Effective August, 2023
1 General Information and Scope
2 Controller and Data Protection Officer
Responsible for data processing of affiliates of the Mitrelli Group:
Mitrelli Group Services AG
If you have any questions regarding the processing of your personal data, please contact us at data-privacy@Mitrelli.com or by post to Mitrelli Group, Data Protection Officer, Zuercherstrasse 239, 8500 Frauenfeld.
3 Which personal data do we process?
We process personal data that you supply to us. “Personal Data” is any information which could, alone or together with other information, personally identify you or otherwise be reasonably linked or connected to you.
If necessary for the provision of our services, we also process Personal Data that we have obtained from publicly accessible sources (e.g. public databases, Internet and the press) or from third parties in a lawful manner (e.g. cooperation partners, insurers, investors, financial service providers, lawyers, experts, suppliers).
We may process various types of Personal Data, including:
- Personal details (e.g. name, address and other contact details, date of birth, language preferences, application and usage data, financial information and creditworthiness data).
- Data on customer and/or supplier activities (e.g. contract data, customer and/or supplier contacts, session data relating to visits to our website, IP addresses).
- Other data which we are legally obliged or entitled to collect and process and which we need for your authentication, identification or to check the data we collect (e.g. identity of contractual partners, origin of assets, payment instructions).
If particularly sensitive Personal Data is required to conclude or perform a contract, we will always obtain your consent.
In addition, and without derogating from the above, you hereby give your consent that any use of the Site, which requires the entry of Personal Data (as defined above) and/or other basic details, whether on your own initiative or at our initiative, will be documented by us and/or anyone on our behalf.
4 For which purposes and on which legal basis do we process your Personal Data?
We use your Personal Data in accordance with legal requirements for the following purposes:
- As part of the conclusion and performance of a contract:
g. provision of advice and customer support, risk assessment, credit checks, contract management and amendment, collection, surveys on customer satisfaction in connection with the contractual services.
- To safeguard our legitimate interests or those of third parties:
g. detection of fraudulent acts, maintain and evaluate customer relationships / customer behaviour, newsletters, market and opinion surveys, research and development.
- With your consent:
in certain cases, we need your consent to process your data, e.g. when processing particularly sensitive Personal Data.
- Due to legal obligations:
we are subject to various legal requirements (e.g. confidentiality obligations, Anti-Corruption laws and regulations, tax and accounting obligations, retention requirements).
Without derogating from the above and to the extent permitted under any applicable law, any information and/or data and/or content that will be transmitted by you or is automatically collected by us while using the Site (such as information from cookies or similar technologies) will be considered as open information to which no confidentiality applies, and we and/or anyone on our behalf will be entitled to use such information, for the purposes defined above.
5 Which other persons will we make your Personal Data available to?
We do not pass your Personal Data on to unauthorised third parties. Only employees have access to the data they require for the purpose of fulfilling contractual and / or legal obligations. To be able to provide our services, it is necessary in certain circumstances for us to pass on your data both within and outside the company. Depending on their purpose, these include, for example, affiliates of Mitrelli Group and third parties acting on our behalf (e.g., IT services, logistics, printing services, marketing). All third parties integrated into our business processes process your Personal Data on our behalf and only as we are permitted to do so ourselves. They are carefully checked by us with regard to data protection and data security and are committed to secrecy and compliance with data protection regulations, taking into account the applicable statutory data protection provisions.
For the avoidance of any doubt, we can share Personal Data to third parties in the following circumstances:
- To comply with the law.We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
- In an emergency.We may share information if we believe it is necessary to prevent imminent and serious bodily harm to a person.
- To enforce our policies and rights.We may share information if we believe your actions are inconsistent with the Terms, or to protect the rights, property, and safety of Mitrelli and others.
- With affiliates of Mitrelli Group.We may share information between and among Mitrelli Group, and any of its parents, affiliates, subsidiaries, and other companies under common control and ownership.
- With your consent.We may share information about you with your consent or at your direction.
- Aggregated or de-identified information.We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you.
Furthermore, we must disclose your Personal Data to state authorities (e.g. authorities, social insurance companies and courts), insofar as we are legally obliged to do so.
6 How do we use automated individual decision-making and profiling?
We are currently not using automated individual decision-making processes and do not compile profiles with any Personal Data.
7 Where will your Personal Data be processed?
We have offices in Switzerland and other jurisdictions. The IT-infrastructure used to process and store Personal Data is located in Switzerland. However, we may transfer Personal Data to affiliates and third parties acting on our behalf. Personal Data will in such cases only be used and processed according to the intended purpose as defined above and will only be transferred to other states if there is an adequate level of data protection regulation comparable to that in Switzerland, or if the recipient contractually guarantees to us an equivalent level of protection of the Personal Data.
When you visit a website, it can access or save information from your browser, usually in the form of cookies. This may be information about you, your settings or your device, and it is mostly used to ensure that the website functions as expected. This information generally does not identify you directly but is used to offer you a more personalised web experience.
We may partner with third-party analytics providers to better understand your use of the Site. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. For example: We may use analytics partners to help analyse usage and traffic for our Site, number of visitors to the Site, etc.
10 How is your Personal Data protected?
We take certain measures to help protect your information from being lost, stolen, or otherwise misused. We also enforce technical and administrative access controls to limit which of our employees have access to non-public Personal Data.
11 How long will your Personal Data be stored for?
We proceses and/or store the information we collect for as long as it is necessary for the purpose(s) for which we have originally collected it and for as long as we are obliged to do so by the provisions of the applicable law. We may retain certain information for legitimate business purposes or as required by law.
12 What rights do you have in connection with your Personal Data?
You have the right to obtain information about your Personal Data, to have it corrected or erased, to object to it or to restrict its processing and – where applicable – a right to data portability and a right to lodge complaints with the responsible data protection supervisory authority.
If you would like to exercise these rights, please contact our Data Protection Officer. Please note that the exercise of these rights may prevent us from entering into or performing the contract or from offering further services. We can – under certain circumstances and in accordance with the applicable law – refuse to provide such information, only comply with your request in part, or refuse to correct or erase your Personal Data.
13 Changes to This Policy
We may change this Policy from time to time, at our sole discretion. This Policy was last amended in July 2022.
Mitrelli Group Services AG