Privacy Policy of BREIL PUR SA
Version dated September 1, 2023
In this Privacy Policy, we, BREIL PUR SA (hereinafter referred to as Breilpur, we, or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; specific matters may be governed by other privacy policies [or general terms and conditions, participation terms, and similar documents]. Personal data refers to any information relating to an identified or identifiable individual.
If you provide us with personal data of other individuals (e.g., family members, data of colleagues), please ensure that these individuals are aware of this Privacy Policy and only provide us with their personal data if you are authorized to do so, and if the provided personal data is accurate.
This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DSG”), and the revised Swiss Data Protection Act (“revDSG”). However, the applicability of these laws depends on the specific circumstances.
1. Data Controller
Responsible for the data processing described here is BREIL PUR SA. If you have data protection concerns, you can contact us at the following address:
BREIL PUR SA
Via Plaun 26,
7163 Danis/Brigels CH
2. Collection and Processing of Personal Data
We primarily process personal data obtained within the scope of our business relationships with our customers and other business partners, as provided by them and other individuals involved, or as collected during the operation of our websites, apps, and other applications from their users.
To the extent permitted by law, we may also extract certain data from publicly accessible sources (e.g., debt registers, land registers, commercial registers, press, internet) or receive such data from other companies, authorities, and third parties. In addition to the data you provide directly to us, the categories of personal data we receive from third parties about you include information from public registers, information we learn in connection with official and court proceedings, information related to your professional functions and activities (to enable us, for example, to conduct and process business with your employer with your assistance), information about you in correspondence and discussions with third parties, credit information (when we conduct business with you personally), information about you provided by individuals in your circle (family, advisors, legal representatives, etc.) to allow us to conclude or process contracts with you or involving you (e.g., references, delivery addresses, authorizations, compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurers, distribution and other contractual partners for us to avail or provide services through you (e.g., payments made, purchases made), information from media and the internet about your person (as far as relevant in the specific case, e.g., in the context of a job application, press coverage, marketing/sales, etc.), your addresses, and possibly interests and other socio-demographic data (for marketing), data related to the use of the website (e.g., IP address, MAC address of smartphone or computer, device and settings information, cookies, date and time of visit, accessed pages and content, used features, referring website, location data).
3. Purposes of Data Processing and Legal Bases
We primarily use the personal data we collect to enter into and fulfill contracts with our customers and business partners, particularly within the scope of communication and marketing services with our customers and the procurement of products and services from our suppliers and subcontractors. We also use personal data to comply with our legal obligations in both domestic and international contexts. If you are acting on behalf of such a customer or business partner, your personal data may also be affected in this capacity.
Furthermore, we process personal data from you and other individuals, to the extent permitted and deemed appropriate, for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:
– Offering and improving our products, services, and websites, apps, and other platforms on which we are present;
– Communication with third parties and handling their inquiries (e.g., job applications, media inquiries);
– Examination and optimization of procedures for needs analysis for direct customer approach and collection of personal data from publicly accessible sources for customer acquisition;
– Advertising and marketing (including events), unless you have objected to the use of your data (if we send you advertising as an existing customer, you can object to it at any time, and we will then place you on a suppression list to prevent further marketing communications);
– Market and opinion research, media monitoring;
– Enforcement of legal claims and defense in connection with legal disputes and administrative proceedings;
– Prevention and investigation of crimes and other misconduct (e.g., conducting internal investigations, data analysis for fraud prevention);
– Ensuring the operation of our business, especially IT, our websites, apps, and other platforms;
– Video surveillance to protect property rights and other measures for IT, building, and facility security, and the protection of our employees and other individuals and our assets (e.g., access controls, visitor logs, network and email scanners, phone recordings);
– Purchase and sale of business areas, companies, or parts of companies, and other corporate transactions, including the transfer of personal data, as well as measures for business management and compliance with legal and regulatory obligations, and internal regulations of Breil Pur SA
If you have provided us with consent to process your personal data for specific purposes (e.g., when signing up to receive newsletters or undergoing a background check), we will process your personal data in accordance with and based on that consent, provided that we do not have another legal basis and one is required. Consent given can be revoked at any time, but this will not affect data processing that has already occurred.
4. Cookies/Tracking and Other Technologies Related to the Use of Our Website
We typically use “cookies” and similar technologies on our websites, which allow your browser or device to be identified. A cookie is a small file sent to your computer or mobile device automatically by your web browser when you visit our website. When you revisit this website, we can recognize you even if we don’t know who you are. In addition to session cookies, which are used only during a session and deleted after your website visit (“session cookies”), cookies can also be used to store user settings and other information for a specific period (e.g., two years) (“persistent cookies”). However, you can configure your browser to reject cookies, store them only for a session, or delete them prematurely. Most browsers are set to accept cookies. We use persistent cookies [to store user settings (e.g., language, auto-login),][to better understand how you use our offerings and content,][and][to display customized offers and advertising to you (which can also occur on websites of other companies; however, they will not know who you are from us, as they only see that the same user who was on our website visited a specific page on their website)]. [Some of the cookies are set by us, and some are set by contract partners we collaborate with.] Blocking cookies may result in certain functionalities (e.g., language selection, shopping cart, order processes) no longer working.
In our newsletters and other marketing emails, we sometimes include visible and invisible image elements, to the extent permitted, through which we can determine whether and when you opened the email from our servers. This allows us to measure and better understand how you use our offerings and tailor them to you. You can block this in your email program; most are preset to allow this.
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 to do so, you must adjust your browser or email program accordingly.
We occasionally use Google Analytics or similar services on our websites. This is a third-party service that may be located in any country worldwide (in the case of Google Analytics, it is Google Ireland, based in Ireland, relying on Google LLC, based in the USA, as a data processor (both “Google”), www.google.com), which allows us to measure and evaluate the use of the website (non-personalized). This service also uses persistent cookies set by the service provider. We have configured the service to shorten the IP addresses of visitors from Europe before forwarding them to the USA, making them untraceable. We have disabled the “data sharing” and “signals” settings. Although we believe that the information we share with Google is not personal data for Google, it is possible that Google may use this data to draw conclusions about the identity of visitors, create personal profiles, and link this data to the Google accounts of these individuals. If you have registered with the service provider yourself, the service provider knows you. The processing of your personal data by the service provider is then the responsibility of the service provider, in accordance with its privacy policy. The service provider only informs us about how our respective website is used (no information about you personally).
We also use so-called social network plugins such as Facebook, , YouTube, or Instagram on our websites. This is visible to you (typically through corresponding icons). 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 you are and can use this information for their purposes. The processing of your personal data is then the responsibility of the operator in accordance with its privacy policy. We do not receive any information about you from them.
5. Data Disclosure and International Data Transfers
In the course of our business activities and for the purposes outlined in section 3, to the extent permitted and deemed appropriate, we also disclose data to third parties, whether because they process it on our behalf or because they want to use it for their own purposes. This involves, in particular, the following entities:
– Service providers, including data processors (such as IT providers);
– Dealers, suppliers, subcontractors, and other business partners;
– Customers;
– Domestic and foreign authorities, government agencies, or courts;
– Media;
– The public, including visitors to websites and social media;
– Competitors, industry organizations, associations, organizations, and other bodies;
– Acquirers or potential acquirers of business areas, companies, or other parts of BREIL PUR SA;
– Other parties in potential or actual legal proceedings;
– All collectively referred to as recipients.
These recipients may be located within the country or anywhere in the world. You should be aware that your data may be transferred to all countries where BREIL PUR SA is represented, as well as to other European countries and the USA, where the service providers we use are located.
If a recipient is located in a country without adequate legal data protection, we contractually obligate the recipient to comply with applicable data protection regulations (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 data protection, and we cannot rely on an exemption provision. An exemption may apply, especially in the case of foreign legal proceedings, but also in cases of overriding public interests or if contract execution requires such disclosure, if you have consented, or if it involves data that you have made generally accessible and to which you have not objected to processing.
6. Duration of Personal Data Retention
We process and store your personal data for as long as necessary to fulfill our contractual and legal obligations or for the purposes pursued with the processing, i.e., for the duration of the entire business relationship (from initiation, execution to termination of a contract) and beyond, in accordance with legal retention and documentation requirements. It is possible that personal data may be retained for the period during which claims can be asserted against our company and as far as we are otherwise legally obliged or have legitimate business interests (e.g., for evidence and documentation purposes). Once your personal data is no longer required for the purposes mentioned above, it will generally be deleted or anonymized, to the extent possible. For operational data (e.g., system logs), 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 IT and network security solutions, access controls, and encryption of data carriers.
8. Obligation to Provide Personal Data
In the context of our business relationship, you must provide the personal data necessary for the initiation and execution of a business relationship and the fulfillment of 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 enter into a contract with you (or the entity or person you represent) or process it. The website also cannot be used if certain information necessary for data traffic security (such as an IP address) is not disclosed.
9. Profiling
We process your personal data partially automatically with the aim of assessing certain personal aspects (profiling). We use profiling, in particular, to provide you with targeted information and advice on products. We use evaluation tools that allow us to engage in needs-based communication and advertising, including market and opinion research.
10. Rights of the Data Subject
Under applicable data protection law and as provided therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing, and the right to object to our data processing, especially for purposes of direct marketing, profiling conducted for direct advertising, and other legitimate interests in processing, as well as the right to receive certain personal data for transfer to another entity (so-called data portability). Please note, however, that we reserve the right to assert the statutory restrictions on our part, such as if we are obligated to retain or process certain data, have a predominant interest (as far as we may rely on it), or need them to assert claims. If costs are incurred for you, we will inform you in advance. We have already informed you about the possibility of revoking your consent in section 3. Please note that the exercise of these rights may conflict with contractual agreements and may have consequences such as the premature termination of a contract or cost consequences. In such cases, we will inform you in advance unless this is already contractually regulated.
To exercise such rights, it generally requires you to clearly prove your identity (e.g., by providing a copy of your identity card, where your identity is otherwise unclear or cannot be verified). To assert your rights, you can contact us at the address provided in section 1.
Every data subject also has the right to enforce their claims in court or to lodge 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 amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If this privacy policy is part of an agreement with you, we will inform you of the changes by email or through other suitable means in the event of an update.
BREIL PUR SA, breilpur.ch
