At Ansam Group, we recognize the need to protect your personal data and to ensure transparency in our processing activities.
- The Data of our clients (the "Clients"), the clients of our Clients as well as the end-users of our Clients (the "End-Clients") which we collect while performing the services provided by Ansam Group (the "Services");
- The Data of our employees, persons applying for a job with one of the entities of Ansam Group, and other Business Partners;
- The Data of the persons consulting our websites www.ansam.group, www.ixion-group.ch, www.nj-info.ch and www.filaos.ch (the "Websites"); and
- The Websites.
We may also have separate documents that describe how we process Data in specific circumstances.
"Business Partner" means all service providers, subcontractors, vendors, agents, advisors, fiduciaries, accountants, auditors, consultants or other persons outside our entities with whom we interact in the course of our business.
"Data" means any data and personal information that will directly or indirectly identify you, including your identity (name, gender, date of birth, age), contact details (e-mail address, postal address, telephone number or other contact information), official documents (passport, ID, AVS/AHV number), family life (marital status, number of dependent children), bank details (bank account, PostFinance, etc.), preferences, Internet Protocol ("IP") address, and location data.
2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
Ansam Holding SA is responsible for the processing of your Data. You will find our contact information below in Section 14. However, this only applies to our own activities and not to those of third parties.
We may also act as a processor for our affiliated companies, who are then deemed to act as data controllers.
By using the Website or our Services, you consent to the collection, use and processing of the Data as described herein.
4. HOW DO WE COLLECT YOUR DATA?
We collect the Data that you provide directly to us.
To the extent permitted, we may also collect Data directly from public authorities or public sources, such as public or commercial registers.
4.1 Information we automatically collect
We collect certain information from the browser you use to come to our Websites, such as your IP address, device identifier, location data browser type and language, access times, the Uniform Resource Locator ("URL") of the website that referred you to our Websites and the URL to which you browse away from our Website if you click on a link on our Website.
5. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
We process your Data for specific purposes and only to the extent that it is relevant to achieving those purposes. In particular, we process your Data for the following purposes:
- To provide our Services.
- For the administrative management of our activities. We process Data that is necessary for the administrative management of our business.
- If you apply for a job with us. If you apply for a job with us, we will process your Data exclusively for the purpose of evaluating your application for the potential forming of an employment relationship, including for purposes of assessing your abilities and qualifications and conducting reference checks, to the extent permitted by Swiss law.
All information you provide to us must be accurate, complete and not misleading. Providing inaccurate, incomplete or misleading Data may, to the extent permitted by law, result in your application being rejected or in disciplinary action, including your immediate dismissal if you have been hired.
The personal details of candidates who have not been hired are deleted at the end of the recruitment process within a one-year period from the end of the recruitment process. If an employment relationship is formed as a result of your application, your Data will be entered into the HR file and subsequently processed in accordance with our internal rules.
- If you visit our Websites or digital platforms. If you visit our Websites, web portals or other digital platforms operated by Ansam Group, we process your Data to provide you with the requested functionality, to establish a connection with your device over the Internet, to identify you when you use our Websites, to manage the stability and security of those Websites.
- To comply with our legal obligations. We may also process your Data if we are legally obliged to do so, or based on other legitimate interests.
- If we have obtained your consent. In addition to the above, we may process your Data if we have obtained your prior consent. The consent you have given may be withdrawn at any time, but this does not affect the Data processed prior to the withdrawal.
We also process your Data to :
- Better understand our Clients and End-Clients as well as online visitors, including profiling based on interests and interactions with our Websites, web portals or other digital platforms;
- Diagnose problems with our Websites and Services, and to administer our Websites, web portals or other digital platforms;
- Contact you and provide you with information about the Services and our Websites, web portals or other digital platforms;
- Facilitate your use of our Websites, web portals or other digital platforms and Services including Ansam Group's newsgroups and blogs;
- Customize, analyse and improve our Websites, web portals or other digital platforms and Services (including the content and advertisements to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
- Meet our contractual obligations and enforce our conditions of Services, Websites, web portals or other digital platforms' terms and separate contracts with you, if any;
- Prevent fraud, software piracy, and other prohibited or illegal activities;
- Protect your security and integrity as well as Ansam Group's; or
- Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.
5.1 Legal basis for Processing
In general, we collect and process your Data on one or more of the following bases:
- For compliance with a contractual obligation. We will advise you upon collection whether the provision of any of your Data is mandatory and of the possible consequences if you do not provide us with such Data.
- For compliance with Ansam Group's legal obligations where other laws require the processing of your Data.
- Ansam Group's legitimate interests which include the provision of the Websites, web portals or other digital platforms and/or relevant Services, and/or the carrying out of marketing and profiling activities, provided always that our legitimate interests are not outweighed by any prejudice or harm your rights and freedoms.
If you have any questions or need more information concerning the legal basis on which we collect your Data, please contact us at firstname.lastname@example.org.
5.2 How long do We store your Data?
We destroy or anonymize the Data as soon as it is no longer required for the purposes set out in Section 6. This period varies depending on the type of Data concerned and the applicable legal requirements.
If you withdraw your consent for the processing on certain Data, we will delete them within 30 days or keep them but on an anonymous basis.
6. HOW DO WE STORE YOUR DATA?
We use appropriate technical and organizational security measures to protect your personal data stored by us against loss and unlawful processing, namely unauthorized access by third parties. Our security measures are continuously adapted in line with technological developments. However, security risks cannot be completely ruled out in general; residual risks are unavoidable.
Ansam Group takes all reasonable steps to protect your Data from misuse, interference and loss, as well as unauthorized access, modification or disclosure. The ways we do this include:
- In some cases, using encryption when collecting or transferring sensitive information;
- Having in place technical and organizational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and Services;
- Limiting physical access to our premises (offices and data centers);
- Limiting access to the information we collect about you;
- Ensuring that we have appropriate security safeguards to keep Data secure; and
- Where required by law, destroying or de-identifying Data.
We encourage you to keep any passwords you use confidential and to be careful to avoid "phishing" scams where someone may send you an email that appears to be from Ansam Group asking for your personal information. However, despite our efforts, no security controls are 100% effective and Ansam Group cannot ensure or warrant the security of your Data.
7. HOW DO WE SHARE YOUR DATA?
We only disclose your Data to third parties if there is a legal obligation or authorization to do so (e.g. to authorities in connection with law enforcement, fraud prevention or other legal action), if you expressly consent to it, if disclosure is in your interest or if this is necessary to enforce our rights, in particular claims arising from a contractual relationship.
We will only pass on your Data to third parties insofar as this is necessary for the performance of the Services, for example to our Business Partners. In addition, we will transfer your Data to external Business Partners in order to protect our economic, legal and ideal interests (e.g. for marketing purposes or to improve our online offering).
We also disclose your Data if we intend to sell Ansam Group or merge Ansam Group with another company or if we sell the Websites or a business unit or all or a substantial portion of our assets to a third party.
8. DATA TRANSFER ABROAD
For example, for software tools, we use the services of several software companies. Data collected in connection with the use of these software tools may be transmitted to servers located in the following countries: Switzerland, the countries of the European Union (incl. France, Belgium, Germany), the United States (e.g. Microsoft, Adobe, Apple, 10Zig), Cyprus (3CX), Russia (Kaspersky), Japan (e.g. TrendMicro) and China (e.g. Lenovo, Yealink).
Many countries outside of Switzerland or the EU and the EEA currently do not have laws that ensure an adequate level of data protection under the Federal Act on Data Protection (FADP) such as the United States, Cyprus, Russian, Japan and China.
If a recipient is located in a country without adequate data protection, we may contractually obligate such recipient to comply with an adequate level of data protection. Exceptions may apply in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of the Services requires such disclosure, if you have consented or if it is a matter of Data made generally accessible by you, the processing of which you have not objected.
Also, we cannot require contractual obligations from Business Partners with whom we do not negotiate specific contracts on a one-to-one basis but have to accept the application of their general terms and conditions, such as Google, Microsoft, Kaspersky, Apple, etc. By using our Services, you expressly consent to the transfer of your Data abroad, including to those countries which do not offer the adequate level of protection foreseen by the FADP.
Please note that within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce.
9. YOUR DATA PROTECTION RIGHTS
You have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law:
- Access. You have the right to request information about how we process your Data and to obtain a copy thereof by sending a request to email@example.com. We may charge you a fee for this Service;
- Rectification. You have the right to request the rectification of inaccurate Data about you and for any incomplete Data about you to be completed;
- Objection. You have the right to object to the processing of your Data, which is based on our legitimate interests (as described above);
- Erasure. You have the right to request the erasure of your Data (subject to certain conditions);
- Restriction. You have the right to ask us to restrict our processing of your Data, so that we no longer process that information until the restriction is lifted;
- Portability. You have the right to receive your Data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organization under certain conditions.
In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Data infringes applicable data protection law, which is in Switzerland the Federal Data Protection and Information Commissioner.
10. RESPONSABILITY OF ANSAM GROUP REGARDING YOUR DATA
ANSAM GROUP CANNOT BE HELD RESPONSIBLE FOR ANY INTERRUPTION OF SERVICES OR POSSIBLE UNAVAILABILITY OF SERVICES. ANSAM GROUP IS NOT ABLE TO GUARANTEE THE CONTINUITY OF SERVICES PERFORMED REMOTELY VIA THE INTERNET, WHICH YOU ACKNOWLEDGE AND AGREE TO. ANSAM GROUP RESERVES THE RIGHT IN CERTAIN CASES OF FORCE MAJEURE (E.G. INTRUSION ON ITS SERVERS, MISUSE OF SERVICES BY USERS, REQUEST FROM AN AUTHORITY, ETC.) TO SUSPEND THE SERVICES AND, IN PARTICULAR, ACCESS TO YOUR FILES.
ANSAM GROUP UNDERTAKES COMMERCIALLY REASONABLE EFFORTS TO ENSURE THE SECURITY OF THE DATA STORED ON THE SERVERS. HOWEVER, IT CANNOT GUARANTEE THAT THE DATA STORED WILL NOT BE MODIFIED/ALTERED BY A THIRD PARTY (VIRUS, DATA THEFT, ACCOUNT HACKING, ETC.).
ANSAM GROUP SHALL NOT BE LIABLE (WITHIN THE MEANING OF ART. 100 AND 101 OF THE SWISS CODE OF OBLIGATIONS) FOR ANY DAMAGES RESULTING FROM (I) THE USE OF THE SERVICES OR (II) FRAUDULENT INTRUSION BY A THIRD PARTY OR (III) ALTERATION/LOSS OF THE DATA AND (IV) MORE GENERALLY, FOR ANY DIRECT OR INDIRECT DAMAGE, REGARDLESS OF THE CAUSE, ORIGIN, NATURE OR CONSEQUENCES THEREOF. ANSAM GROUP DECLINES ALL RESPONSIBILITY IN THE EVENT OF FAULT ON THE PART OF ITS AUXILIARIES, INCLUDING IN THE EVENT OF GROSS NEGLIGENCE.
11. SELECTION OF YOUR COMMUNICATION PREFERENCES AND CREATION OF CUSTOMIZED PROFILES ABOUT YOU
You can choose to receive or not to receive marketing communications from Ansam Group by indicating your preferences. You can click or answer "unsubscribe" in any marketing email communications or newsletters about our Services or you can email us at firstname.lastname@example.org to opt-out of allowing us to create a customized profile about you.
Any marketing by Ansam Group, or any third parties on behalf of Ansam Group, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences.
Please allow up to five business days for your email preferences to take effect. As some marketing tools are developed in advance, you will sometimes receive marketing communications after we receive your preference request.
12. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
14. CONTACTING US
If you would like to contact us for any reason regarding our privacy practices, please email us at email@example.com or write to us at the following address:
Ansam Holding SA, c/o Filaos SA, Rue des Marchandises 13, 1260 Nyon
15. GOVERNING LAW AND PLACE OF JUSRIDICTION
Effective Date: 1st septembre 2023
ANSAM GROUP | COOKIES POLICY
Cookies are small text files that are downloaded to your device by visiting our Website or opening our marketing related emails. Cookies (including third party cookies such as tracking technologies) are in particular used to improve the Website or for general marketing purposes by providing information on interaction of unique browser-device pairs with our Website (such as number of sessions and time spent); statistical information on interaction with our Website (including accessing users' categories, markets, regions, languages, browser and device types and similar information) or statistical information on interaction with our marketing emails (such as if they have been opened or forwarded or links have been clicked on).
Business Partners may track your use of our Website, combine this information with information from other websites you have visited (and which they also track) and use such combined information for their own purposes. If you have registered with the respective Business Partners, they may be able to identify you. In these instances, their processing of your Personal Data will be governed by their privacy policies.
To learn more about Cookies, including how to see which Cookies have been set and how to manage, delete and block them, visit www.aboutcookies.org or www.allaboutcookies.org. You may also consult the help section of your web browser or electronic device for more specific instructions on how to manage Cookies.
Updates to this Cookies Policy
We may update this Cookies Policy. We encourage you to check this page regularly for the latest information on Cookies used with the Website.
Last update : 1st septembre 2023