Polimec Foundation (Polimec or we) is committed to protecting the privacy and security of the personal information that is provided to us or collected by us during the course of our operations. The processing of personal information shall always be in accordance with the Swiss Data Protection Act and to the extent applicable the EU General Data Protection Regulation (GDPR) and/or other country-specific data protection regulations applicable to Polimec as in force from time to time. We may provide you with additional privacy notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this privacy policy.

By means of this privacy policy, Polimec would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process on the Internet pages for Polimec. Furthermore, data subjects are informed, by means of this privacy policy, of the rights to which they are entitled.

As the controller of the Internet pages for Polimec (Polimec Websites), Polimec has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through the Polimec Websites. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means.

Definitions

Our privacy policy should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we explain the terminology used. In this privacy policy, we use, inter alia, the following terms:

1. Personal Data

   Personal data means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Until 1 September 2022, the term personal data will also cover information relating to an identified or identifiable legal person if Swiss data protection law is applicable.

2. Data Subject

   Data subject is any identified or identifiable person, whose personal data is processed by the controller responsible for the processing.

3. Processing

   Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Restriction of Processing

   Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

5. Profiling

   Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

6. Pseudonymisation

   Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

7. Controller

   Controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

8. Processor

   Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

9. Recipient

   Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

Name and Address of the Controller of the Polimec Websites

The controller of your personal data is Polimec Foundation, Reiffergässli 4, 6300 Zug, Switzerland. We are responsible for the processing of your personal information provided to us or collected by us during the course of our operations or for other purposes described in this privacy policy.
Website: www.polimec.org
Email: [email protected] (info at polimec.org)

Processing of Personal Data when Visiting the Polimec Websites

Polimec Websites collect a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. In particular, we may collect (1) the browser types and versions used, (2) the operating system used by the accessing system or the name of the access provider, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the name and the URL of the accessed documents and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Polimec does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Polimec analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our organisation, and to ensure an optimal level of protection for the personal data we process. The data of the server log files are stored separately from all personal data provided by a data subject.

The processing of this data is in our legitimate interest to provide services to you, to run Polimec’s operations (e.g. carry out administrative or operational processes), identify security risks, monitor and analyse our operations or to improve our services and products for you.

In certain instances, Polimec may request or collect other information or personal data from you when accessing specific websites (Participate Website) for the purpose of determining your eligibility to access other sections of the Participate Website for legal and regulatory purposes as well as compliance with any applicable law. This may include, but is not limited to, information or personal data provided by you via your credential (e.g. country of residence or incorporation) or other technical means, or any other data necessary for the purpose of accessing and using the services provided on the Participate Websites. By actively providing the requested information or personal data when accessing the Participate Websites, you explicitly consent to the collection and processing of the same by Polimec. This information or personal data will be processed with the same level of commitment to data protection and security as outlined in this privacy policy. The data collected for this purpose will be retained for documentation purposes according to any applicable law and will not be used for any other purposes.

Subscription to our Newsletters

On the Polimec Websites, visitors are given the opportunity to subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when and possibly for which topics the newsletter is ordered from the controller.

A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter shipping. This confirmation email is used to prove whether the owner of the email address as the data subject is authorised to receive the newsletter.

We only use this data for the delivery of our newsletter if you have agreed to receive it. You can unsubscribe from our newsletter at any time via a link in each respective email. You can also send us a message to [email protected] so that we can delete you from our mailing list. We will send you our newsletter based on your consent.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller. We process such data within our legitimate interest to ensure the offering of secure services in line with the applicable law.

To send you our newsletter in a professional manner, we use the solution SendGrid, which is a service from Twilio Inc., San Francisco, USA. Twilio has implemented a global privacy program based on Binding Corporate rules governing the global processing of personal data and ensuring an adequate level of data protection.

Newsletter-Tracking

The newsletter for Polimec contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Polimec may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller based on its legitimate interest to optimise the shipping of the newsletter, as well as to adapt the content of future newsletters to the interests of the data subject.

Contact Possibility via the Polimec Websites

The Polimec Websites contain information that enables a quick electronic contact to Polimec as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address).

We only use these data as well as any additional information voluntarily provided by you (e.g. in a message you write to us) in order to answer your contact enquiry in the best possible and personalised way. The processing of this data is therefore in our legitimate interest.

Retention Period of the Personal Data

Unless stated to the contrary within this privacy policy, the data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the Swiss legislator, the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by one of the above legislators or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Rights of the Data Subject

You have a right to request information about the personal data that we store about you. In addition, you have a right to correct incorrect data and a right to request deletion of your personal data, insofar as there is no legal obligation to retain such data and no legal basis for further processing the existing data. You also have the right to make a notice of objection in case you disagree with the processing.

You also have a right to request the data that you have provided to us (right to data portability). Upon request, we will transfer your data to a third party of your choice. You have a right to receive the data in a common file format.

You can contact us for the aforementioned purposes at [email protected]. In order to process your requests, we may request proof of your identity.

In many countries, you also have the right to file a complaint with the relevant data protection authority if you have concerns about how we process your data.

These rights depend on the applicable data protection legislation and may be either more limited or more comprehensive.

Security Measures

Polimec applies various adequate technical and organisational measures to help protect your personal data from unauthorised access or modification, improper use, disclosure, alteration or unlawful destruction or accidental loss. Our security measures are continuously improved in line with technological developments.

You should always treat your access data confidentially and close the browser window when you have finished communicating with us, especially if you share your computer, tablet or smartphone with others.

Our employees, partners and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

Use of Cookies

Cookies are small text files that are placed in browser directories on your computer or mobile device when you visit the Polimec Websites. The Polimec Websites use session cookies and persistent cookies. Session cookies enable you to move from page to page within the website and any information you enter to be remembered. A session cookie is deleted when you close your browser or after a short time. Persistent cookies allow the website to remember your preferences and settings when you visit the website in the future. Persistent cookies expire latest after three months.

You can change your browser settings to block cookies or to alert you when cookies are being sent to your device. Please note that if you decide to disable cookies, you may not be able to access certain functions of the Polimec Websites or communications.

Data Protection Provisions about the Application and Use of Google Analytics (with Anonymisation Function)

On the Polimec Websites, the controller has integrated the component of Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States (Google).

For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing the Polimec Websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of the Polimec Websites and to provide online reports, which show the activities on the Polimec Websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of the Polimec Websites. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under

https://www.google.com/intl/en/policies/privacy/ and

http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following

https://www.google.com/analytics/.

Use of Hotjar on the Polimec Websites

Polimec uses services of Hotjar Limited, a private limited liability company registered under the Laws of Malta with company number C65490 (Hotjar) in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps Polimec better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar does not disclose the data outside Europe. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section at

https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar

Use of Telegram on the Polimec Websites

The controller has integrated components of the Telegram Corporation on the Polimec Websites. Telegram is a cloud-based mobile and desktop messaging app with a focus on security and speed that allows encrypting, sending and destroying of documents and messages. The group function allows for sharing and of important messages as well as broadcasting special announcements to a wider group of people.

The company who developed Telegram was the Telegram Messenger LLP, registred in London at 71-75 Shelton Street, Covent Garden, London, United Kingdom.

With each call-up to one of the individual pages the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Telegram component of Telegram. Further information about the Telegram plug-in may be accessed under https://telegram.org/apps. During the course of this technical procedure, Telegram gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on Telegram, Telegram detects with every call-up to the Polimec Websites by the data subject – and for the entire duration of their stay on the Polimec Websites - which specific sub-page of the Polimec Websites was visited by the data subject. This information is collected through the Telegram component and associated with the respective Telegram account of the data subject. If the data subject clicks on one of the Telegram buttons integrated on the Polimec Websites, then Telegram assigns this information to the personal Telegram user account of the data subject and stores the personal data.

Telegram receives information via the Telegram component that the data subject has visited our website, provided that the data subject is logged in at Telegram at the time of the call-up to the Polimec Websites. This occurs regardless of whether the person clicks on the Telegram button or not. If such a transmission of information to Telegram is not desirable for the data subject, then he or she may prevent this by logging off from their Telegram account before a call-up to our website is made. Telegram does not disclose personal data outside of Europe.

The applicable privacy policy for Telegram is available under https://www.telegram.org/privacy.

The Telegram Terms of Service are available under https://www. telegram.org/tos.

Use of Twitter on Polimec Websites

On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of the Polimec Websites, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of the Polimec Websites was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of the Polimec Websites to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to the Polimec Websites by the data subject and for the entire duration of their stay on the Polimec Websites, which specific sub-page of Polimec Websites was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on the Polimec Websites, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited the Polimec Websites, provided that the data subject is logged in on Twitter at the time of the call-up to the Polimec Websites. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made. Personal data will be disclosed to Twitter and therefore, in particular, to the USA.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

Access to and Sharing of Personal Data

Within Polimec, access to your data will be provided to those people that require it to fulfil our contractual and statutory obligations.

Polimec does not sell, transfer or market your personal data to third parties. However, we may disclose your personal data to third parties and/or certain types of persons in charge, or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications, consulting, and advisory agencies, third parties involved in hosting or organizing events or seminars) appointed, if necessary, as data processors by us.

Transfer of Data abroad

If necessary or useful for us to provide our services or for other purposes defined in this privacy policy, we may share your personal information collected in the course of providing services with third parties (such as advisors, related parties, courts, authorities, counterparties and other persons) in Switzerland, the EU or other countries if required or useful for providing our services.

We are entitled to transfer your personal data to third parties (contracted service providers) abroad for the purpose of the data processing described in this privacy policy. These are bound to protect data to the same extent as we are. If the level of data protection in a country does not correspond to that in Switzerland or Europe, we will contractually ensure that the protection of your personal data corresponds to that in Switzerland or the EU/ EEA at all times.

Period for Personal Data Storage

We only store personal data for as long as is necessary for the above described uses and further processing in the context of our legitimate interest. Contract data is stored by us for a longer period of time, as this is prescribed by statutory obligations. Obligations to store data may arise out of accounting law, civil law and tax law. According to these laws, business communication, concluded contracts and accounting vouchers must be stored for up to 10 years. If we no longer need this data to carry out the services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.

Non-Existence of Automated Decision-Making

As a responsible controller, we do not use automatic decision-making or profiling.

Changes in the Privacy Policy

We reserve the right to update and change this privacy policy from time to time in order to reflect any changes to the way in which we process your personal information or changing legal requirements. Any changes we may make to our privacy policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our privacy policy. The privacy policy was last updated on 9. February 2023.