE, DSID, FLC, AID, TAID, ADS_VISITOR_ID, OTZ, NID, UULEMarketingVaries by cookieGoogle / DoubleClick
SAPISID, SID, SIDCC, SSID, HSID, SEARCH_SAMESITEFunctional / Marketing / Security depending on contextVaries by cookieGoogle
ANONCHK, MUIDMarketingVaries by cookieMicrosoft
datr, fr, sb, xsMarketing / SecurityVaries by cookieMeta / Facebook
ttcsid, ttcsid_D5GFV53C77U3VC0C2T50, odin_tt, tt_chain_token, ttwidMarketingVaries by cookieTikTok

8.6 How to Disable Cookies in Your Browser

You can configure your browser to refuse cookies:

  • Chrome: Settings → Privacy and security → Cookies and other site data
  • Firefox: Settings → Privacy & Security → Cookies and Site Data
  • Safari: Preferences → Privacy → Block all cookies
  • Edge: Settings → Cookies and site permissions

Note: Blocking all cookies may affect website functionality.

8.7 Additional Information

For detailed information about each cookie, including purposes, categories, and third-party providers, please refer to our Cookie Statement accessible from every page via the cookie icon.

The cookie banner and cookie statement may include cookies from ASKO SA and from third-party providers such as Google, Microsoft, Meta, and TikTok, depending on the services enabled on the site and the user’s consent choices.

The complete list of cookies currently detected and categorized is also displayed in the cookie banner under the "Details" tab.

9. Data Sharing

Trading Providers receive only the data necessary for order execution, which are then immediately deleted.

ASKO SA may use third-party service providers and platforms for analytics, advertising, attribution, embedded content, and technical service delivery, including providers such as Google, Microsoft, Meta, and TikTok, depending on the services enabled on the website and the user’s consent choices.

These providers may act as independent data controllers for the data collected through their own cookies, tags, pixels, SDKs, or embedded services, under their respective privacy policies.

All service providers are selected to ensure appropriate security and confidentiality standards in accordance with Art. 8 nLPD.

No personal data is sold, traded, or shared for marketing purposes.

11. Data Subject Rights

Requests for access, rectification, erasure, restriction, objection, portability, and withdrawal of consent are handled:

  • Within 72 hours if submitted via e-mail or support form
  • Within 9 business days if submitted by post

Users also have the right to contact the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland for complaints regarding data processing.

12. Updates to This Policy

Material changes will be communicated via e-mail.

Non-material changes will update the “Last updated” date at the top of this page.

Continued use of the services after an updated version is published constitutes acceptance of the new policy.

13. Contacts and Support

ASKO SA – TWM
Via Ceresio 43, 6963 Lugano, Switzerland
E-mail: privacy@twm.one
Technical support: twm.one/support

Requests to exercise data rights must include a unique identifier (such as the registered e-mail address) to verify the requester’s identity.

Necessary cookies help make the website usable by enabling basic functions such as consent storage, security protection, language preferences, authentication, and preserving the active navigation context.

  • Necessary cookies

    UserUUID

    Technical identifier used to manage and persist cookie consent preferences.

    Maximum storage duration: 12 Months | Type: Necessary cookies
    consent

    Stores your cookie consent choices and selected preferences.

    Maximum storage duration: 12 Months | Type: Necessary cookies
    site_mode

    Preserves the active navigation context, for example keeping the user in the standard website flow or the Start Trading flow when shared navigation elements are used.

    Maximum storage duration: Up to 30 Days | Type: Necessary cookies
    .AspNet.Consent

    Indicates whether the user has provided cookie consent.

    Maximum storage duration: 1 Year | Type: Necessary cookies
    .AspNetCore.Antiforgery

    Used to prevent CSRF attacks and protect form submissions and user data.

    Maximum storage duration: Session | Type: Necessary cookies
    .AspNetCore.Cookies

    Used to manage authentication information and signed-in sessions.

    Maximum storage duration: 1 Year | Type: Necessary cookies
    .AspNetCore.Culture

    Stores the user’s language and localization preferences.

    Maximum storage duration: 1 Year | Type: Necessary cookies

Functional cookies allow the website to remember preferences and support enhanced features or integrations such as Google services, maps, embedded media, or account-related personalization.

  • Functional Cookies

    LSOLH

    Used by Google to store session information and support service-related functionality.


    Maximum storage duration: Session | Type: Functional Cookies
    COMPASS

    Used by Google to remember settings and improve navigation across integrated services.

    Maximum storage duration: 6 Months | Type: Functional Cookies
    ACCOUNT_CHOOSER

    Remembers which Google accounts have been used on the device.

    Maximum storage duration: 1 Year | Type: Functional Cookies
    APISID

    Used by Google to store preferences and information when using integrated Google services such as Maps.

    Maximum storage duration: 2 Years | Type: Functional Cookies
    LSID

    Used by Google to store preferences while viewing pages that incorporate Google services.

    Maximum storage duration: 2 Years | Type: Functional Cookies
    SAPISID

    Used by Google services to support embedded content, maps, and account-related personalization.

    Maximum storage duration: 2 Years | Type: Functional Cookies
    __Host-GAPS

    Used by Google to support service preferences and related functionality on pages integrating Google services.

    Maximum storage duration: 2 Years | Type: Functional Cookies

Statistical cookies help us understand how visitors interact with the site, measure traffic, and improve services. Data is processed in aggregated or pseudonymized form by providers such as Google and Yandex.

  • Statistical Cookies

    _ga, _ga_*

    Google Analytics cookies used to distinguish users and sessions for traffic measurement and site usage analysis.


    Maximum storage duration: 2 Years | Type: Statistical Cookies
    _gid

    Google Analytics cookie used to distinguish users within a single day session.

    Maximum storage duration: 24 Hours | Type: Statistical Cookies
    _ym_uid

    Yandex Metrica unique visitor identifier used to distinguish users across sessions.

    Maximum storage duration: 1 Year | Type: Statistical Cookies
    _ym_d

    Yandex Metrica cookie that stores the date of the user's first visit.

    Maximum storage duration: 1 Year | Type: Statistical Cookies
    _ym_isad

    Yandex Metrica cookie used to detect whether the user has an ad blocker enabled.

    Maximum storage duration: 2 Days | Type: Statistical Cookies
    _ym_visorc

    Yandex Metrica Webvisor cookie used to record and replay user sessions for usability analysis.

    Maximum storage duration: 30 Minutes | Type: Statistical Cookies

Marketing cookies are used for advertising, campaign attribution, conversion tracking, personalization, and cross-platform measurement by providers such as Google, Microsoft, Meta, and TikTok.

  • Marketing Cookies

    AID

    Used by Google to link activity across devices and improve ad attribution.


    Maximum storage duration: 1 Year | Type: Marketing Cookies
    ANONCHK

    Used by Microsoft Advertising to validate and support ad-related requests.

    Maximum storage duration: 10 Minutes | Type: Marketing Cookies
    MUID

    Microsoft advertising identifier used to recognize browsers across Microsoft domains.

    Maximum storage duration: 13 Months | Type: Marketing Cookies
    __Secure-3PSID, __Secure-3PAPISID, __Secure-3PSIDTS, __Secure-3PSIDCC

    Google advertising and personalization cookies used to build preference profiles and support ad delivery.

    Maximum storage duration: 2 Years | Type: Marketing Cookies
    ADS_VISITOR_ID

    Used by Google to identify visitors for advertising and attribution purposes.

    Maximum storage duration: 2 Years | Type: Marketing Cookies
    OTZ

    Used by Google to support ad personalization and service optimization.

    Maximum storage duration: 1 Month | Type: Marketing Cookies
    __Secure-1PAPISID, __Secure-1PSID

    Google cookies used to support more relevant ads and account-related ad security.

    Maximum storage duration: 2 Years | Type: Marketing Cookies
    IDE, DSID, FLC

    DoubleClick / Google Ads cookies used for campaign attribution, ad delivery, and remarketing.

    Maximum storage duration: Varies by cookie | Type: Marketing Cookies
    datr, fr, sb, xs

    Meta / Facebook cookies used for browser recognition, security, ad measurement, and personalization across Meta services and partner sites.

    Maximum storage duration: Varies by cookie | Type: Marketing Cookies
    ttcsid

    TikTok identifier used for session-level event attribution, conversion tracking, and advertising measurement.

    Maximum storage duration: Varies by configuration | Type: Marketing Cookies
    ttcsid_D5GFV53C77U3VC0C2T50

    TikTok pixel-specific session cookie used for conversion attribution and advertising performance reporting.

    Maximum storage duration: Varies by configuration | Type: Marketing Cookies
    odin_tt

    TikTok cookie used for campaign attribution, browser recognition, and advertising performance measurement.

    Maximum storage duration: Varies by cookie | Type: Marketing Cookies
    tt_chain_token

    TikTok cookie used for event attribution and campaign linkage across sessions.

    Maximum storage duration: Varies by cookie | Type: Marketing Cookies
    ttwid

    TikTok browser identifier used for attribution, advertising measurement, and remarketing support.

    Maximum storage duration: Varies by cookie | Type: Marketing Cookies
    NID, UULE

    Google cookies that may support ad personalization, localization, and service preference handling depending on the integration and browser state.

    Maximum storage duration: Varies by cookie | Type: Marketing Cookies
    SEARCH_SAMESITE

    Google cookie used to support secure cookie handling across requests and service interactions.

    Maximum storage duration: 6 Months | Type: Marketing Cookies
About cookies and consent

This website uses cookies and similar technologies to ensure its proper functioning and, with your consent, to support functionality, measure usage, improve performance, and provide advertising, attribution, or personalized content. The legal basis for the use of necessary cookies is the legitimate interest of the data controller (Art. 6(1)(f) GDPR), while functional, statistical, and marketing cookies are used only upon your explicit consent (Art. 6(1)(a) GDPR).

Cookies are small text files stored on your device to make the website work efficiently and improve your experience. Some cookies are placed directly by us, while others may be set by third-party services integrated into our pages.

Cookie categories
  • Necessary cookies: enable core site functionality such as consent storage, navigation context, language selection, authentication, and access to secure areas. These cannot be disabled.
  • Functional cookies: allow the website to remember settings and support integrations such as embedded or third-party services.
  • Statistical cookies: collect usage and performance data to help understand and improve the site.
  • Marketing cookies: support advertising, campaign attribution, personalization, and remarketing across providers and services.
Storage and consent management

Your cookie preferences are stored locally in a cookie named consent, valid for 12 months, and pseudonymously on our systems using a technical identifier (UserUUID), which does not allow direct identification of the user. A technical cookie named site_mode may also be used to preserve the current navigation context across pages. You may change or withdraw your consent at any time via the cookie settings button visible at the bottom left of the site.

Third-party cookies

Some cookies are provided by third-party services such as Google, Microsoft, Meta, TikTok, and Yandex. These third parties may act as independent controllers for the data collected through their own technologies and services.

Your rights

You can withdraw or modify your consent at any time, delete cookies through your browser settings, and exercise your rights under Articles 15–22 GDPR (access, rectification, deletion, limitation, opposition, portability) by contacting us via the details provided in the Privacy Policy.

This Cookie Policy is aligned with Regulation (EU) 2016/679 (GDPR) and the ePrivacy Directive.