1. Introduction
The purpose of this Statement is to inform you about the use made of the personal data that we collect in the context of the provision of our services and products, including when consulting our website and our social media.
This Statement applies to personal data we already hold or that we collect in the future.
The processing of your personal data is subject to the applicable data protection legislation in force in Switzerland, including in particular the Federal Data Protection Act of 25 September 2020, which came into force on 1 September 2023 (LPD).
Personal data is considered to be any information relating to an identified or identifiable natural person (hereinafter the “Data”). This includes information such as name, address, telephone number, email address, IP address and information that can be used to identify devices.
2. Controller of your Data
Responsible for processing your Data:
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3. Categories of data processed
When you contact us, including by telephone, through our website or on social media, you transmit to us and we collect certain Data. This Data may include:
4. Use of your Data
Depending on the different categories of Personal Data, the latter may be used for the following purposes:
5. Sharing data with third parties
5.1 Service providers, partners and subcontractors
We may transmit Personal Data to our employees, to third-party service providers (trustees, banks, media agencies, legal advisors, etc.), to partner companies (to integrate and offer new services or products for example) and to subcontractors (hosting services, application managers, domain name managers, etc.).
These third parties to whom we communicate Personal Data are not authorized to use them for purposes or uses other than those described in this Declaration.
However, when we integrate third-party services or content on our website that may allow you to interact directly with them (for example, an online payment service), the Data that you enter is then either transmitted to these third parties for the purpose of processing and performing the service concerned and your Data is then processed in accordance with their own provisions regarding the use and protection of data.
Provided that the legal conditions are met, third-party service providers, partner companies and subcontractors likely to receive Personal Data may be established in any country, in particular in Switzerland, in the EEA countries as well as in the United States.
If Personal Data is communicated abroad (outside the European Union) in a State which does not have, according to the list established by the Federal Council, legislation ensuring an adequate level of protection (in accordance with Annex 1 of the Data Protection Ordinance of 31 August 2023), you will be informed of the State concerned and whether the Data has been communicated within the framework of the contractual guarantees provided for in Art. 16 para. 2 LPD or the exceptions provided for in Art. 17 LPD.
5.2 Transmission to the authorities
We may also be required to communicate Personal Data in order to comply with a legal obligation or to respond to a request from an administrative or judicial authority.
6. Your rights
Under the conditions of art. 25 et seq. LPD, you have in particular the following rights:
Right of access – You have the right at any time to know in particular which Personal Data as such is processed.
Right to information – You have the right to be informed about how your Data is used. This Statement and any additional information provided are intended to provide this information.
Right to withdraw consent – Where Data is processed on the basis of consent, this may be withdrawn at any time.
Right to object to processing – You have the right to object to the processing of your Data at any time.
Right to rectification – You have the right to have inaccurate Data rectified and incomplete Data completed.
Right to restriction of processing – Subject to any legal provisions to the contrary, you may request to restrict the processing of your Data.
Right to erasure/deletion – You are entitled to request the erasure or deletion of your Personal Data unless a legal basis or legitimate interest requires or allows us to retain certain Data.
Right to delivery or transmission of Data – You have the right to request the delivery or transmission of your Data in a commonly used electronic format that allows their reuse when the processing of the Data is carried out by automated means, on the basis of consent or in direct connection with the conclusion or performance of a contract.
We reserve the right to limit any of the rights listed above to the extent permitted by law.
Subject to the exceptions provided by law, the exercise of these rights is free of charge.
Requests relating to the exercise of your rights must be communicated to the above address (supra ch. 2).
7. Data retention period
We retain your Data for as long as necessary to achieve the purposes for which it was collected.
Certain Data is subject to legal retention obligations of ten years or more which we respect.
We may also retain certain Data, in particular contractual Data, at least for the applicable limitation periods in order to assert our rights.
Conversely, certain Data generated in the context of the use of our services (cookies for example) are deleted significantly earlier as soon as their processing is no longer of interest given the purposes for which they were collected.
Anonymized Data may be retained for longer periods. Subject to express contractual agreement, we are not required to retain your Data for a specific period.
8. Data security
In accordance with applicable legislation, we use appropriate organizational and technical security measures to protect your Data against accidental or intentional manipulation, against total or partial loss or destruction or against unauthorized access by third parties. Our security measures are improved in line with technological developments.
9. Cookies
10. Effective Date
This Statement was last updated on September 25, 2023.
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