Data Protection Notice Schaffner Holding AG
1. What is this Data Protection Notice about?
The Schaffner Group (also “we”, “us”) collects and processes personal data that concerns you and other individuals (“third parties”). We use the word “data” here interchangeably with “personal data”.
The “Schaffner Group” means the Schaffner Holding AG and its subsidiaries and group companies. A list of these subsidiaries and group companies can be found here .
“Personal data” means data relating to identified or identifiable individuals, which means that the relevant data, in combination with additional data, make it possible to draw conclusions about the identity of these individuals. “Sensitive personal data” is a subset of personal data that is specially protected under applicable data protection law. This includes, for example, data revealing racial or ethnic origin, health data, religious or philosophical beliefs, biometric data for identification purposes, and information relating to trade union membership. In Section 3, you will find information about the data we process in accordance with this Data Protection Notice. “Processing” means any operation that is performed on personal data, such as collection, storage, use, alteration, disclosure and erasure.
In this Data Protection Notice, we describe what we do with your data when you use Schaffner.com, our other websites or apps (collectively referred to as the “website”); obtain services or products from us; interact with us in relation to a contract; communicate with us; or otherwise deal with us. When appropriate we will provide a just in time notice to cover any additional processing activities not mentioned in this Data Protection Notice. In addition, we may inform you about the processing of your data separately, for example, in consent forms, terms and conditions, additional privacy notices, forms and other notices.
If you disclose data to us or share data with us about other individuals, we assume that you are authorized to do so, and that the relevant data is accurate. When you share data about others with us, you hereby confirm that. Please make sure that these individuals have been informed about this Data Protection Notice.
This Data Protection Notice is aligned with the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DPA”) and the revised Swiss Data Protection (“revDPA”). However, the application of these laws depends on each individual case.
2. Who is the controller for processing your data?
The Schaffner Holding AG, Industrie Nord, Nordstrasse 11e, 4542 Luterbach, Switzerland (“Schaffner”) is the controller for Schaffner group’s processing under this Data Protection Notice, unless we tell you otherwise in an individual case, for example, in additional data protection notices, on a form, or in a contract. However, unless we tell you otherwise, this Notice also applies where a group company of the Schaffner group is the controller, instead of Schaffner Holding AG. This applies, in particular, where your data is processed by a group company in connection with its own legal obligations or contracts or where you share data with such a group company. In these cases, this group company is the controller and only if it shares your data with other group companies for their own processing (see Section 7), will these other group companies also become controllers.
For each processing activity there are one or several parties that are responsible for ensuring that processing complies with data protection law. This party is called the controller. It is responsible, for example, for responding to access requests (Section 11) or for ensuring that personal data is processed securely and not used in an unlawful manner.
Additional parties may be joint controllers for the processing set out in this Data Protection Notice if they participate in determining the purpose or means of the processing. All group companies may act as joint controllers. If you wish to receive information about the controllers for a specific processing activity, you are welcome to ask us as part of your access rights (Section 11). The Schaffner Holding AG remains your primary contact, even if there are other joint controllers.
In Section 3, Section 7 and Section 12, you will find additional information about third parties with whom we work together and who are controllers for their processing. If you have any questions for these third parties or if you wish to exercise your rights, please contact them directly.
You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:
Schaffner Holding AG
3. What data do we process?
We process various categories of data about you. The main categories of data are the following:
- Technical data: When you use our website or other online offerings, we collect the IP address of your terminal device and other technical data to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. Generally, we keep technical data for 6 months. To ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example, as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser that you use to access our electronic offerings. This can help us to provide an appropriate layout of the website or to show you a website customized for your region, for example. We know through which provider you access our offerings (and therefore also the region) because of the IP address, but usually this does not tell us who you are. However, this changes for example, when you create a user account, because personal data can then be linked with technical data (for example, we can know the browser you use to access an account through our website). Examples of technical data include protocols (“logs”) that are created in our systems (for example, the log of user logins to our website).
- Registration data: Certain offerings and services (such as login areas of our website, newsletters, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or service. Registration data may be required in relation to access control to certain facilities, potentially including biometric data, depending on the control system. Generally, we keep registration data for 12 months from the date the use of the service ceases or the user account is closed.
Registration data includes the information you provide when you create an account on our website (for example, username, password, name, e-mail). It also includes the data that we may require from you before you can use certain free services. You must also register if you wish to subscribe to our newsletter. In relation to access controls, we may need to register you with your data (access codes in badges, biometric data for identification) – please see the category ”Other data”.
- Communication data: When you are in contact with us via the contact form, by e-mail, telephone or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we have to determine your identity, for example, in relation to a request for information, a request for press access, etc., we collect data to identify you (for example, a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. Generally, e-mails in personal mailboxes and written correspondence are kept for at least 10 years.
Communication data is your name and contact details, this means, place and time of communication and usually also its content (i.e. the content of e-mails, letters, etc.). This data may also include information about third parties. For identification purposes, we may also process your ID document number, or a password set by you.
- Master data: By master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example, as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example, as part of marketing and advertising, with invitations to events, with newsletters, etc.). We receive master data from you (for example, when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations, and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.). We may also collect master data from our shareholders and investors. Generally, we keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is usually much shorter, usually no more than 2 years from the last contact.
Master data includes data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, photos and videos, copies of ID cards; moreover, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (for example, from the media), or official documents (for example, excerpts from the commercial register, permits, etc.) that concern you. Declarations of consent and optout information are also part of the master data, as well as information about third parties, for example, contact persons, recipients of services or representatives.
In relation to contact persons and representatives of our customers, suppliers and partners, master data includes, for example, name and address, information about the role or function in the company, qualifications and (where applicable) information about superiors, co-workers and subordinates and information about interactions with these persons.
Master data is not collected comprehensively for all contacts. The data collected in an individual case depends mostly on the purpose of the processing activity.
- Contract data: This means data that is collected in relation to the conclusion or performance of a contract for example, information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example, complaints, feedback about satisfaction, etc.). We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example, credit information providers) and from public sources. Generally, we keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
Contract data includes information about the conclusion of the contract, about your contracts, for example, the type and date of conclusion, information from the application process (such as the application for the performance of our products or services) and information about the relevant contract (for example, its duration) and the performance and administration of the contracts (for example, information related to billing, customer service, technical assistance and enforcement of contractual claims). Contract data also includes information about deficiencies, complaints and changes to a contract, as well as information about customer satisfaction that we may collect for example, through surveys. Contract data also includes financial data, such as credit information (meaning information that allows us to draw conclusions about the likelihood that receivables will be paid), information about reminders and debt collection. We receive this data partly from you (for example, when you make payments), but also from credit agencies and debt collection companies and from public sources (for example, a commercial register).
- Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example, as part of health protection concepts). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example, at events, with security cameras, etc.). We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data or lists of visitors, etc.), who participates in events or campaigns and who uses our infrastructure and systems and when. Moreover, we collect and process data about our shareholders and other investors, in addition to master data, including information for registers, in relation to the exercise of their rights and events (for example, general meetings). The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many security cameras, to a few weeks for contact tracing and visitor data, which is usually kept for 3 months, to several years or more for reports about events with images. Data relating to you as a shareholder or investor is kept in accordance with corporate law, but in any case, for as long as you remain as an investor.
Much of the data set out in this Section 3 is provided to us by you (via forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases, for example, within the framework of binding health protection concepts (legal obligations). If you wish to enter into contract with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.
We provide certain services to you only if you provide us with registration data, because we or our contractual partners wish to know who uses our services or has accepted an invitation to an event, because it is a technical requirement or because we wish to communicate with you. If you or the person you represent (for example, your employer) wishes to enter into or perform a contract with us, we must collect master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offerings for this purpose. If you do not provide us with the data necessary for the conclusion and performance of the contract, you should expect that we may refuse to conclude the contract, that you may commit a breach of contract or that we will not perform the contract. Similarly, we can only submit a response to a request from you if we process communication data and – if you communicate with us online – also possibly technical data. Also, the use of our website is not possible without us receiving technical data.
As far as it is not unlawful, we also collect data from public source or receive data from other companies within our group, from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).
The categories of personal data that we receive about you from third parties include, in particular: information from public registers; information that we receive in relation to administrative and legal proceedings; information in relation to your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your assistance); information about you in correspondence and meetings with third parties, credit information (where we conduct business with you in a personal capacity); information about you that persons related to you (family members, advisors, legal representatives, etc.) share with us so that we can conclude or perform contracts with you or involving you (for example, references, your delivery address, powers of attorney, information about compliance with legal requirements such as those relating to fraud prevention and the combating of money laundering and terrorist financing, export restrictions, information from banks, insurance companies, sales and other contractual partners of us about your use or provision of services (for example, payments, purchases, etc.); information from the media and the internet about the use or provision of services by you (for example, payments made, purchases made, etc.); information from the media and the internet about you (where appropriate in a specific case, for example, in the context of an application, marketing/sales, press review, etc.), your address and potentially interests and other sociodemographic data (especially for marketing and research purposes) and data in relation to the use of thirdparty websites and online offerings where such use can be linked to you.
4. What is this Data Protection Notice about?
We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent both our and any third party interests. You can find further information on the legal basis of our processing in Section 5.
We process your data for purposes related to communication with you, especially in relation to responding to inquiries and in the exercising of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we particularly use communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for followup inquiries. The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting, authentication in case the website is used, and for training and quality assurance (for example, in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes for example, so that we can provide services or respond to an access request. Our processing also serves to document the communication and its content.
The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting, authentication in case the website is used, and for training and quality assurance (for example, in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes for example, so that we can provide services or respond to an access request. Our processing also serves to document the communication and its content.
We process data for the conclusion, administration, and performance of contractual relationships.
We conclude various contracts with our business and private customers, suppliers, subcontractors and other parties, such as partners in projects or parties in legal proceedings. In particular, we process master data, contract data and communication data and, depending on the circumstances, registration data relating to the customer or the persons for whose benefit the customer has received a service.
In the formation of a business relationship, personal data – in particular master data, contract data and communication data – are collected from potential customers, or other contractual partners (for example, in an order form or a contract), or results from a communication. In connection with the conclusion of a contract, we process data to assess creditworthiness and to start a customer relationship. In some cases, this information is reviewed to comply with legal requirements.
As part of organizing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security service providers, banks, insurance companies or credit information providers, who may in turn provide data to us), for consulting and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the organization, as are accounting, termination of contracts and public communication.
We process data for marketing purposes and relationship management, for example, to send our customers and other contractual partners personalized advertising for products and services from us and also third parties. This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns. You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 12).
For example, if you consent, we may send you information, advertising and product offers from us and from third parties within the group, as printed material, electronically or by telephone. For this purpose, we process in particular communication and registration data. As most companies do, we personalize communication so that we can provide you with customized information and offers that meet your needs and interests. Therefore, we combine data we process about you and collect preference data and use this data as a basis for personalization (see Section 3).
Relationship management includes addressing existing customers and their contacts, potentially personalized based on behavioral and preference data. In the context of relationship management, we may also operate a customer relationship management system (“CRM”) in which we keep the data of customers, suppliers and other business partners that is required for relationship management, for example, data about contact persons, relationship history (for example, information about products and services purchased or supplied, interactions, etc.), interests, marketing measures (newsletters, invitations to events, etc.) and other information.
All this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.
We further process your data for market research, to improve our services and operations, and for product development.
We strive to continuously improve our products and services (including our website) and to respond quickly to changing needs. We therefore analyze, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details, see Section 12). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioral data and preference data, but also communication data and information from customer surveys, polls and studies and other information. We use pseudonymized or anonymized data for these purposes to the extent possible. We may also use media monitoring services or conduct media monitoring ourselves and process personal data to conduct media monitoring or to understand and respond to current developments and trends.
We may also process your data for security and access control purposes.
We continuously review and improve the appropriate security of our IT and other infrastructure (for example, buildings). Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. We therefore process data, for example, for monitoring, inspection, analysis and testing of our networks and IT infrastructures, for system and error checks, for documentation purposes and in the context of backups. Access controls include electronic system access controls (for example, logging into user accounts), as well as physical access controls (for example, building access). For security purposes (to prevent and investigate incidents), we also keep access protocols and visitor lists and use surveillance systems (for example, security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations (“Compliance”).
This includes, for example, the implementation of health security concepts or the regulated fight against money laundering and terrorist financing. In certain cases, we may also be required to make certain clarifications about our customers (“Know Your Customer”) or to report to the authorities. Disclosure and information or reporting obligations, for example, in connection with supervisory and tax obligations, also require or entail data processing, for example, archiving obligations and the prevention, detection and investigation of criminal offenses and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations, or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example, by a law enforcement or supervisory authority or by a mandated private entity. Furthermore, we process data to serve our shareholders and other investors and to fulfill our obligations in this regard. For all these purposes, we process in particular master data, contract data and communication data, but also, under certain circumstances, behavioral data and data from the category of “other data”. The legal obligations may arise under Swiss law but also under foreign regulations to which we are subject, as well as selfregulations, industry standards, our own “corporate governance” and instructions and requests from authorities.
We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.
For these purposes, we process in particular master data, contract data, registration data and technical data, but also behavioral and communication data. For example, as part of our financial management, we need to monitor our accounts receivable and accounts payable, and we need to avoid becoming victims of crime and abuse, which may require us to analyze data for relevant patterns of such activities. We may also conduct profiling and create and process profiles for these purposes and to protect you and us from criminal or abusive activity (see also Section 6). In the context of planning our resources and organizing our operations, we may need to evaluate and process data relating to the use of our services and other offerings or share information about them with others (for example, outsourcing partners), which may also include your data. The same applies with respect to services provided to us by third parties. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the exchange and processing of data (including from you for example, as a customer or supplier or as a supplier representative).
We may process your data for further purposes for example, as part of our internal processes and administration or for quality assurance purposes and trainings.
These further purposes include, for example, training and educational purposes, administrative purposes (such as managing master data, accounting and data archiving, and testing, managing and continuously improving IT infrastructure), protecting our rights (for example, to enforce claims in or out of court, and before authorities in Switzerland and abroad, or to defend ourselves against claims for example, by preserving evidence, conducting legal assessments and participating in court or administrative proceedings) and evaluating and improving internal processes. These further purposes also include safeguarding other legitimate interests that cannot be named exhaustively.
5. On what basis do we process your data
Where we ask for your consent for certain processing activities (for example, for the processing of sensitive personal data, for marketing mailings, for personalized motion profiles and for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by e-mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example, in the case of GDPR, the laws in the EEA and in the case of DPA, under Swiss law). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.
Where we receive sensitive personal data (for example, health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.
6. What applies in case of profiling and automated individual decisions?
We may automatically evaluate personal aspects relating to you (“profiling”) based on your data (Section 3) for the purposes set out in Section 4, where we wish to detect misuse and security risks, to perform statistical analysis or for operational planning.
If you are our customer, we may, for example, use certain Captchas to determine whether you are a human. During this data collection a Profile is created. “Profiles” are to be distinguished from “profiling”. “Profiles” refer to the combining of different data to draw conclusions from the totality of this data. Profiles may also be used for marketing, for example, or for security purposes.
In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.
7. We do not conduct profiling or automated decision making. With whom do we share your data?
In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:
- Group companies: A list of our group companies can be found here . These group companies may use the data according to this Data Protection Notice for the same purposes as we use it (see Section 4). We may also disclose health data to our group companies.
The group companies have access in particular to your master data, contract data and registration data, as well as behavioral and preference data in order to offer their own range of products and services to you or to advertise them. If you wish to object to the disclosure and use of data for marketing purposes, you can do so through us (Section 2), even if the processing concerns another group company once data has already been transferred. We also disclose your data to other group companies for certain products and services for example, if certain products and services originate from other group companies where we only coordinate their performance.
- Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example, IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit information agencies, or address verification providers). For the service providers used for the website, see Section 12.
To be able to deliver our products and services efficiently and focus on our core competencies, we procure services from third parties in various areas. These may include, for example, IT services, information transmission, marketing, sales, communication or printing services, facility management, security, and cleaning, organizing and holding events and receptions, debt collection, credit agencies, address verification provider (for example, to update address lists in case of relocations), fraud prevention measures and services from consulting companies, lawyers, banks, insurers and telecommunication companies. In each case, we disclose to these providers the data they require for their services, which may also concern you. In addition, we enter into contracts with these providers that include provisions to protect data, where such protection does not follow from the law. In some cases, our service providers may also process data on how their services are used and other data that is generated while using their services as independent data controllers for their own legitimate interests (e.g., for statistical analysis or billing purposes). Service providers inform about their independent data processing activities in their own privacy statements.
- Contractual partners including customers: This refers to customers and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate or who conduct advertising for us and to whom we may therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers). We require these partners send you or display advertising based on your data only with your consent (for online advertising, see Section 12).
If you act as an employee for a company with which we have concluded a contract, performance of this contract may require us to tell the company, for example, how you have used our service.
- Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. These authorities act as separate controllers.
Examples are criminal investigations, police measures (for example, procedures for health protection, the fight against violence, etc.), regulatory requirements and investigations, legal proceedings, reporting obligations and precourt and out-of-court proceedings, as well as legal obligations to provide information and to cooperate. Data may also be disclosed if we wish to obtain information from public bodies, for example, to justify a request for information or because we need to state about whom we require information (for example, from a register).
- Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4, for example, service recipients, the media and associations in which we participate or if you are included in one of our publications.
Other recipients include, for example, delivery recipients or third-party payees specified by you, other third parties in relation to agency relationships (for example, if we share your data with your lawyer or your bank) or persons involved in administrative or legal proceedings. If we cooperate with the media and share materials with them (for example, photos), this may also affect you depending on the circumstances. The same applies if we publish content (for example, photos, interviews, quotes, etc.) for example, on our website or in our other publications. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the disclosure of data (including from you for example, as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In relation to communicating with competitors, industry organizations, associations and other bodies, data may be exchanged that also affects you.
All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example, IT providers), but not by others (for example, authorities, banks, etc.).
In addition, we enable certain third parties to collect personal data from you on our website and at events organized by us (for example, press photographers, providers of tools on our website, etc.). Where we have no control over this data collection, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 12 for the website.
8. Is your personal data disclosed abroad?
As explained in Section 7, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed in any country in the world.
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: eurlex.europa.eu/eli/dec_impl/2021/914/oj, unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply, for example, in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.
Many countries outside Switzerland or the EEA currently do not have laws that ensure an adequate level of data protection under DPA or GDPR. The contractual arrangements mentioned compensate for this weaker or missing legal protection to some extent. However, contractual precautions cannot eliminate all risks (namely of government access abroad). You should be aware of these remaining risks, even though they may be low in an individual case, and we take further measures to minimize them.
Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.
9. How long do we process your data?
We process your data for as long as our processing purposes, legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage remain a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
Documentation and evidence purposes include our interest in documenting processes, interactions, and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data, and we therefore need to keep it with it (for example, in case of backups or document management systems).
10. How do we protect your data?
We take appropriate security measures to maintain the required security of your personal data and ensure its confidentiality, integrity, and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure, or access.
Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely; residual risks are unavoidable.
11. What are your rights?
Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
- The right to request information from us as to whether and what data we process from you;
- The right to have us correct data if it is inaccurate;
- The right to request erasure of data;
- The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
- The right to withdraw consent, where our processing is based on your consent;
- The right to receive, upon request, further information that is helpful for the exercise of these rights;
- The right to express your point of view in case of automated individual decisions (Section 6) and to request that the decision be reviewed by a human.
If you wish to exercise the abovementioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example, by means of a copy of your ID card, unless identification is not possible otherwise).
You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 7 and additional information in Section 12.
Please note that conditions, exceptions, or restrictions apply to these rights under applicable data protection law (for example, to protect third parties or trade secrets). We will inform you accordingly where applicable.
In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example, by redacting content that concerns third parties or our trade secrets).
If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
12. Do we use online tracking and online advertising techniques?
We minimize the amount of tracking and advertising we use. Currently we only create aggregated statistics via the webserver log files. Currently we only integrate a limited amount of external data processors on our website. These are :
13. What data do we process on our social network pages?
We may operate pages and other online presences (“fan pages”, “channels”, “pro-files”, etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example, when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example, about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example, to personalize advertising) and to manage their platforms (for ex-ample, what content they show you) and, to that end, they act as separate con-trollers.
We receive data about you when you communicate with us through online presences or view our content on the corresponding platforms, visit our online presences or are active on them (for example, publish content, submit comments). These platforms also collect tech-nical data, registration data, communication data, behavioral data and preference data from you or about you, among other items (see Section 3 about these terms). These platforms usually perform statistical analysis of the way you interact with us, how you use our online presences and our content or other parts of the platform (what you view, comment on, “like”, forward, etc.) and combine this data with other information about you (for example, infor-mation about your age and your gender and other demographic information). In that way, they create profiles about you and statistics on the use of our online presences. They use this data and profiles to display to you our or other advertisements and other personalized content on the platform and to manage the behavior of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. We can control the analysis that these platforms generate regarding the use of our online presence to some extent.
For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects and associated rights and how you can exercise them or obtain further information. We currently use the following plat-forms:
- We use the technical platform and services of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland for the information service offered on Linked under ch.linkedin.com/company/schaffner-gruppe. We would like to point out that you use this LinkedIn page and its functions with your own responsibility. This applies in particular to the use of the interac-tive functions (e.g. commenting, sharing, rating). Alternatively, you can also access parts of the information offered via our website at www.schaffner.com.
LinkedIn is the sole responsible party for the processing of personal data when you visit our LinkedIn page. For more information about the pro-cessing of personal data by LinkedIn, please visit www.linkedin.com/legal/privacy-policy.
When you visit, follow, or engage with our LinkedIn company page, LinkedIn processes personal data to provide us with anonymized statistics and insights. This provides us with insights into the types of actions that people take on our site (so-called page insights). For this purpose, LinkedIn processes in particular such data that you have already provided to LinkedIn via the information in your profile, such as data relating to func-tion, country, industry, seniority, company size and employment status. In addition, LinkedIn will process information about how you interact with our LinkedIn company page, such as whether you are a follower of our LinkedIn company page. With page insights, LinkedIn does not provide us with any personal data about you. We only have access to the aggregated Page Insights. It is also not possible for us to draw conclusions about indi-vidual members via the information in the Page Insights. This processing of personal data in the context of Page Insights is carried out by LinkedIn and us as joint controllers. The processing serves the performance of a public task. The evaluation of the types of actions taken on our LinkedIn company page serves in the context of public relations to improve our company page based on these insights. We have entered into a joint controller agreement with LinkedIn, which sets out the distribution of data protection obligations between us and LinkedIn. The agreement is available at: legal.linkedin.com/pages-joint-controller-addendum.
Thereafter, the following applies:
You can contact the Data Protection Officer at LinkedIn Ireland via the fol-lowing link: www.linkedin.com/help/linkedin/ask/TSO-DPO. You may also contact us via the contact details we have provided about exercising your rights in connection with the processing of personal data in the context of Page Insights. In such a case, we will forward your request to LinkedIn.
LinkedIn and we have agreed that the Irish Data Protection Commission is the lead supervisory authority overseeing processing for Page Insights. You always have the right to lodge a complaint with the Irish Data Protection Commission (see at www.dataprotection.ie) or any other supervisory au-thority.
- We use the technical platform and services of YouTube which is provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland for the information service offered on Youtube under www.youtube.com/user/schaffnergroup. We would like to point out that you use this Youtube page and its functions at your own responsibility. This applies in particular to the use of interactive functions (e.g. comment-ing, sharing, rating). Alternatively, you can also access some of the infor-mation offered via our own website at www.schaffner.com.
Youtube is the sole responsible party for the processing of personal data when you visit our Youtube page. For more information about the pro-cessing of personal data by Youtube, please visit https://policies.google.com/privacy?hl=en-US.
- When you visit, follow or engage with our Youtube company page, Youtube processes personal data to provide us with anonymized statistics and in-sights. This provides us with insights into the types of actions that users take on our site. For this purpose, Youtube processes in particular such da-ta that you have already provided to Youtube via the information in your profile. In addition, Youtube will process information about how you interact with our Youtube company page, such as whether you are a follower of our Youtube company page. With page insights, Youtube does not provide us with any personal data about you. We only have access to the aggregated information. It is also not possible for us to draw conclusions about individ-ual members via the information
Insofar as your personal data processed in connection with the use of our social media channel it is also or exclusively processed for the relevant service provider's own purposes, such as the technical and administrative provision of its own online services, including the storage and evaluation of user data generated in the pro-cess. Insofar as data processing in the context of the provision and use of our social media channels is carried out on the basis of joint controllership of Schaffner and the respective service provider, such as in particular data analysis for statistical purposes, we have concluded an agreement between jointly responsible parties with the service provider in accordance with the legal requirements, which you can view here:
14. Can we update this Data Protection Notice?&
This Data Protection Notice is not part of a contract with you. We can change this Data Protection Notice at any time. The version published on this website is the current version. Last updated: 31.10.2022 This Data Protection Notice is not part of a contract with you. We can change this Data Protection Notice at any time. The version published on this website is the current version. Last updated: 31.10.2022