Privacy Policy


Last updated:

1. Data Controller

ASKO SA
Via Ceresio 43, 6963 Pregassona, 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

Necessary cookies: used for session and authentication (.AspNet.Consent, .AspNetCore.Cookies).

Functional, analytical, and marketing cookies: used only with explicit consent (Google Analytics 4, Microsoft Clarity).

The cookie banner appears on the first visit and is renewed every 12 months or whenever the site or code changes introduce new cookies.

Consent can be managed through the banner (“Accept All”, “Accept Selected”, “Reject All”) and revoked at any time via the Cookie Statement.

Google Analytics 4 operates under the EU–US and Swiss–US Data Privacy Frameworks, ensuring an adequate level of protection for cross-border data transfers. Google acts as an independent data controller according to its privacy terms.

Microsoft Clarity complies with the EU–US and Swiss–US Data Privacy Frameworks. Microsoft acts as an independent data controller, and ASKO SA has no access to individual user recordings.

9. Data Sharing

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

Aside from analytical services (Google Analytics 4 and Microsoft Clarity), ASKO SA does not use any sub-processors.

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 Pregassona, 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 a website usable by enabling basic functions such as page navigation and access to protected areas of the site.

  • Necessary cookies

    .AspNet.Consent

    Indicates whether the user has consented to the use of necessary cookies.

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

    Used to prevent CSRF attacks and protect user data.

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

    Used to manage authentication information and the user's session.

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

    Used to store user's language preferences.

    Maximum storage duration: 1 Year | Type: Necessary cookies
    __Secure-OSID

    Security cookie set by Google to authenticate users and prevent fraudulent use of login credentials.


    Maximum storage duration: 6 Months | Type: Necessary cookies
    __Host-3PLSID

    Ensures you stay connected to your Google accounts across various services.

    Maximum storage duration: 2 Years | Type: Necessary cookies
    AEC

    Used to verify your Google account and ensure that requests in sessions come from you.

    Maximum storage duration: 6 Months | Type: Necessary cookies
    HSID

    Security cookie used by Google to authenticate users and prevent fraudulent use of login credentials, protecting user data.

    Maximum storage duration: 2 Years | Type: Necessary cookies
    SEARCH_SAMESITE

    This cookie prevents the browser from sending the cookie along with cross-site requests, helping to mitigate the risk of cross-origin information leakage.

    Maximum storage duration: 6 Months | Type: Necessary cookies
    SID

    Important for Google's security and to ensure that Google can authenticate the account and block fraudulent access attempts.

    Maximum storage duration: 2 Years | Type: Necessary cookies
    SIDCC

    Security cookie to protect user data from unauthorized access.

    Maximum storage duration: 1 Year | Type: Necessary cookies
    __Host-1PLSID, __Host-3PLSID

    Crucial cookies to ensure that you remain securely logged into your Google accounts while accessing various Google services.

    Maximum storage duration: 2 Years | Type: Necessary cookies

Functional cookies allow the website to provide enhanced functionality and personalization. They may be set by the website owner or by third parties whose services have been added to the pages.

  • Functional Cookies

    LSOLH

    Used by Google to store session information and enhance the user's experience on Google services.


    Maximum storage duration: Session | Type: Functional Cookies
    COMPASS

    Used by Google to improve user navigation by remembering preferences and information, such as preferred language.

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

    Remembers which accounts have been used to log into Google services on the device.

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

    Used by Google to store user preferences and information when viewing pages with Google maps.

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

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

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

    Used by Google to remember user preferences, such as preferred language, to provide a more personalized experience.

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

    Used by Google to collect information about visitors for videos hosted on YouTube or maps integrated with Google Maps.

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

    Used by Google to store user preferences and information when pages containing maps or Google services are viewed.

    Maximum storage duration: 2 Years | Type: Functional Cookies

Statistical cookies help website owners understand how visitors interact with the site by collecting and transmitting information anonymously.

  • Statistical Cookies

    CLID

    Unique identifier used to track user interactions and maintain unique sessions.


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

    Microsoft cookie that collects data on user interactions to improve services.

    Maximum storage duration: 7 days | Type: Statistical Cookies
    SM

    Used by the Microsoft Clarity analytics suite to maintain the user's session.

    Maximum storage duration: Session | Type: Statistical Cookies

Marketing cookies are used to track visitors on websites. The intent is to display relevant and engaging ads for the individual user.

  • Marketing Cookies

    AID

    Used by Google to link your activity across devices if you have logged in with the same Google account.


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

    Used by Microsoft Advertising to check the anonymity of data sent by tracking cookies.

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

    Microsoft cookie used to track user interactions across Microsoft domains.

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

    Google cookies designed to build a profile of your preferences and show you relevant ads on other sites, protecting the Google account.

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

    Used by Google to identify and track visitors across various websites to display personalized advertising.

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

    Used by Google to personalize ads on Google properties, like Google Search.

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

    Used by Google to deliver more relevant ads and protect the security of your preferences and Google account information.

    Maximum storage duration: 2 Years | Type: Marketing Cookies
About cookies and consent

This website uses cookies and similar technologies to ensure its proper functioning and, with your consent, to measure usage, improve performance, and provide personalized content or advertisements. 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 come from third-party services integrated into our pages.

Cookie categories
  • Necessary cookies: enable core site functionality such as navigation, language selection, and access to secure areas. These cannot be disabled.
  • Functional cookies: allow the website to remember your preferences and settings for a better user experience.
  • Statistical cookies: collect anonymous data on site usage to help us understand and improve performance.
  • Marketing cookies: used to display personalized advertisements based on your browsing interests.
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. You may change or withdraw your consent at any time via the cookie settings button visible at the bottom left of the site or through the link in this section.

Third-party cookies

Some cookies are provided by third-party services (e.g., Google, Microsoft). These third parties act as independent controllers or processors under their own privacy policies.

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.