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Privacy Policy

(hereafter referred to as the “website”)
 

Version dated 23 May 2018

 

1. Subject of the privacy policy and responsible authority

This privacy policy provides visitors of our website (hereafter referred to as “users”) with information about the nature, scope and purpose of the collection, processing and use of their personal data by the accountable provider of this website.

The accountable provider of the website is ACOLIN Holding AG. For more information, please refer to the legal notice. In case of questions or comments regarding the privacy policy, you can contact us as follows:

ACOLIN Holding AG
Affolternstr. 56
CH-8050 Zurich, Switzerland
E-mail: dataprivacy@acolin.com
Telephone: +41 44 396 96 96

By using this website of ACOLIN Holding AG, you explicitly consent – where required – to the processing of your personal data as described in this privacy policy.

 

2. Collection, processing and use of personal data in general

We collect, process and use personal data of users in compliance with the applicable data protection provisions of Switzerland and the European Union. ACOLIN Holding AG processes personal data that has been collected in good faith and in a lawful manner comprehensible for the respective person and in accordance with the following provisions. Unless specified otherwise, the mentioned terms follow the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereafter “GDPR”).

Whenever the user visits the website, certain personal data are automatically collected. For the specific data collected, please refer to the following sections (cookies, plug-ins etc.).

 

3. Legal basis in general

The personal data of users is by default only processed after the user has provided consent. An exception shall apply in cases when consent cannot be obtained in advance for factual reasons and it is permitted to process the data due to legal provisions or predominant interests.

For the cases in which we obtain consent for processing personal data from the respective person, Art. 6 Para. 1 (a) GDPR or Art. 13 Para. 1 in conjunction with 4 Para. 5 Swiss Federal Act on Data Protection (FADP) shall serve as legal basis.

When processing personal data is required for fulfilment of a contractual obligation with the respective person being the contractual party, Art. 6 Para. 1 (b) GDPR and Art. 13 Para. 2 (a) FADP shall serve as legal basis. This also applies to processing required for executing pre-contractual measures.

When personal data need to be processed to preserve a legitimate interest of our enterprise or of a third party and the interests, basic rights and freedoms of the affected person do not outweigh the former interests, Art. 6 Para. 1 (f) GDPR and Art. 13 Para. 2 FADP shall serve as legal basis for processing personal data.
 

4. Purpose of processing in general

The collected (personal) data of the users may be partially used for marketing purposes. However, the primary purpose of collected data is for use and maintenance of the website’s functionalities. More specific information is available in the provisions below.

When contacting ACOLIN Holding AG, for example through the contact form, the information and contents of the form are used and stored for processing the request and possible follow-up questions.

ACOLIN Holding AG may pass personal data on to subsidiaries (jointly and hereafter referred to as “ACOLIN”) for the previously mentioned purposes. In any case, the specific purpose of data collection remains in force.

 

5. Collection of general information when visiting the website (log files)

Every time the website is accessed, we or the webspace provider automatically collect certain information. This information is referred to as server log files.

The collected information includes:

Access date and time, web browser and version used, referrer URL (the page from which you access our website), and the IP address.

This data is stored in the log files for debugging purposes and to be able to identify the perpetrator in case of online attacks (hacking etc.). Therefore, the collection of personal data is mandatory while a limitation of or objection to data processing could lead to loss of full functionality of the website, which is why such limitation or objection is only possible in part.

Art. 6 Para. 1 (f) GDPR and Art. 13 Para. 2 FADP serve as legal basis for temporarily storing data and log files.

Personal data will be deleted after 3 months at the latest.

 

6. Cookies

This website uses cookies. Cookies are text files that the server sends to your web browser, where they are stored for later access. Cookies contain information about the session, particularly the date of creation and expiration. We will not forward such data to third parties or link it with your personal data without your consent.

We use session cookies to make the experience of our website more user-friendly. Cookies help us to simplify navigation through our website and enable the website to display correctly. Some elements of our website require the accessing browser to be identifiable after changing sites.

You also have the option of accessing our website without the use of cookies. To do so, please change the relevant settings in your browser. For information on how to disable cookies, please refer to the Help function of your browser. However, we would like to inform you that disabling cookies may restrict some of the website’s functionalities and thereby reduce comfort of use.

We will delete personal data, which may have been collected, at the latest when you remove the session cookie from your browser.

The legal basis for processing personal data through the use of cookies is Art. 6 Para. 1 (f) GDPR and Art. 13 Para. 2 FADP, as the data significantly contributes to proper operation of the website as per the described purpose.

 

7. Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics makes it possible to allocate dates, sessions and interactions across several devices to one pseudonymous user ID and therefore analyse the activities of a user on several devices.

Google Analytics also uses cookies (see above description in Item 6). The information about your use of our website generated by cookies (such as web browser and version used, operating system of the user, domain name of the Internet provider of the user, referrer URL, abbreviated IP address) is generally transmitted to a Google server in the United States and stored there.

We only use Google Analytics with IP anonymisation enabled. This means that Google truncates the IP address within member states of the European Union and other contractual states of the treaty of the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and truncated there. Therefore, ACOLIN is no longer able to match the address to a person.

Google uses the information on our behalf to anonymously evaluate your use of the website, compile reports about website activities and provide further services associated with the use of the website and the Internet in general to the website operator. The IP address transmitted by your browser for Google Analytics is not linked with other data provided by Google.

If you object to this, you can prevent your data from being collected through cookies and regarding your personal website use (incl. IP address) by Google and stop Google from processing this data by downloading and installing the browser plugin available at the following link: Browser add-on for deactivating Google Analytics: http://tools.google.com/dlpage/gaoptout?hl=en.

You may prevent cookies from being stored by changing the settings in your browser software. However, we would like to inform you that in this case, you will not be able to use the full functionality of this website.

The legal basis for the use of Google Analytics is Art. 6 Para. 1 (f) GDPR and Art. 13 Para. 2 FADP as we rely on the information collected (in anonymous form) for the purposes of improvement.

The collected data are deleted automatically after 14 months.

More information about the terms of use and data protection is available at http://www.google.com/analytics/terms/gb.html or at https://policies.google.com/?hl=gb.

 

8. Use of Twitter, LinkedIn and Xing recommendation components

We use components of the providers Twitter, LinkedIn and Xing on our website. Twitter is a service provided by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. LinkedIn is a service provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Xing is a service provided by XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany.

The purpose of these components is for you to be able to access the respective social media account directly from ACOLIN and/or share certain content from the website using your own profile.

We use a “Shariff” plugin, which prevents personal data from being sent to the social media platform before you access it.

We have no influence on the data collected by accessing the social media platform. More information is available in the privacy policy:

http://twitter.com/privacy.

http://www.linkedin.com/legal/privacy-policy

https://www.xing.com/app/share?op=data_protection

 

9. Information about newsletter and consent

The following information is intended to explain the content of our newsletter as well as the subscription, distribution and statistical analysis processes and your rights of objection. By subscribing to our newsletter, you consent to receiving it and to the described processes.

Our website offers the option of subscribing to a newsletter free of charge. When doing so, the data entered to subscribe to the newsletter (all mandatory: e-mail address, first and last name, enterprise) as well as the log data (see b) below) are sent to us.

If you register to receive our newsletter, we will only use the data you entered for the purposes of personalising the newsletter or to inform you about the circumstances relevant for this service or registration. We do not send personal data to third parties.

To process data, we obtain your consent during the registration process (see Art. 6 Para. 1 (a) GDPR) and refer to this privacy policy.

a) Contents of newsletter

We send newsletters, e-mails and other electronic notifications containing advertisements (hereafter referred to as the “newsletter”) only if consent has been provided by the recipient or on the basis of legal provisions. In addition, our newsletters contain information about current topics concerning ACOLIN.

b) Double opt-in and logging

If you subscribe to our newsletter, it will be via a double opt-in process. This means that you will receive an e-mail after registering in which you will be asked to confirm that you wish to subscribe. This confirmation is required so that nobody can subscribe with e-mail addresses belonging to other people.

Your registration for the newsletter is logged so that the registration process can be substantiated as required by legal provisions. This includes storing the time you registered and confirmed, as well as your IP address.

c) Use of the e-mail marketing service provider “MailChimp”

Newsletters are sent using “MailChimp“, an e-mail marketing platform of the US service provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

The e-mail addresses of our newsletter recipients and other personal data obtained as part of this information about the newsletter is stored on MailChimp servers in the United States. MailChimp uses this information to send and evaluate the newsletter in our order. Furthermore, MailChimp may, according to its own information, use this data to optimise or improve its own services, e.g. for the technical optimisation of shipping and the presentation of newsletters or for economic purposes, to determine which countries the recipients come from. However, MailChimp does not use the data of our newsletter recipients to write to them themselves and does not share the data with third parties. Subcontractors and subsidiaries are excluded from this.

We rely on the reliability and IT and data security of MailChimp. MailChimp is certified under the US-EU privacy agreement Privacy Shield and has therefore committed to complying with EU data protection requirements. Furthermore, we have concluded a Data Processing Agreement with MailChimp. This is a contract in which MailChimp has committed to protecting the data of our users, to process it in accordance with its privacy policy on our behalf and, in particular, not to disclose it to third parties. You can view the privacy policy of MailChimp here.

The legal basis for the inclusion of MailChimp is Art. 6 Para. 1 (a) and (f) GDPR andArt. 13 FADP. We are interested in having a user-friendly and secure newsletter system that serves both our business interests and the expectations of our users.

d) Statistical survey and analyses

The newsletters contain a “web-beacon”, meaning a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. In the scope of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services based on their specifications or target audience and their reading behaviour, according to their retrieval locations (which can be determined using the IP address) or access times.

Statistical surveys also include determining whether the newsletters will be opened, when they will be opened and which links will be clicked on. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our desire nor that of MailChimp to monitor individual users. The analyses serve us to a greater extent and only with a view to identifying the reading behaviour of our users and to adapt our content to them or to send different content, according to the interests of our users.

e) Online request for information and data management

There are cases in which the newsletter recipients are redirected to the MailChimp websites. This means that our newsletters may contain links that allow newsletter recipients to retrieve newsletters online (for example, in the event of problems displaying it with the e-mail program). Furthermore, newsletter recipients can store their data, such as subsequently correcting the e-mail address. Similarly, the MailChimp privacy policy is only available on their website.

In this context, we point out that cookies are used on the MailChimp websites and therefore personal data is processed by MailChimp, their partners and service providers (for example, Google Analytics). We have no influence on this data collection. Further information can be found in the MailChimp privacy policy. We also point out the possibilities to object to data collection for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European area).

f)  Cancellation/revocation and deletion

You may object to the receipt of our newsletter at any time; in other words, you may revoke your consent. At the same time, your consent to it being sent via MailChimp and the statistical analyses will be cancelled. Unfortunately, you cannot separately revoke your consent to it being sent via MailChimp or to the statistical evaluation.

At the end of each newsletter you will find an unsubscribe link.

The personal data is deleted by us as soon as it is no longer necessary for the purpose of its collection. The e-mail address of the user is therefore stored as long as the subscription to the newsletter is active. The other personal data collected in the course of the registration process will be kept for as long as it is required to prove that the user has subscribed to the newsletter. Rocket Science Group LLC will delete the personal data collected after the discontinuation or expiration of the contractual relationship with ACOLIN or will provide this information to ACOLIN for deletion.

 

10. Contact form

Contact forms are available on our website that can be used to make contact electronically. If a user uses this option, the data entered in the form will be transferred to us and saved. These details are:

  1. Name
  2. Enterprise
  3. E-mail address
  4. Telephone number
  5. Message

At the time of sending the contact form, the following data is also stored:

  1. The user’s IP address
  2. Date and time of the communication

In order to process personal data, your consent is obtained during the sending process and reference is made to this privacy policy.

Alternatively, contact is possible via the e-mail address provided. In this case, the user’s personal data communicated by e-mail will be stored.

In this context, there is no disclosure of the data to third parties, with the exception of the aforementioned disclosure within ACOLIN Holding. The personal data from the entry form is processed exclusively for contact and conversation purposes. The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

The legal basis for the data processing is the user’s consent as per Art. 6 Para. 1 (a) GDPR and Art. 13 Para. 1 FADP. The legal basis for the processing of data communicated in the course of sending an e-mail is Article 6 Para. 1 (f) GDPR and Art. 13 Para. 2 FADP. If the e-mail contact aims to conclude a contract, then additional legal basis for the processing is Art. 6 Para. 1 (b) GDPR and Art. 13 Para. 2 (a) FADP.

The user has the possibility to revoke their consent to the processing of personal data at any time. If the user contacts us by e-mail, they may object to the storage of their personal data at any time. In such a case, however, conversation cannot continue. All personal data that is stored in the course of establishing contact will be deleted in this case. If consent is not revoked, the data will be deleted as soon as it is no longer needed. Previous legal provisions remain reserved.

 

11. Integration of further services and content of third parties

Our offer sometimes includes content and services from other providers. These are, for example, maps provided by Google Maps, videos from YouTube and pictures and images from other websites. In order for this data to be accessed and displayed in the user’s browser, disclosure of the IP address is absolutely necessary. The providers (hereinafter referred to as “third-party providers”) therefore see the IP address of the respective user.

Although we endeavour to only use third-party providers who only need the IP address to deliver content, we have no control over whether the IP address is stored. This process is used for statistical purposes, among others. If we become aware that IP addresses are being stored, we will inform our users.

We also provide a link to ACOLIN connect on our website. This platform is also operated by ACOLIN, but its own privacy policy is applicable.

 

12. User rights

a) Right to information

You can request a confirmation from the person responsible that personal data concerning you is processed by us. If such processing is taking place, you can request details about the information as per Art. 15 GDPR and Art. 8 (f) FADP.

b) Right to rectification

You have a right to have your personal data corrected and/or completed with regard to the responsible person if the personal data concerning you is incorrect or incomplete. The responsible person must make the correction without delay.

c) Right to restriction of processing

Under the conditions set out in Art. 18 GDPR, you may request the restriction of processing of your personal data.

If the processing of personal data concerning you has been restricted, this data may only be processed – with the exception of its storage – with your consent or another legal exemption.

d) Right to erasure

You may request of the person responsible that the personal data concerning you be immediately deleted, and the person responsible is obliged to immediately delete this data, provided that one of the reasons stated in Art. 17 GDPR is fulfilled and there is no exemption clause.

e) Right of objection

You have the right at any time, for reasons that arise from your particular situation, to appeal against your personal data being processed, which occurs pursuant to Art. 6 paragraph 1 (e) or (f) GDPR.

f) Right to withdraw the data protection declaration of consent

You have the right to withdraw your data protection declaration of consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the point of revocation.

g) Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to appeal to a supervisory authority, in particular in the EU Member State of your place of residence, place of work or place of alleged breach, if you believe that the processing of the personal data concerning you violates the GDPR and said regulation is applicable.

The supervisory authority to which the appeal has been submitted shall inform the claimant of the status and results of the appeal, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.

For data processing under Swiss law, the remedies are governed by FADP.

 

The described rights can be asserted in writing by letter to the address mentioned above or by e-mail to dataprivacy@acolin.com.

 

13. Storage period

Unless otherwise stated in individual cases, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not obstruct any statutory storage obligations.

 

14. Changes to the privacy policy

We reserve the right to change the privacy policy, in order to adapt it to changed legal situations, or to changes in the service and data processing. However, this only applies to declarations of data processing. If consents are required or parts of the privacy policy contain provisions of the contractual relationship with you, the changes will only be made with your consent. We ask you to inform yourself regularly about the content of the privacy policy.

 

15. More information

ACOLIN endeavours to store your personal data by taking all appropriate technical and organisational measures so that it is not accessible to third parties. When communicating by e-mail, complete data security cannot be guaranteed, so we recommend that you send confidential information by post.

Employees and service providers appointed by ACOLIN are required by ACOLIN to maintain confidentiality and to comply with the applicable privacy policies.

We take organisational, contractual and technical security measures in accordance with the state of the art, in order to ensure that the provisions of the data protection laws are complied with and to protect the data we manage from accidental or intentional manipulation, loss, destruction or access by unauthorised persons.