We are committed to handling your personal data responsibly; this is a priority for us. When we (or third parties appointed by us) collect and process personal data, we comply with the provisions of the Federal Act on Data Protection. We also comply with the provisions of the EU-GDPR, insofar as we are legally required to do so.
- How you can contact us with any questions.
- What personal data we will collect from you and process, and for what purpose.
- What the legal basis is for our data processing.
- To whom we disclose your personal data.
- How we protect your data.
- What cookies/tracking and other technologies we use.
- For how long we process your personal data.
- What rights you have with respect to your personal data.
1. Our contact details
Rue des Croix 43
2014 Bôle (Milvignes)
Point of contact for data privacy questions
Kowema Group data protection centre
EU data protection representative
Our data protection representative in the EU pursuant to Article 27 GDPR is:
2. What data we collect and for what purpose
2.1 Website visits (creation of log files) and other electronic resources
Every time a user visits our website, our web server automatically records data and information from the computer accessing the services. This includes, in particular, information on the browser type and the version being used, the user’s operating system, the user’s internet service provider, the referrer URL (website from which the user’s system accesses the Kowema website), websites that are accessed from the user’s system via the Kowema website, and the user’s IP address, access date and time, and client file request (file name and URL). This data is saved in our sys-tem’s log files (or those of third parties) together with other data, and is only used for the purposes of statistical analysis.
If you use other electronic resources, such as our wifi network or app(s), we collect specific tech-nical data. This includes the logs in which we record the use of our systems (log data). We may sometimes also assign a unique identification number (ID) to your device (tablet, PC, smartphone, etc.).
We use this data to ensure a smooth connection setup, ease of use of the website and other elec-tronic resources, evaluation of system security and stability, and for other administrative purpos-es. In general, this data does not enable us to draw any conclusions about your identity. However, it may be connected to other data categories – and therefore to you as an individual – in the con-text of user accounts and registrations.
2.2 Marketing and newsletter
We may use your name and your postal or e-mail address(es) to provide our services and send out newsletters, event information/invitations, publications and the like. The newsletter may be sent via external software partners that are based abroad. By registering, you consent to our transferring your data to our software partners, monitoring your open and click-through rates and to our contacting you directly in certain cases. We will obtain your consent first where required by law, unless we have obtained your contact details in the context of our services and you have not explicitly opted out of receiving marketing materials of this kind. If you no longer wish to receive these communications from us, you can unsubscribe at any time by using the contact details pro-vided. An unsubscribe link is also included at the bottom of every e-mail.
2.3 Contact via e-mail and other communication channels
We offer you the option of contacting us via the e-mail address(es) published on our website and via other digital communication channels. In such cases we store the transmitted data.
Some digital communication channels are operated by companies that are based abroad, e.g. in the US. By using these digital communication channels, you consent to your data being transmit-ted abroad (e.g. to the US), to your open and click-through rates being monitored and to our con-tacting you directly.
Some digital communication traffic (e.g. e-mail) is unencrypted and unsecured, and you assume the associated risk.
2.4 Contact forms
Our website offers you the option of getting in touch with us and our experts so that we can con-tact you and respond to your query. The data you enter in this/these form(s) is sent to us using
SMTP-SSL encryption and stored. By using the contact form to get in touch with us, you consent to our processing your data. You also confirm that you have read and understood our privacy pol-icy.
2.6 In the context of business relationships
We process data that we obtain from our clients, other business partners and other individuals involved in the context of our business relationships with them. This includes, in particular, contact details such as salutation, first name, last name, sex, date of birth, address, e-mail address, phone number and other contact details, and communication data such as content exchanged in e-mails, other written correspondence, phone calls, video conferences, etc., and information about the form, time and place of the communication.
To the extent permitted, we also obtain data from public sources (e.g. commercial registers, me-dia, internet, social media, etc.). In addition to data that you give to us directly, this includes data about you that we obtain from third parties (authorities, credit information, banks, address dealers and other third parties), in particular: information from public registers; in connection with official and court proceedings; in connection with your professional roles and activities; information about you in correspondence and conversations with third parties; information given to us by people you are in contact with (e.g. family, advisors, legal representatives or employers) so that we can con-clude or perform contracts with you or with your involvement (e.g. references, powers of attor-ney); your address and any interests and other sociodemographic data (for marketing purposes).
3. Legal basis for data processing
3.1 In the context of our services and to fulfil contractual obligations
Data is processed for the purposes of providing our services to customers, including pre-contractual measures and post-contractual support, and for the purposes of meeting contractual obligations with other contractual partners. The data collected is used for the full performance of our services, including any later warranty claims, technical administration, etc. Please refer to the relevant contractual documents and terms and conditions for further details on the purposes of data processing.
3.2 In the context of a balance of interests
To the extent necessary and permissible, we process your data beyond the actual fulfilment of the contract to safeguard our legitimate interests or those of third parties. This includes:
– Consulting and exchanging data with information centres and other third parties (e.g. debt col-lection registers)
– Checking and optimising needs analysis processes for the purpose of direct customer contact and collecting personal data from public sources for the purpose of customer acquisition
– Carrying out advertising or market and opinion research, unless you have objected to the use of your data
– Asserting legal claims and defending legal disputes
– Safeguarding IT security and IT operations, including video monitoring to protect property rights and other measures to ensure IT, building and system security, the protection of our employees and other individuals and assets belonging or entrusted to us, such as access controls, visitor lists, network and mail scanners and telephone recordings
– Preventing or investigating criminal acts
– Implementing measures to manage the business and develop services, products and the web-site
– Purchasing and selling business divisions, companies or parts of companies and other corpo-rate transactions, and the related transfer of data and business control measures.
3.3 Based on your consent
Provided that you have given us consent to process your personal data for specific purposes, the processing is lawful on the basis of your consent. Any consent given can be revoked at any time. Any revocation of consent does not affect the lawfulness of data processed up until the time of revocation.
3.4 Based on legal regulations or in the public interest
We are also subject to various legal obligations requiring us to process your data.
4. Passing on data, including transfer abroad
- Group companies according to this overview :
Subsidiaries - KOWEMA
Subgroup Ceramaret Companies
The Group companies may process your data (i) on our behalf, (ii) jointly with us, or (iii) independently. We may also disclose particularly sensitive data to our Group companies
- Data processors, such as service providers evaluating use of the website (for marketing purposes), IT service providers (data management, data storage, technical support, newsletter dispatch, etc.), and service providers in the areas of recruitment, talent management, HR and other services
- External business partners (e.g. traders, suppliers, subcontractors, banks, debt collection agencies) and experts in connection with the contractual service
- Competitors, industry organisations, associations and other bodies
- Acquirers and parties interested in acquiring business divisions, companies and other parts of the Kowema Group
- Domestic and foreign authorities, government offices and courts
- Other parties in potential and actual legal proceedings
We do not only process personal data in Switzerland. Your data may be processed in the European Union or in any country in the world (including the US). If the level of data protection in the third-party data processor’s country is considered inadequate for Swiss standards (including the US), we grant suitable data protection by means of appropriate guarantees (e.g. standard contractual clauses) except where there are legal exceptions (e.g. your consent), where the recipient is already subject to a legally recognised framework (e.g. Swiss-US Data Privacy Framework) for the assurance of data protection, or where we can rely on an exemption. Such contractual precautions (guarantees) can partially offset weaker or lacking legal protection, but cannot entirely exclude all risks (e.g. of state access abroad).
Please also note that data exchanged via the internet is often sent via third countries. Your data may therefore be sent abroad even if the sender and recipient are located in the same country.
5. Data security
We use appropriate technical and organisational measures as part of our systems to protect your data against loss, destruction, modification and unauthorised access by third parties while we are storing it.
Technical security measures include encryption (including login data) and pseudonymisation of data, logging, access restrictions and saving of backup copies.
We also take our own in-house data protection very seriously. Our employees and the service providers appointed by us are obliged to uphold confidentiality and comply with data protection laws. Our data processors are also obliged to take appropriate technical and organisational security measures. In addition, they are only granted access to personal data to the extent necessary.
Our security measures are continuously adapted in line with new technological developments, but we cannot guarantee absolute protection.
6. Cookies/tracking and other technologies
We use session cookies to identify that you have already visited certain pages on our website. These are automatically deleted when you leave the site. We also use temporary cookies in order to improve the user experience. These are saved on your device for a defined period of time. If you visit our website again to use our services, these cookies will automatically detect that you have visited us in the past and will reapply your previous entries and settings so that you do not have to enter them again.
Cookies can be deactivated or removed using tools that are available in most commercial brows-ers. The method of managing and deleting cookies depends on the browser you are using. You can find information on this in the Help menu of your browser (usually under the heading “Priva-cy”). If cookies and pixels are deactivated for our website, some of its functions may not work properly.
To the extent permitted, some of our marketing e-mails also include visible and invisible picture elements (including pixels). By retrieving these from our servers we can ascertain whether you have opened the e-mail – and, if so, when – so that we can monitor and better understand how you use our services and tailor them more effectively to you. You can block this in your e-mail client.
By using our website and agreeing to receive marketing e-mails, you consent to the use of these technologies. If you do not wish to give your consent, you must adjust the settings in your browser and/or e-mail client accordingly.
Please read the webpage : Cookie Notice
The information generated by these performance cookies about use of the website (including the user’s IP address) is transmitted to and stored on Google’s servers in the USA. We have config-ured these services so that the IP addresses of users of Google’s websites within Europe are truncated before being sent to the US and therefore cannot be traced. We have deactivated the “data sharing” and “signals” settings. Google provides us with reports and in this sense can be seen as our data processor. However, Google also processes some data for its own purposes. In some circumstances, Google can use the data collected to draw conclusions about the identity of website visitors and create personal profiles and connect the data obtained with any available user accounts for these individuals. Google may also pass this information on to third parties if this is a statutory requirement or if third parties process the data on Google’s behalf. If you agree to the use of Google, you explicitly consent to such processing, which also includes the transfer of per-sonal data to the US and other countries. Further information on data protection at Google Analytics can be found here
If you do not wish your visit to our website to be recorded by analytics services, you can deacti-vate performance cookies in the cookie settings, for example.
6.3 Google Maps
Our website uses Google Inc.’s Google Maps product. By using this website, you consent to the recording, processing and use of the data automatically collected by Google Inc., its representa-tives and third parties. The Terms of Service of Google Maps can be found here: https://maps.google.com/help/terms_maps/
6.4 Social media
When you visit our social media sites, data (e.g. about your user behaviour) may also be transmit-ted directly to the relevant provider or collected by them and processed together with other data that is already available to them (e.g. for marketing and market research purposes and to person-alise the platform content). You can find more information about how social network providers process data, in which countries they process your data, and your rights in the data privacy poli-cies of the relevant social networks.
7. Period during which your personal data is processed
We will only process your data for as long as is necessary for the relevant purpose and to meet our contractual and legal duties, including statutory retention requirements (generally 10 years), or if you have given us your consent to do so. We will continue to process your data if we have a legitimate interest in storing it. In particular, this might be the case if we require personal data to enforce or defend against claims, for archiving purposes, or to ensure IT security.
8. Your rights
You can choose between several options when using this website. You may choose not to enter any data by not completing any forms or data fields on our website, blocking cookies and not using any of the personalised services we offer.
If you do decide to enter personal data or provide this to us in the context of our business relationship, you have the right, in specific circumstances and to the extent provided for by law, to information, data rectification, data deletion, restriction of data processing, withdrawal of your consent and, if applicable, data portability and objection. However, this is not an absolute right. We reserve the right to enforce the statutory restrictions and will inform you of this accordingly.
If you wish to exercise your rights against us, please provide corresponding ID.
Every data subject also has the right to assert their claims in court or submit a complaint to the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). You can find a list of European data protection authorities here.
9. Right of modification
Last update: October 2023