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ZURICH
Swisspath Group
Seefeldstr. 56
8008 Zurich
Switzerland

T +41 44 454 26 26
F +41 44 454 26 27
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BVI
Swisspath Consulting (BVI) Ltd/
Swissbluecapital (BVI) Ltd
3076 Sir Fancis Drake’s Highway
PO Box 3463
Road Town, Tortola
British Virgin Islands

T +1284 494 8161
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Swisspath.com

Privacy Policy

Who controls the personal data

The Controller of personal data collected through the website is:
Swisspath Group
Seefeldstrasse 56
8008 Zürich, Switzerland
Telefon: +41 44 454 26 26
Fax: +41 44 454 26 27
Email: info@swisspath.com.

Swisspath determines the purposes and means of the processing of your personal data and is therefore responsible for the processing and use of your personal data as described in this Privacy Policy. If you have any questions or concerns regarding privacy or how we process your personal data, kindly contact us at any time by sending an email to info@swisspath.com.

 

How do we process personal data

Any personal data collected through the website is processed in accordance with the provisions of applicable data protection and privacy laws. We collect and process personal data carefully and for the purposes described in this Privacy Policy. In accordance with applicable law, we may also use your personal data in other ways as described in this Privacy Policy. In such event, we will provide specific privacy policies or notices at the time of collection and obtain your consent where necessary. We always seek, to the extent reasonably possible, to collect information on an anonymized or pseudonymized basis so we cannot recognize your identity.

 

What personal data do we collect via our website contact information

We may collect the following personal data via our website contact information:

a. Information provided by you

We collect information which you actively and voluntarily provide us through the website via our contact email address info@swisspath.com or by phone call. This may include the following personal data:

  • your name, first name, address, email address, phone number, business contact information, information about your business or other information about yourself or another person;
  • Information that you provide when you apply for a job position, such as your name, email address, address, telephone number, date of birth, qualifications, competences, experience, skills, education, information relating to your employment history, third party references. This includes information provided via email, CVs or resumes, in person via telephone, at interviews and/or by any other method.

The providing of such personal data will always be voluntary based on your consent. Without providing such information you may, however, not be able to use the services or purposes for which the information is requested.

We may in certain circumstances also collect personal data not directly provided by you, but from third parties to the extend relevant and permitted by applicable law, e.g. in connection with a job application. We may, subject to your consent, seek references about you from former employers or any other references provided by you.

b. Information automatically collected

Swisspath collects and stores information that your browser automatically transmits to us in „server log files“ when visiting our website. These may include the following data:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address
  • These data will not be combined with data from other sources.

This data is stored by us until it is automatically deleted within six months at the latest.

 

For what purposes and on what legal basis do we process personal data about you

a. Purposes of processing

i) Information provided by you

We will use the information provided by you for the lawful purposes which were evident from the circumstance or indicated at the time of collection which may include the following purposes:

  • communicating with you (e.g. about our services) and provide you with the best possible and personalized information you may require from us;
  • for answering any questions or requests you may have about our services in the best possible manner, asking you questions and giving additional information tailored to your interests in connection with our services prior to entering into a possible contract relation;
  • to consider your application in respect of a position for which you have applied;
  • to consider your application in respect of other future positions in case your application was unsuccessful; in such an event, we will seek your consent for keeping your application on file after we have informed you about the rejection of your job application;
  • to communicate with you in respect of the recruitment process, e.g. to obtain additional information where necessary, to provide you with information relating to your application;
  • to contact third party references provided by you to evaluate your previous performances subject to your consent; and
  • to fulfill and comply with legal and regulatory compliance obligations imposed on us, e.g. it is mandatory to check a successful applicant’s eligibility to work in a country before employment begins.

ii) Information automatically collected

The data automatically collected as described above is processed for the purposes of proper functioning of our website, e.g. for establishing a connection, ensuring stability and uninterrupted system security, to improve our services, and for statistical purposes in the event of attacks on the network infrastructure on which the website is made available.

b. Legal basis for processing

The legal basis for processing your personal data for the purposes described above may be based on the following legal grounds:

  • your consent;
  • for the performance of a contract with you or for the intention to enter into a contract, e.g. an employment contract;
  • to comply with a legal obligation (e.g. for purposes of legal investigations or proceedings), or
  • for the purposes of our legitimate interests, for example for maintaining and improving our internal business administration, organization, operations, risk management, protection of systems and premises, prevention of fraud and other offences, for advertising and marketing activities, to guarantee an effective, efficient, secure and harmonized service;
  • to comply with legal or other regulatory requirements and internal rules; and for establishing, exercise and/or defend actual or potential legal claims, investigations or similar proceedings.

Should the processing be based on your consent or our legitimate interests, you may withdraw consent or object to that processing at any time by contacting us directly at info@swisspath.com. The personal data processed before we receive your request may still be legally processed.

 

With whom do we share your personal data

We take necessary measures to ensure only our authorized personnel on a need to know basis will have access to your personal data to fulfill the purposes for which your personal data was collected.

We may share your personal data with the following categories of recipients in accordance with the purposes of processing as described herein:

  • our affiliated companies;
  • our trusted third-party service providers, including processors (e.g. providers of IT services);
  • website designers and developers;
  • professional advisors and auditors;
  • acquires or parties interested in acquiring business units, companies or other parts of Swisspath;
  • governmental administrations, courts and other competent authorities;
  • other parties in potential or actual legal proceedings.

We choose our partners and data processors carefully and only upon sufficient guarantees they have appropriate technical and organizational measures in place. Our third-party partners are subject to confidentiality requirements and may use your personal data solely to the extent necessary to fulfill the purpose for which your personal data was collected, except as otherwise required by law.

 

Transfer of personal data to countries outside the EEA

We may transfer, store and process your personal data in data locations around the world, where our affiliated companies or our third-party providers are located. Therefore, we may transfer your personal data outside the EEA if it is required for the data processing described in this Privacy Policy in accordance with applicable law.

If data is disclosed to countries that do not guarantee an adequate level of protection, Swisspath will ensure adequate protection of data disclosed by putting appropriate safeguards in place, such as contractual guarantees (e.g., on the basis of EU standard clauses), binding corporate rules, on the basis of the EU-U.S. and the Swiss-U.S. Privacy Shield Framework for transfers to third parties based in the U.S., or transferring data pursuant to explicit consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims. You may obtain more information about our appropriate safeguards by contacting us via email to info@swisspath.com.

 

For how long do we keep information about you

We retain your personal data for as long as necessary to fulfill the purposes for which your personal data was collected. For this reason, we will delete or anonymize personal data (or equivalent) once they are no longer necessary to achieve the purposes, subject however (i) to any applicable legal or regulatory requirements to store personal data for a longer period (e.g. for tax or accounting reasons), or (ii) to establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings, including legal holds, which we may enforce to preserve relevant information.

On that basis, we normally process personal data subject to the following rules and obligations:

  • For contract related personal data (including business records and communication), we retain personal data as long as the contractual relation is ongoing and for ten years after the termination of the contractual relationship;
  • For unsuccessful job applicant’s data, we will hold personal data on file for six months after the end of the relevant recruitment process or, with applicant’s consent, we will keep personal data on file for additional twelve months for consideration for future job positions;
  • For operational data containing data (e.g. protocols, logs), we retain personal data for a period of 3 – 12 months.

 

Google Maps

This website uses the map service of Google Maps via an API. Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA is the provider. The storage of your IP address is required if you want to use the functions of Google Maps. This information is normally transmitted to a server of Google in the USA and it will be stored there. Swisspath has no influence over the data transmission.

Google Maps is used to facilitate our location listed on our website. This represents a legitimate interest of Swisspath for the processing of the data (see point 4 b).

Further information about the handling of user data can be found in the data privacy statement of Google: https://www.google.de/intl/de/policies/privacy.

 

Security

We have implemented various technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.

Swisspath may use third party data processors to collect and process your personal data. Any data processors commissioned by us will only process your personal data in accordance with our instructions and are legally obliged to adhere to strict security procedures when handling personal data.

Unfortunately, transmission of information via the internet is not wholly secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is done so at your own risk. Once we have received your information, we employ strict procedures and rigid security measures to try to prevent unauthorised access.

 

Children

Our websites are not intended for children and we do not knowingly collect personal data from children under the age of 16. If we are notified or otherwise learn that personal data of a child under the age of 16 has been improperly collected, we will take all reasonable steps to delete that personal data.

 

What are your rights

You may request information from Swisspath as to whether data concerning you is being processed. In addition, you have the right to request the correction, destruction or restriction of personal data regarding yourself as well as to object to the processing of personal data. Should the processing of personal data be based on consent, you may withdraw consent at any time. However, please note that a withdrawal does not affect the legitimacy of the processing activities that took place before you withdrew your consent. In countries of the EEA you may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Request in this respect shall be submitted to Swisspath via the following email address: info@swisspath.com. Swisspath reserves the right to restrict the rights of the affected user in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.

For any requests and any questions or concerns regarding this Privacy Policy or how we process your personal data, kindly contact us at any time by sending an email to info@swisspath.com.

If we refuse your request or if you are not satisfied with our processing, you are also entitled to lodge a complaint with the competent supervisory authority and seek a judicial remedy. For users located in Switzerland, the competent authority is the Federal Data Protection and Information Commissioner in Switzerland (http://www.edoeb.admin.ch). For the users located in the EU Countries, a list of the supervisory authorities can be found here.

 

Changes to our Privacy Policy

This Privacy Policy may be changed from time to time and without prior notice or announcement. All changes to this Privacy Policy are effective when they are posted on the website unless indicated otherwise. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our website or in another appropriate manner prior to the change becoming effective and update the ‘effective date’ at the top of this page.