Privacy Notice

Privacy Notice

Sandsiv Switzerland Ltd and its group companies (“SANDSIV”) is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the applicable data protection legislation protects you.

The main data protection legislation applicable to SANDSIV is the Swiss Federal Act on Data Protection. However, SANDSIV is also committed to complying with Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation”) and the UK Data Protection Act 2018 and UK GDPR.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how SANDSIV collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or similar service.

This website is not intended for children and we do not knowingly collect data relating to  children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

SandSIV Switzerland Limited (also known as SandSIV Schweiz AG) is the controller and responsible for  your  personal  data.   Group  companies  of  SandSIV  Group  Limited  may  also  collect  your personal data (collectively referred to as “SANDSIV”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Privacy Manager (DPM) who is responsible for overseeing questions in  relation to this privacy notice. 

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPMusing the details set out below.

Contact details

Our full details are:

Full name of legal entity: SandSIV Switzerland Limited Email address: privacy@sandsiv.com 

Postal address: Technoparkstrasse 1, CH-8005 Zurich

You have the right to make a complaint at any time to the Swiss Federal Data Protection and Information Commissioner (https://dsb.zh.ch) or to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.   We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier,
  • Contact Data includes e-mail address and telephone
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this
  • Usage Data includes information about how you use our website, products and
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not  considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated  Data  with  your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms. This includes personal data you provide when you:
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We only use analytical cookies, such as HubSpot and Google analytics. For more details please visit our Cookie Policy here – https://sandsiv.com/cookie-policy/

Lawful basis for which we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following lawful bases:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those
  • Where we need to comply with a legal or regulatory obligation
  • Where we have your consent (for processing for marketing purposes)

Purposes for which we will use your personal data

  • For data collected via direct interactions (for the contract that we have with you and on the basis of our legitimate interests or your consent) :
    • To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey
    • To make suggestions and recommendations to you about goods or services that may be of interest to you
    • For data collected via automated technologies or interactions (on the basis of the legitimate interest of our company):
      • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting  of data)
    • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • To comply with legal and regulatory requirements for example our financial and reporting obligations and data security obligations

Please rest assured that SandSiv adheres to the principle of data minimization, so the amount of the personal data processed by SandSiv is a necessary minimum for achieving the identified purposes of the processing.

SandSiv does not use automated decision-making based on automated processing of your personal data.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies we use, please visit our Cookie Policy here – https://sandsiv.com/cookie-policy/.

Change of purpose

If we need to use your personal data for a purpose unrelated to the purpose for which we originally processed your data, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data 

We may have to share your personal data with the parties set out below for the purposes set out in “Purposes for which we use your personal data” above.

  • Internal Third Parties as defined in the Glossary, to the extent they are involved in the provision of services to you being part of SANDSIV.
  • External Third Parties as defined in the Glossary, to the extent they are involved in the provision of services to you or the provision of infrastructure required in connection with the services.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data outside of Switzerland, the UK and the European Economic Area (EEA) without implementing the necessary safeguards as required by the data protection legislation.

Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will     notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention 

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

For data collected via this website, we will keep the data for approximately 12 months from the last interactivity with you and will then delete it. However, where you are a customer or customer contact, different retention periods apply, as set out in the services agreement or otherwise agreed. 

Your legal rights

You have rights under data protection laws in relation to your personal data. Please refer to the below and the definitions in the Glossary to find out more about these rights:

  • Withdraw your consent
  • Access to your personal data
  • Correction of your personal data in case of any inaccuracies
  • Request erasure of your personal data in specific circumstances
  • Object to processing of your personal data.
  • Request restriction of processing your personal data in specific circumstances
  • Transfer of your data to another entity in specific circumstances
  • File a complaint to the Supervisory Authority in case of privacy violation

If you wish to exercise any of the rights set out above, please contact our DPM.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and  ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

 

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means processing your personal data where you provided us with a freely given, specific, informed and unambiguous indication, by a statement or by a clear affirmative action, signifying agreement to the processing of personal data relating to you.

THIRD PARTIES

Internal Third Parties

Other companies in the SANDSIV Group , each of which is bound by confidentiality and non-disclosure obligations.

External Third Parties

  • Hosting provider
  • CRM provider
  • Analytics provider

Please contact us if you want more information.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons  which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Changes to this privacy notice

SANDSIV may update this notice from time to time by publishing the new version on this website. Please check this page regularly to make sure you are up-to-date with any changes to the terms of this notice.

Last updated: September 2023