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GLD Swiss Privacy Policy

 

Version as of January 1, 2024

 

In this privacy policy, we, GLD SWISS, explain how we collect and otherwise process personal data. This is not a definitive description; specific situations may be governed by other privacy policies. Personal data refers to any information relating to an identified or identifiable person.

 

If you provide us with personal data of other persons (e.g., family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only provide us with their personal data if you are allowed to do so and if these personal data are correct.

 

This privacy policy is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA"), and the revised Swiss Data Protection Act ("revDPA"). Whether and to what extent these laws apply depends on the individual case.

 

In data processing, we consider the principles of legality, proportionality, purpose limitation, transparency – particularly the duty to inform – and data security.

 

1. Data Controller / Data Protection Officer / Representative

Responsible for the data processing activities described here is GLD SWISS in Basel, unless otherwise specified in individual cases. If you have data protection concerns, you can contact us at the following address: GLD SWISS, Hochberger Strasse 60, 4057 Basel - info@gldswiss.ch

 

2. Collection and Processing of Personal Data

We primarily process personal data that we receive from our customers and other business partners in the course of our business relationship with them and other involved persons, or that we collect from users of our websites, apps, and other applications.

 

Where permitted, we also obtain certain data from publicly accessible sources (e.g., debt collection registers, land registers, commercial registers, press, internet) or receive such data from authorities. In addition to the data you provide us directly, the categories of personal data we receive about you from third parties include, in particular, information from public registers, information we learn in connection with administrative and judicial proceedings, information in connection with your professional functions and activities

(so we can, for example, conclude and process business with your employer through your assistance), information about you in correspondence and meetings with third parties, credit information (if we do personal business with you), information about you provided by persons in your environment (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or involving you (e.g., references, your address for deliveries, powers of attorney, information to comply with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, distributors, and other contract partners of ours for the use or provision of services by you (e.g., payments made, purchases made)), information from the media and internet about you (if appropriate in the specific case, e.g., in the context of an application, press review, marketing/sales, etc.), your addresses and possibly interests and other sociodemographic data (for marketing), data related to the use of the website (e.g., IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

 

3. Purposes of Data Processing and Legal Bases

We primarily use the personal data we collect to fulfill and execute our contracts with our customers and business partners. This is particularly relevant in the context reservation management, communication with our customers, and the procurement of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations domestically and abroad. If you are employed by such a customer or business partner, you may also be affected by this in your capacity with your personal data.

 

Additionally, we process personal data from you and others, as far as permitted and as we see fit, also for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

- Offering and further development of our services, websites, apps, and other platforms where we are present;

- Communication with third parties and processing their inquiries (e.g., applications, media inquiries);

- Examination and optimization of procedures for demand analysis for direct customer contact and collection of personal data from publicly accessible sources for customer acquisition;

- Advertising and marketing, as long as you have not objected to the use of your data (if we send you advertising as an existing customer, you can object at any time, and we will then place you on a blocklist against further advertising);

- Market and opinion research, media monitoring;

- Assertion of legal claims and defense in connection with legal disputes and regulatory proceedings;

- Prevention and investigation of criminal offenses and other misconduct (e.g., conducting internal investigations, data analyses for fraud prevention);

- Ensuring the operation of our business, especially IT, our websites, apps, and other platforms;

- Video surveillance to uphold house rights and other measures for IT, building, and facility security, and protection of our employees and other individuals and values owned or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone recordings);

- Purchasing and selling of business units, companies, or parts of companies, and other corporate transactions, and the associated transfer of personal data, as well as measures for business management and compliance with legal and regulatory obligations and internal regulations.

 

To the extent that you have given us consent to process your personal data for specific purposes (for example, when you register to receive newsletters or conduct a background check), we process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. A given consent can be revoked at any time, but this does not affect data processing that has already occurred.

 

4. Cookies / Tracking and Other Technologies in Connection with the Use of Our Website

 

On our websites, we typically use "cookies" and similar techniques to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser when you visit our website. When you visit this website again, we can recognize you, even if we do not know who you are. In addition to cookies that are only used during a session and deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information over a certain period (e.g., two years) ("permanent cookies"). However, you can configure your browser to reject cookies, only save them for a session, or delete them prematurely. Most browsers are set to accept cookies by default. We use permanent cookies. If you block cookies, certain functionalities may no longer work.

 

By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not wish this, you must adjust your browser or email programs accordingly.

 

Furthermore, on our websites, we use so-called plug-ins from social networks such as Facebook, Twitter, YouTube, Pinterest, or Instagram. This is typically visible to you (usually through corresponding symbols). We have configured these elements to be deactivated by default. If you activate them (by clicking), the operators of the respective social networks can register that you are on our website and where, and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator according to its privacy policy. We do not receive any information about you from them.

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5. Data Transfer and Transmission Abroad

Within the scope of our business activities and the purposes as per no. 3, as far as allowed and as we deem appropriate, we also disclose data to third parties, either because they process it for us, or because they want to use it for their own purposes. This particularly involves the following entities:

- Service providers of ours, including order processors;

- Dealers, suppliers, subcontractors, and other business partners;

- Customers;

- Domestic and foreign authorities, offices, or courts;

- Media;

- Public, including visitors to websites and social media;

- Competitors, industry organizations, associations, organizations, and other bodies;

- Acquirers or interested parties in the acquisition of business units, companies, or other parts of GLD SWISS;

- Other parties in possible or actual legal proceedings;

- Other companies of GLD SWISS.

These recipients are partly domestic but can be anywhere in the world. In particular, you must expect your data to be transmitted to any country where our service providers are located (such as Microsoft, WordPress).

 

If a recipient is in a country without adequate legal data protection, we contractually oblige the recipient to comply with applicable data protection (we use the revised standard contractual clauses of the European Commission, available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless they are already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exemption. An exemption may apply, in particular, in legal proceedings abroad, but also in cases of overriding public interest, or if contract execution requires such disclosure, if you have consented, or if it concerns data you have made generally accessible and have not objected to its processing.

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6. Duration of Personal Data Storage

We process and store your personal data for as long as it is necessary for the fulfillment of our contractual and legal obligations, or otherwise for the purposes pursued with the processing. This means, for example, for the duration of the entire business relationship (from initiation, processing to the termination of a contract) and beyond, in accordance with legal retention and documentation obligations. It is possible that personal data may be retained for the period during which claims can be made against our company, and as far as we are otherwise legally obligated or legitimate business interests require it (e.g., for evidence and documentation purposes). As soon as your personal data is no longer required for the purposes mentioned above, it will be deleted or anonymized as far as possible and practicable. For operational data (e.g., system logs, logs), generally shorter retention periods of twelve months or less apply.

 

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, and regular checks.

 

8. Obligation to Provide Personal Data

In the context of our business relationship, you must provide those personal data necessary for the initiation and execution of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or execute a contract with you (or the entity or person you represent). Also, the website cannot be used if certain details to ensure data traffic (such as IP address) are not disclosed.

 

9. Profiling and Automated Decision-Making

For the establishment and execution of the business relationship and otherwise, we generally do not use fully automated decision-making (as regulated, for example, in Article 22 of the GDPR). There is no profiling. If we use such procedures in individual cases, we will inform you separately, as legally required, and clarify your associated rights.

 

10. Rights of the Data Subject

Within the scope of the applicable data protection law that applies to you, and as far as provided therein (such as in the case of the GDPR), you have the right to access, correct, delete, restrict data processing, and otherwise object to our data processing, particularly for direct marketing purposes, profiling conducted for direct advertising, and other legitimate interests in processing, as well as the right to transfer certain personal data to another entity (so-called data portability). However, please note that we reserve the right to assert legally provided restrictions, for example, if we are obliged to store or process certain data, have an overriding interest in it (as far as we are allowed to rely on it), or need it for the assertion of claims. If there are costs for you, we will inform you in advance. We have already informed you about the possibility of revoking your consent in no. 3. Note that the exercise of these rights can conflict with contractual agreements and may have consequences such as early termination of the contract or cost implications. We will inform you about this in advance, where it is not already contractually regulated.

 

The exercise of such rights generally requires you to clearly prove your identity (e.g., by a copy of an ID card, where your identity is not otherwise clear or can be verified). To assert your rights, you can contact us at the address given in no. 1.

 

Moreover, every affected person has the right to enforce their claims in court or file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

 

11. Changes

We may adjust this privacy statement at any time without prior notice. The current version published on our website applies. If the privacy statement is part of an agreement with you, we will inform you about any updates via email or in another suitable manner.

 
 
 
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