Privacy Notice

Privacy Notice for Website Visitors
Privacy Notice for Clients
Privacy Notice for Job Applicants

Privacy Notice for Website Visitors

I. Name and address of the person responsible

The controller within the meaning of the EU General Data Protection Regulation (hereinafter referred to as “GDPR”) is

Domar Fiduciary and Management Establishment
Heiligkreuz 6
9490 Vaduz
Liechenstein

T +423 235 8181
F +423 235 8282

info@domar.li

II. General information on data processing

1. Preamble

The companies Marxer Attorneys Domar Fiduciary and Management Establishment, Protec Trust Management Establishment, Diligentia Trust Establishment, Fundationsanstalt and Percuro Trust Establishment, all with registered office at Heiligkreuz 6, LI-9490 Vaduz (hereinafter “Companies”) process information and personal data relating to you (hereinafter “Data Subject”). In principle, this information processing is carried out by the Companies in the context of existing or prospective business relationships, including the use of the websites. The Companies endeavor to ensure the best possible protection of your personal data.

The controller within the meaning of the EU General Data Protection Regulation (hereinafter “GDPR”) is Domar Fiduciary and Management Establishment, Heiligkreuz 6, LI-9490 Vaduz. The Companies have appointed a joint data protection officer (see point 10).

This Privacy Notice (hereinafter “Notice”) applies to the Companies. It describes the processing of personal data in connection with the provision of services by the Companies and their websites. This Privacy Notice is based on the GDPR, the Data Protection Act (DSG) and the relevant special legal regulations.

The Companies reserve the right to amend the notice if necessary.

2. Scope of processing personal data

Personal data is any information that can be used to directly or indirectly identify a natural person. This includes, for example, name, address, e-mail address, telephone number.

Processing of our users’ personal data is limited to the data required to provide a functional website and our content and services.

The Companies collect, process and use your personal data exclusively in accordance with the provisions of Art. 5 and 6 GDPR (contract, legal requirements, legitimate interest or consent of the data subject) insofar as these are actually required for the performance and processing of our tasks and services or are provided to us voluntarily.

The Companies are subject to professional confidentiality and secrecy requirements that can be derived from data protection law, contract law or professional secrecy. When processing personal data, the Companies are bound by these requirements.

3. Your rights

3.1 Right to information

You have the right to request information about your personal data that is stored by the Companies. A request for information must be sent in writing to the Data Protection Officer (see point 10) together with proof of identity.

Upon receipt of your request for information, you will be provided with information within the statutory period of 30 days. The information may be refused, restricted or postponed if this is provided for by law or is necessary due to the prevailing interest of a third party or a requested company.

The request for information can be combined with a request for rectification or erasure of data.

3.2 Right to rectification or erasure

You have the right to request in writing and free of charge the rectification or erasure of your personal data you if it is incorrect or has been stored or processed unlawfully. A reasoned request for rectification or erasure must be sent to the Data Protection Officer (see point 10) together with proof of identity.

Under certain circumstances, legal regulations may prevent erasure. In such a case, the Companies will only process your personal data to the extent necessary to comply with legal requirements.

3.3 Right of objection or cancellation

You have the right to object in writing to the processing of your personal data in whole or in part or to cancel your consent to data processing. An objection or cancellation must be sent in writing to the Data Protection Officer (see point 10) together with proof of identification.

Receipt of your objection or cancellation will be confirmed to you and the data concerned will subsequently be deleted.

Under certain circumstances, compliance with an objection or cancellation may be prevented by legal regulations. In such a case, the Companies will only process your personal data to the extent necessary to comply with legal requirements.

3.4 Right to Restriction

You have the right to restrict your personal data from being passed on to third parties. A request for restriction must be sent in writing to the Data Protection Officer (see point 10), enclosing proof of identity.

Receipt of your request for restriction will be confirmed, and your request will be processed within a reasonable period of time.

Restriction may be prevented by legal regulations under certain circumstances. In such a case, the Companies will only pass on your personal data to third parties to the extent necessary to comply with legal requirements.

3.5 Right of Complaint

You have the right to file a complaint with the competent Liechtenstein supervisory authority. You can also contact another supervisory authority of an EU or EEA member state, e.g. at your place of residence or work or at the place of the alleged infringement.

The contact details of the data protection authority responsible in Liechtenstein are as follows:

3.5.1 Liechtenstein Data Protection Authority

Kirchstrasse 8
P.O. Box 684
LI-9490 Vaduz
+423 236 60 90
info.dss@llv.li

3.5.2 Contact details of the Data Protection Officer

If you have any questions about data protection and data processing, please contact the Companies’ Data Protection Officer in writing. You can reach our Data Protection Officer as follows:

Domar Fiduciary and Management Establishment
Data Protection Officer
Heiligkreuz 6
LI-9490 Vaduz
+423 235 81 81
dsb@domar.li

III. Description and scope of data processing

1. Provision of the website

Each time our website is accessed, our web server automatically records data and information from the computer system of the accessing computer in so-called server log files.

The following data is collected:

date and time of access
the IP address of the user
information about the browser type and version used

This information is stored for a maximum period of 30 days. It is stored for reasons of data security and to ensure stability and operational security.

2. Cookies

We use cookies on our website to make our website more user-friendly. Cookies are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. The cookies remain stored until you delete them. This enables us to recognize your browser on your next visit.

If you do not want this, you can set up your browser so that it informs you about the setting of cookies and you allow them in specific cases. However, we would like to point out that deactivating cookies will mean that you will not be able to use all the functions of our website.

The legal basis for the data processed by cookies is Art. 6 (1) (1) (a) and (f) GDPR.

The cookies remain valid for an indefinite period and are then deleted by your browser.

In our cookie notice you will find all cookies listed, sorted by function and explained in detail. You can customize your settings and allow or reject only the necessary cookies or all cookies (including statistics, marketing, etc.).

A distinction is made between the following cookie types and functions:

a) Necessary (also: essential or absolutely necessary) cookies

Cookies help to make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

b) Preference (functional) cookies

Preference cookies allow the website to remember information that influences the way a website behaves or looks, such as preferred language or region in which the website visitor is located.

c) Statistics cookies

Statistics cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously. This data helps us to analyze and improve the performance of our website.

d) Marketing cookies

Marketing cookies are used to track visitors on websites. The intention is to show adverts that are relevant and attractive to the individual visitor and therefore more valuable to publishers and third party advertisers.

3. Web analysis

We analyze the use of our website with the open source web analysis tool Matomo (privacy policy can be found at https://matomo.org/privacy-policy/). However, the automatically collected IP addresses are anonymized before analysis. All analyses created are therefore based on anonymized data records and no personal evaluation takes place. Web analysis is used exclusively to optimize the website in terms of user-friendliness and to provide useful information about our services. This data is not merged with other personal data sources or passed on to third parties.

You can also prevent cookies from Matomo by selecting the “Only necessary cookies” button in the “Cookie information” pop-up that appears when you access the website. The use of Matomo cookies will then not be permitted.

The legal basis for the processing of data processed by Matomo cookies is Art. 6 (1) (a) GDPR (“consent”).

4. Form & e-mail contact

You can contact us via the contact form on the website or by e-mail or other electronic message. Your details will be stored for the purpose of processing your enquiry and any other related questions and will only be used within the scope of the enquiry.

When submitting job applications via the contact form, the applicant agrees that personal data will be processed in accordance with the relevant data protection regulations, in particular the General Data Protection Regulation (GDPR), on the collection, processing and use of your data for the purpose of our staff selection.

Your personal data is collected and processed solely for the purpose of carrying out the application process. There is also no automated decision-making in accordance with Art. 22 GDPR.

The legal basis for processing your enquiry is Art. 6 (1) (1) (b) GDPR (pre-contractual measures). The processing of images/photos in the context of job applications is based on Art. 6 (1) (a) GDPR (consent).

We will delete your e-mail address after your enquiry has been dealt with. Online applications will be deleted after 60 days.

5. Data security

SSL encryption

When you visit our website, we use the widespread TLS method in conjunction with the highest level of encryption supported by your browser. You can recognize whether an individual page of our website is transmitted in encrypted form by the closed key or lock symbol in the address bar of your browser.

In addition, we apply further suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

Regardless of the measures taken to protect data, you must be aware that data transmission via the Internet – this applies to both websites and e-mail services – is uncontrolled and cross-border. Even if the sender and recipient are located in the same country, data may be transmitted across borders. The Companies can therefore not guarantee the confidentiality of data transmitted via the Internet. If you disclose personal data via the Internet, you must be aware that third parties can access this information, read, change, falsify, monitor, destroy or misuse the data. Data transmission may also be delayed. Furthermore, data may be lost during transmission. Moreover, third parties could draw conclusions about existing business relationships. Therefore, the Companies cannot accept any responsibility for the security of your data during transmission via the Internet and disclaim any liability for direct or indirect damage.

6. Mails sent to us

We would like to point out that – subject to an explicit agreement and configuration – e-mails sent to us are not encrypted.

7. Transfer of personal data to third parties

The personal data collected in the course of the Companies’ business activities is generally not passed on to third parties.

However, in order to fulfil business tasks, it is possible that your data may be forwarded to third parties due to technical processing requirements or legal regulations. Your data will be forwarded in accordance with the provisions of the GDPR.

Furthermore, we inform you that the Companies may obtain information about you from third parties as part of their business activities and to fulfil legal due diligence requirements.

The Companies will only transfer your personal data to countries that the EU Commission has certified as having an adequate level of data protection. If the Companies transfer your personal data to countries that do not have a level of data protection certified as adequate, the Companies will take measures to ensure the protection of your data by contracting with recipients in these countries in accordance with the standard contractual clauses (L 199/18 – 2021/915 of 07.06.2021).

Your personal data will only be transferred to third parties if i) you have given your express consent (Art. 6 (1) (a) GDPR) or ii) the processing is necessary for the fulfilment of a contract (Art. 6 (1) (b) GDPR) or iii) there is a legal requirement (Art. 6 (1) (c) GDPR) or iv) there is a legitimate interest (Art. 6 (1) (f) GDPR).

8. Storage of personal data

The Companies’ systems required for data processing are located in Liechtenstein and Switzerland. The data transmitted by you will be stored for as long as this is necessary for the purpose of data processing or as required by law.

9. Updating and amending this privacy notice

This privacy notice is currently valid and has the status: May 2025.

Due to the further development of our website or legal changes, adjustments may be necessary.

10. Contact us

If you have any questions about data protection and data processing, please contact the Companies’ Data Protection Officer in writing. You can reach our Data Protection Officer as follows:

Domar Fiduciary and Management Establishment
Data Protection Officer
Heiligkreuz 6
LI-9490 Vaduz
+423 235 81 81
dsb@domar.li

Privacy Notice for Clients

Data Collection as Part of the Implementation and Processing of our Services and Tasks

1. Data Processing Purposes

We process personal data of our clients for the following purposes:

activities pursuant to the Lawyers Act, the Trustees Act and the Persons and Companies Act, in particular:
- legal representation in all matters, pursuant to Art. 6 (1) (b) GDPR
- mandate administration (incl. administration of legal entities), pursuant to Art. 6 (1) (b) and Art. 6 (1) (c) GDPR in conjunction with Art. 20a SPG
- fulfilment of statutory accounting requirements, pursuant to Art. 6 (1) (b) and (c) GDPR
- correspondence, pursuant to Art. 6 (1) (b) and (c) GDPR
- Provision of notarial services (notarization and certification as well as register management), pursuant to Art. 6 (1) (a) and (b) GDPR
- compliance with legal requirements in connection with the Lawyers Act, the Trustees Act, the Persons and Companies Act, and the Civil Code, pursuant to Art. 6 (1) (c) GDPR

2. Data Categories

In our data directories, the following data categories are processed directly in accordance with
Art. 9 GDPR to perform our activities within the scope of the purposes listed under a.:

Data category
Data description
Data recipient

Identification data
Identification documents, e.g. copies of passports or ID cards, utility bills, tax numbers, death certificates; authentication data, e.g. specimen signatures
Banks, asset managers, brokers, trust companies, tax consultants

Due diligence documents
e.g. contractual partners, identification of beneficial owners, profile of the business relationship with information on professional and personal background (e.g. profession and hobbies), World-Check data, Nexis Diligence, Nexis Diligence and Internet checks in accordance with the Due Diligence Act
Liechtenstein banks and asset managers (persons subject to due diligence associated with the mandate), authorities (register and directory entries) and supervisory authorities

Entries in public registers and registers of beneficial owners
Among other things, information on corporate bodies must be entered in registers and information on beneficial owners must be entered in the electronic Register of Beneficial Owners of Legal Entities.
Persons subject to due diligence are required by law to make entries in public and electronic registers.

Mandate information
e.g. company documents, bank records, correspondence, due diligence documents, tax data, resolutions by bodies
Liechtenstein authorities due to statutory requirements

Accounting data
Transaction and accounting information
Liechtenstein authorities due to statutory requirements

Correspondence
Client orders, general
Banks and members of bodies, Liechtenstein authorities due to statutory requirements

Data of legal entities
Articles of incorporation, by-laws, certificates, mandate agreements, signatory powers
Commercial register and Liechtenstein authorities due to statutory requirements

Tax data
FATCA, AEOI, AStA (Withholding Tax Agreement), LDF reports (Liechtenstein Disclosure Facility UK)
Tax authorities due to statutory requirements

Data for notarization and certification
Name (first name, surname), title, place of residence, as well as other data visible on the identification document (e.g. passport, identity card, driving licence), such as date of birth, place of birth, number of the identification document
No disclosure to third parties.

3. Access to and Forwarding of Data

We process clients’ personal data exclusively for the fulfilment of our contractual, statutory and supervisory duties for the purposes listed under a.

The following parties may receive personal data for this purpose:

group companies
external service providers and parties (such as banks, asset managers, insurance companies, lawyers, auditors; suppliers, dealers, transport companies, subcontractors or other cooperation partners; associations, public-interest organizations); data will only be forwarded to us by third-party service providers with the express consent of the client.

If we must fulfil statutory or supervisory requirements, the following parties in particular may receive personal data:

official bodies and public authorities (e.g. supervisory authorities, courts, Office of Justice, professional associations
tax authorities (e.g. as part of the Automatic Exchange of Information [AEOI, FATCA, AStA (Withholding Tax Agreement)]).

4. Data origin

The data is collected directly (e.g. during meetings or as part of correspondence with clients; internal background and due diligence checks) and in some cases by third-party service providers (such as banks, asset managers, auditors).

5. Data Retention Period

The personal data is processed and stored during the ongoing business relationship, unless there are special shorter erasure periods. After termination of the business relationship, this data is stored for at least 10 years on the basis of statutory provisions (Persons and Companies Act, Due Diligence Act). Data will only be stored for longer on the basis of statutory or contractual retention requirements or for evidence purposes with regard to time-barring laws.

6. Automated Decision-Making (Art. 22 GDPR)

No automated decision-making takes place regarding the data collected. Should such procedures be used in specific cases, we will inform clients to the extent required by law.

7. Your Rights

7.1 Right to information

The request for information can be combined with a request for rectification or erasure of data.

7.2 Right to Rectification or Erasure

You have the right to request in writing and free of charge the rectification or erasure of your personal data if it is incorrect or stored or processed unlawfully. A reasoned request for rectification or erasure must be sent to the Data Protection Officer (see h.), together with proof of identity.

Under certain circumstances, erasure may be prevented by legal regulations. In such a case, the companies will only continue to process your personal data to the extent necessary to comply with legal requirements.

7.3 Right of Objection or Cancellation

You have the right to object in writing, in whole or in part, to the processing of your personal data or to cancel your consent to the processing of such data. The objection or cancellation must be in writing to the Data Protection Officer (see h.) together with proof of identification.

Receipt of your objection or cancellation will be confirmed to you and the data concerned will subsequently be deleted.

Under certain circumstances, compliance with an objection or cancellation may be prevented by statutory regulations. In such a case, the Companies will only continue to process your personal data to the extent necessary to comply with statutory requirements.

7.4 Right to Restriction

You have the right to restrict the processing of your personal data regarding the transmission of such data to third parties. A request for restriction must be sent in writing to the Data Protection Officer (see h.), enclosing proof of identity.

Receipt of your request for restriction will be confirmed, and your request will be processed within a reasonable period of time.

Under certain circumstances, legal regulations may prevent restriction. In such a case, the companies will only pass on your personal data to third parties to the extent necessary to comply with legal requirements.

7.5 Right of Complaint

The contact details of the data protection authority responsible in Liechtenstein are as follows:

7.5.1 Liechtenstein Data Protection Authority

Kirchstrasse 8
P.O. Box 684
LI-9490 Vaduz
+423 236 60 90
info.dss@llv.li

7.5.2 Contact us

If you have any questions about data protection and data processing, please contact the Data Protection Officer of the controller in writing. You can contact our Data Protection Officer as follows:

Domar Fiduciary and Management Establishment
Data Protection Officer
Heiligkreuz 6
LI-9490 Vaduz
+423 235 81 81
dsb@domar.li

Privacy Notice for Job Applicants

A. Data collection from job applicants

By submitting your application documents (by e-mail, online application or in traditional form by post), you agree that personal data may be processed in accordance with the relevant data protection regulations, in particular the General Data Protection Regulation (GDPR), regarding the collection, processing and use of your data for the purpose of our staff selection.

1) Purpose of data processing and data collected

We collect the following personal data as part of your application:

title, surname, first name;
date of birth;
address;
e-mail address;
telephone number;
application documents (cover letter, CV, certificates);
education, professional experience;
salary expectations;
photos.

Your personal data is collected and processed solely for the purpose of carrying out the application process.

2) Automated decision making

There is also no automated decision-making in accordance with Art. 22 GDPR.

3) Passing on the data

Your data will only be forwarded to the internal offices and specialist departments responsible for the specific application process or to the relevant affiliated company. Beyond this, your personal data will not be passed on to third parties.

4) Legal basis

Your personal data is processed on the basis of Art. 6 (1) (b) GDPR. The processing of images/photos is based on Art. 6 (1) (a) GDPR (consent).

5) Storage duration

Your data will be stored until the application process has been completed. If your application is unsuccessful, your data will be deleted no later than six months after completion of the application process, unless there is a statutory retention requirement, or you have consented to longer storage.

Online applications are deleted after 60 days.

B. Your rights

i. Right to information

You have the right to request information about your personal data that is stored by the companies. A request for information must be sent in writing to the Data Protection Officer together with proof of identity.

The request for information can be combined with a request for rectification or erasure of data.

ii. Right to rectification or erasure

You have the right to request in writing and free of charge that your personal data be rectified or erased if it is incorrect or has been stored or processed unlawfully. A reasoned request for rectification or erasure must be sent to the Data Protection Officer together with proof of identity.

Your request for rectification or erasure will be processed within a reasonable period of time after receipt. You will then receive confirmation that your request for rectification or erasure has been processed. Under certain circumstances, erasure may be prevented by legal regulations. In such a case, the companies will only continue to process your personal data to the extent necessary to comply with legal requirements.

iii. Right of objection or cancellation

You have the right to object in writing to the processing of your personal data in whole or in part or to cancel your consent to data processing. An objection or revocation must be sent in writing to the Data Protection Officer together with proof of identification.

Receipt of your objection or cancellation will be confirmed to you and the data concerned will subsequently be deleted.

iv. Right to Restriction

You have the right to restrict your personal data from being passed on to third parties. A request for restriction must be sent in writing to the Data Protection Officer, enclosing proof of identity.

Receipt of your request for restriction will be confirmed, and your request will be processed within a reasonable period of time.

v. Right of complaint

The contact details of the data protection authority responsible in Liechtenstein are as follows:

Liechtenstein Data Protection Authority
Kirchstrasse 8
Postfach 684
Ll-9490 Vaduz
+423 236 60 90
info.dss@llv.li

Contact

If you have any questions about data protection and data processing, please contact the Data Protection Officer of the controller in writing. You can contact our Data Protection Officer as follows:

Domar Fiduciary and Management Establishment
Data Protection Officer
Heiligkreuz 6
Ll-9490 Vaduz
+423 235 81 81
dsb@domar.li