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PRIVACY POLICY

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SR Logo White
SR Logo White

At Ansam Group, we recognize the need to protect your Personal Data and to ensure the transparency of our processing activities.

This Privacy Policy describes the privacy practices of all Ansam Group companies, namely Ansam Holding SA and its affiliates: iXion Services SA, idros SA, NJ Informatique Sàrl, Novatix SA and Filaos SA ("Ansam Group","we" or"us"), with respect to:

  • The Data of our customers (the"Customers"), the customers of our Customers as well as the end users of our Customers (the"End Customers") that we collect during the performance of the services provided by Ansam Group (the"Services") ;
  • Data from our employees, persons applying for employment with Ansam Group entities and other business partners;
  • Data of persons visiting our Web sites www.ansam.group, www.ixion-group.ch, www.nj-info.ch and www.filaos.ch (the"Web Sites"); and
  • The Web Sites.

We may also have separate documents describing how we handle Data in specific circumstances.

This Privacy Policy governs the Data we collect from our Customers, End-Users, employees, job applicants and Business Partners, as well as from our Web Sites and other online visitors ("you" or "your") and the Data we automatically collect during your online visits.

For the purposes of this Privacy Policy :

"Business Partner" means all service providers, subcontractors, suppliers, agents, advisors, trustees, accountants, auditors, consultants or other third parties with whom we interact in the course of our business.

"Data" refers to all personal data and information that may identify you directly or indirectly, including your identity (name, gender, date of birth, age), your contact details (e-mail address, postal address, telephone number or other contact information), your official documents (passport, identity card, AVS/AHV number), your family situation (marital status, number of dependent children), your bank details (bank account, PostFinance, etc.), your preferences, your IP (Internet Protocol) address and your location data.

Ansam Holding SA is responsible for processing your Data. You will find our contact details below in Section 14. However, this applies only to our own activities and not to those of third parties.

We may also act as a subcontractor for our affiliates, who are then considered Data Processors.

By using the Website or our Services, you consent to the collection, use and processing of Data as described herein.

We collect Data that you provide to us directly.

Where possible, we may also collect Data directly from public authorities or public sources, such as public or commercial registers.

In addition, we collect and process Data when you (i) register for events or webinars, (ii) participate in surveys or other activities offered online, (iii) subscribe to our newsletters, emails or other marketing materials, or (iv) interact with us on third-party social networks (subject to such third parties' terms of use and privacy policies), or (v) enter information on our IT services portal.

Finally, if you visit our websites, applications or digital platforms, we may automatically collect Personal Data, including through Cookies and other active elements, as described below in this Privacy Policy.

4.1 Information we collect automatically

We collect certain information from the browser you use to access our Websites, such as your IP address, device identifier, location data, browser type and language, access times,the URL of the website that referred you to our Websites and the URL to which you are directed when leaving our Website if you click on a link on our Website.

We process your Data for specific purposes and only insofar as 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 business. We process the Data necessary for the administrative management of our business.
  • If you apply for a position with us. If you apply for a position with us, we will process your Data exclusively for the purpose of evaluating your application for a potential contractual employment relationship, including assessing your skills 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 rejection of your application or disciplinary action, including immediate dismissal if you have been hired.

The Personal Data of applicants who have not been hired will be deleted within 3 months of the end of the recruitment process, unless written consent has been obtained. If an employment relationship is established as a result of your application, your Data will be stored in the human resources file and further 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 via the Internet, to identify you when you use our Websites, and to ensure the stability and security of these Websites.
  • To comply with our legal obligations. We may also process your Data if we are legally obliged to do so or on the basis of 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 Customers and End Customers as well as online visitors, including the creation of profiles based on interests and interactions with our Websites, web portals or other digital platforms ;
  • Diagnose problems with our Websites and Services, and 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 Web Sites, Web portals or other digital platforms and our Services, including Ansam Group newsgroups and blogs;
  • To customize, analyze and improve our Websites, web portals or other digital platforms and Services (including content and advertisements to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
  • Comply with our contractual obligations and enforce our terms of Services, the terms of the Websites, web portals or other digital platforms, as well as separate contracts with you, if any;
  • Prevent fraud, software counterfeiting and other prohibited or illegal activities;
  • Protect the security and integrity of you and Ansam Group; or
  • Perform other functions or serve other purposes, as communicated to you at the time of collection, or as required or permitted by law.

5.1 Legal basis for processing

Our legal basis for collecting and using your Data as described in this Privacy Policy will depend on the Data concerned and the specific context in which we collect it.

In general, we collect and process your Data on one or more of the following bases:

  • Your consent, for example where we have obtained your consent to collect/process your Data and store it in your electronic file or to process your Data for certain activities (such as the use of cookies for online tracking and analytics). You are free to withdraw your consent at any time by contactingdata@ansam.ch. If you withdraw your consent, this will not affect the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal.
  • To comply with a contractual obligation: we will inform you at the time of collection if the provision of certain of your Data is mandatory and of the possible consequences if you do not provide us with such Data.
  • To comply with Ansam Group's legal obligations where other laws require the processing of your Data.
  • Ansam Group's legitimate interests, which include providing the Websites, web portals or other digital platforms and/or relevant Services, as well as carrying out marketing and profiling activities, provided that our legitimate interests do not override any prejudice or infringement of your rights and freedoms.

If you have any questions or require further information about the legal basis on which we collect your Data, please contact us atdata@ansam.ch.

5.2 How long do we keep your Data?

We will retain your Data for as long as necessary for the purposes described in this Privacy Policy and in accordance with Ansam Group's retention policies and applicable law.

We will destroy or anonymize Data as soon as it is no longer needed for the purposes described in Section 6. This period varies depending on the type of Data involved and applicable legal requirements.

If you withdraw your consent to the processing of certain Data, we will delete them within 30 days or retain them but anonymize them.

We use appropriate technical and organizational security measures to protect your Personal Data stored by us against loss and unlawful processing, including unauthorized access by third parties. Our security measures are constantly adapted to technological developments. However, it is impossible to completely eliminate security risks in general; residual risks are inevitable.

Ansam Group takes all reasonable steps to protect your Data against misuse, interference and loss, as well as unauthorized access, modification or disclosure. The means we use for this purpose include:

  • In some cases, the use of encryption when collecting or transferring sensitive information.
  • Implementing technical and organizational measures to ensure the continued 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 protect Data.
  • Where required by law, the destruction or de-identification of Data.

We encourage you to keep any passwords you use confidential and to take care to avoid "phishing" scams, where someone might send you an e-mail that appears to come from Ansam Group and ask you for personal information. However, despite our best efforts, no security measure is 100% effective and Ansam Group cannot guarantee or warrant the security of your Data.

We share your Data within Ansam Group or with our Business Partners for the purposes described in this Privacy Policy, including (without limitation) to perform the Services you request or to store the Data.

We will only disclose your Data to third parties if there is a legal obligation or authorization to do so (for example, to authorities in connection with law enforcement, fraud prevention or other legal actions), if you expressly consent, if disclosure is in your interest or if it 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 (for example, for marketing purposes or to improve our online offering).

We will also disclose your Data if we intend to sell Ansam Group or merge Ansam Group with another company, or if we sell the Web Sites or a business unit or all or a substantial part of our assets to a third party.

We are authorized to transfer your Data to third parties abroad, if this is necessary to carry out the Data processing mentioned in this Privacy Policy. Your Data may therefore be processed both in Europe and possibly in any country in the world (for example, to our service providers).

For example, for software tools, we use the services of several software companies. Data collected in the course of using these software tools may be transmitted to servers located in the following countries: Switzerland, European Union countries (including France, Belgium, Germany), the USA (e.g. Microsoft, Adobe, Apple, 10 Zig), Cyprus (3CX), Russia (Kaspersky), Japan (e.g. TrendMicro) and China (e.g. Lenovo, Yealink).

Many countries outside Switzerland or the EU and EEA currently do not have laws guaranteeing an adequate level of data protection under the Federal Data Protection Act (DPA), such as the USA, Cyprus, Russia, Japan and China.

If a recipient is located in a country without adequate data protection, we may contractually oblige that recipient to comply with an adequate level of data protection. Exceptions may apply in the event of legal proceedings abroad, but also in the event of overriding public interests or if the provision of the Services requires such disclosure, if you have consented to it or if it concerns Data that you have made generally accessible, or that you have not objected to its processing.

In addition, we cannot impose contractual obligations on Business Partners with whom we do not negotiate specific contracts individually, but must accept the application of their 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 countries that do not offer the adequate level of protection provided by the DPA.

Please note that under the "Data Protection Framework" (DPF), the European Commission has also recognized the level of data protection of certain companies in the United States as safe under the Adequacy Decision of 10.07.2023. The list of certified companies and further information on CDP can be found on theUS Department of Commerce website.

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You have the following rights as a Data Subject. Please note that these rights are not absolute and, in some cases, are subject to specific conditions in accordance with applicable laws:

  • Access: You have the right to request information about how we process your Data and to obtain a copy of it by sending a request todata@ansam.ch. We may charge you a fee for this Service.
  • You have the right to request that inaccurate Data concerning you be rectified and that incomplete Data concerning you be completed.
  • You have the right to object to the processing of your Data, based on our legitimate interests (as described above).
  • You have the right to request the deletion of your Data (under certain conditions).
  • You have the right to ask us to restrict our processing of your Data, so that we no longer process this 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 this information transmitted to another organization under certain conditions.

In addition, you have the right to lodge a complaint with a supervisory authority (in Switzerland, the Swiss Federal Data Protection and Information Commissioner) if you believe that the way in which we process your Data breaches data protection law.

If you have any questions about the type of Data we hold about you, or if you wish to make a request and exercise any of these rights as a Data Subject, please send a written request to data@ansam.ch or to the postal address at the bottom of this Privacy Policy. While we will use reasonable efforts to respond to your request, we reserve the right to reject such requests for access or to impose restrictions or requirements on such requests if required or permitted by applicable law. In all cases, we will respond within one month.

ANSAM GROUP CANNOT BE HELD RESPONSIBLE FOR ANY INTERRUPTION OR UNAVAILABILITY OF SERVICES. ANSAM GROUP CANNOT GUARANTEE THE CONTINUITY OF SERVICES PERFORMED REMOTELY VIA THE INTERNET, WHICH YOU ACKNOWLEDGE AND ACCEPT. ANSAM GROUP RESERVES THE RIGHT, IN CERTAIN CASES OF FORCE MAJEURE (E.G.: INTRUSION ON ITS SERVERS, MISUSE OF SERVICES BY USERS, REQUEST BY AN AUTHORITY, ETC.) TO SUSPEND SERVICES AND, IN PARTICULAR, ACCESS TO YOUR FILES.

ANSAM GROUP USES COMMERCIALLY REASONABLE EFFORTS TO ENSURE THE SECURITY OF DATA STORED ON ITS 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 CANNOT BE HELD LIABLE (WITHIN THE MEANING OF ARTICLES 100 AND 101 OF THE SWISS CODE OF OBLIGATIONS) FOR DAMAGE RESULTING FROM (I) USE OF THE SERVICES OR (II) FRAUDULENT INTRUSION BY A THIRD PARTY OR (III) MODIFICATION/LOSS OF DATA AND (IV) MORE GENERALLY, FOR ANY DIRECT OR INDIRECT DAMAGE, WHATEVER THE CAUSE, ORIGIN, NATURE OR CONSEQUENCES. ANSAM GROUP DECLINES ALL LIABILITY IN THE EVENT OF FAULT ON THE PART OF ITS AUXILIARIES, INCLUDING GROSS NEGLIGENCE.

You may choose whether or not to receive marketing communications from Ansam Group by indicating your preferences. You may click "Unsubscribe" in any e-mail marketing communications or newsletters regarding our Services, or you may send us an e-mail at data@ansam.ch to unsubscribe and prevent us from creating a personalized profile about you.

All marketing communications from Ansam Group, or any third party acting on behalf of Ansam Group, will be made in accordance with applicable laws and will include (where appropriate) methods for you to express your preferences.

Please allow up to five business days for your e-mail preferences to take effect. As some marketing tools are developed in advance, you may occasionally receive marketing communications after you have requested your preferences.

Please note that Ansam Group provides links to other web sites, which collect Data about you if you click on them. The information practices of those third-party Web sites linked to the Web Sites are not covered by this Privacy Policy.

We may update this Privacy Policy in the future. If we make changes to this Privacy Policy or make substantial changes to the way we use your Data, we will revise this Privacy Policy to reflect those changes, but we will not send you notice of those changes and/or a new version of the Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Data.

If you would like to contact us for any reason regarding our privacy practices, please e-mail us at data@ansam.ch or write to us at the following address: Ansam Holding SA, Rue des Marchandises 13, 1260 Nyon.

This Privacy Policy and your relationship with Ansam Group shall be governed by and construed in accordance with Swiss law, without reference to principles of conflict of laws. The courts of the Canton of Geneva, Switzerland shall have exclusive jurisdiction over any dispute arising out of this Privacy Policy or your relationship with Ansam Group.

Effective date: September1, 2023

Scope

This cookie policy ("Cookie Policy") explains how we, Ansam Group, use cookies, other analytical tools or similar technologies (collectively,"Cookies") in connection with our Website and web portals for policyholders and businesses.

This Cookie Policy is an integral part of our Privacy Policy.

Use of Cookies

Cookies are small text files downloaded to your device when you visit our Website or open our marketing-related e-mails. Cookies (including third-party cookies such as tracking technologies) are used in particular to improve the Website or for general marketing purposes by providing information about the interaction of unique browser-device pairs with our Website (such as number of sessions and time spent) ; statistical information about interaction with our Website (including user categories, markets, regions, languages, browser and device types and similar information) or statistical information about interaction with our marketing e-mails (such as whether they were opened or forwarded or whether links were clicked).

Business Partners may track your use of our Website, combine this information with information from other websites you have visited (which they also track) and use this combined information for their own purposes. If you have registered with the relevant Business Partners, they may be able to identify you. In such cases, their treatment of your Personal Data will be governed by their privacy policy.

You can modify your browser settings to delete and block Cookies. By continuing to use our website without changing your settings (or by using the add-on, if applicable), you consent to our use of Cookies and to that of our Business Partners.

Information

To find out more about Cookies, including how to see which Cookies have been set and how to manage, delete and block them, visitwww.aboutcookies.org orwww.allaboutcookies.org. You can also consult the help section of your web browser or electronic device for more specific instructions on how to manage Cookies.

Updates to this Cookie Policy

We may update this Cookie Policy from time to time. We encourage you to check this page regularly for the latest information on Cookies used with the Website.

Last update: September1, 2023

1. Introduction

At Ansam Group, we recognize the need to protect your Personal Data and to ensure the transparency of our processing activities.

This Privacy Policy describes the privacy practices of all Ansam Group companies, namely Ansam Holding SA and its affiliates: iXion Services SA, idros SA, NJ Informatique Sàrl, Novatix SA and Filaos SA ("Ansam Group","we" or"us"), with respect to:

  • The Data of our customers (the"Customers"), the customers of our Customers as well as the end users of our Customers (the"End Customers") that we collect during the performance of the services provided by Ansam Group (the"Services") ;
  • Data from our employees, persons applying for employment with Ansam Group entities and other business partners;
  • Data of persons visiting our Web sites www.ansam.group, www.ixion-group.ch, www.nj-info.ch and www.filaos.ch (the"Web Sites"); and
  • The Web Sites.

We may also have separate documents describing how we handle Data in specific circumstances.

This Privacy Policy governs the Data we collect from our Customers, End-Users, employees, job applicants and Business Partners, as well as from our Web Sites and other online visitors ("you" or "your") and the Data we automatically collect during your online visits.

For the purposes of this Privacy Policy :

"Business Partner" means all service providers, subcontractors, suppliers, agents, advisors, trustees, accountants, auditors, consultants or other third parties with whom we interact in the course of our business.

"Data" refers to all personal data and information that may identify you directly or indirectly, including your identity (name, gender, date of birth, age), your contact details (e-mail address, postal address, telephone number or other contact information), your official documents (passport, identity card, AVS/AHV number), your family situation (marital status, number of dependent children), your bank details (bank account, PostFinance, etc.), your preferences, your IP (Internet Protocol) address and your location data.

2. Who is responsible for your data?

Ansam Holding SA is responsible for processing your Data. You will find our contact details below in Section 14. However, this applies only to our own activities and not to those of third parties.

We may also act as a subcontractor for our affiliates, who are then considered Data Processors.

3. Consent

By using the Website or our Services, you consent to the collection, use and processing of Data as described herein.

4. How do we collect your data?

We collect Data that you provide to us directly.

Where possible, we may also collect Data directly from public authorities or public sources, such as public or commercial registers.

In addition, we collect and process Data when you (i) register for events or webinars, (ii) participate in surveys or other activities offered online, (iii) subscribe to our newsletters, emails or other marketing materials, or (iv) interact with us on third-party social networks (subject to such third parties' terms of use and privacy policies), or (v) enter information on our IT services portal.

Finally, if you visit our websites, applications or digital platforms, we may automatically collect Personal Data, including through Cookies and other active elements, as described below in this Privacy Policy.

4.1 Information we collect automatically

We collect certain information from the browser you use to access our Websites, such as your IP address, device identifier, location data, browser type and language, access times,the URL of the website that referred you to our Websites and the URL to which you are directed when leaving our Website if you click on a link on our Website.

5. The purposes for which we process personal data

We process your Data for specific purposes and only insofar as 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 business. We process the Data necessary for the administrative management of our business.
  • If you apply for a position with us. If you apply for a position with us, we will process your Data exclusively for the purpose of evaluating your application for a potential contractual employment relationship, including assessing your skills 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 rejection of your application or disciplinary action, including immediate dismissal if you have been hired.

The Personal Data of applicants who have not been hired will be deleted within 3 months of the end of the recruitment process, unless written consent has been obtained. If an employment relationship is established as a result of your application, your Data will be stored in the human resources file and further 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 via the Internet, to identify you when you use our Websites, and to ensure the stability and security of these Websites.
  • To comply with our legal obligations. We may also process your Data if we are legally obliged to do so or on the basis of 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 Customers and End Customers as well as online visitors, including the creation of profiles based on interests and interactions with our Websites, web portals or other digital platforms ;
  • Diagnose problems with our Websites and Services, and 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 Web Sites, Web portals or other digital platforms and our Services, including Ansam Group newsgroups and blogs;
  • To customize, analyze and improve our Websites, web portals or other digital platforms and Services (including content and advertisements to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
  • Comply with our contractual obligations and enforce our terms of Services, the terms of the Websites, web portals or other digital platforms, as well as separate contracts with you, if any;
  • Prevent fraud, software counterfeiting and other prohibited or illegal activities;
  • Protect the security and integrity of you and Ansam Group; or
  • Perform other functions or serve other purposes, as communicated to you at the time of collection, or as required or permitted by law.

5.1 Legal basis for processing

Our legal basis for collecting and using your Data as described in this Privacy Policy will depend on the Data concerned and the specific context in which we collect it.

In general, we collect and process your Data on one or more of the following bases:

  • Your consent, for example where we have obtained your consent to collect/process your Data and store it in your electronic file or to process your Data for certain activities (such as the use of cookies for online tracking and analytics). You are free to withdraw your consent at any time by contactingdata@ansam.ch. If you withdraw your consent, this will not affect the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal.
  • To comply with a contractual obligation: we will inform you at the time of collection if the provision of certain of your Data is mandatory and of the possible consequences if you do not provide us with such Data.
  • To comply with Ansam Group's legal obligations where other laws require the processing of your Data.
  • Ansam Group's legitimate interests, which include providing the Websites, web portals or other digital platforms and/or relevant Services, as well as carrying out marketing and profiling activities, provided that our legitimate interests do not override any prejudice or infringement of your rights and freedoms.

If you have any questions or require further information about the legal basis on which we collect your Data, please contact us atdata@ansam.ch.

5.2 How long do we keep your Data?

We will retain your Data for as long as necessary for the purposes described in this Privacy Policy and in accordance with Ansam Group's retention policies and applicable law.

We will destroy or anonymize Data as soon as it is no longer needed for the purposes described in Section 6. This period varies depending on the type of Data involved and applicable legal requirements.

If you withdraw your consent to the processing of certain Data, we will delete them within 30 days or retain them but anonymize them.

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, including unauthorized access by third parties. Our security measures are constantly adapted to technological developments. However, it is impossible to completely eliminate security risks in general; residual risks are inevitable.

Ansam Group takes all reasonable steps to protect your Data against misuse, interference and loss, as well as unauthorized access, modification or disclosure. The means we use for this purpose include:

  • In some cases, the use of encryption when collecting or transferring sensitive information.
  • Implementing technical and organizational measures to ensure the continued 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 protect Data.
  • Where required by law, the destruction or de-identification of Data.

We encourage you to keep any passwords you use confidential and to take care to avoid "phishing" scams, where someone might send you an e-mail that appears to come from Ansam Group and ask you for personal information. However, despite our best efforts, no security measure is 100% effective and Ansam Group cannot guarantee or warrant the security of your Data.

7. How do we share your data?

We share your Data within Ansam Group or with our Business Partners for the purposes described in this Privacy Policy, including (without limitation) to perform the Services you request or to store the Data.

We will only disclose your Data to third parties if there is a legal obligation or authorization to do so (for example, to authorities in connection with law enforcement, fraud prevention or other legal actions), if you expressly consent, if disclosure is in your interest or if it 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 (for example, for marketing purposes or to improve our online offering).

We will also disclose your Data if we intend to sell Ansam Group or merge Ansam Group with another company, or if we sell the Web Sites or a business unit or all or a substantial part of our assets to a third party.

8. Data transfer abroad

We are authorized to transfer your Data to third parties abroad, if this is necessary to carry out the Data processing mentioned in this Privacy Policy. Your Data may therefore be processed both in Europe and possibly in any country in the world (for example, to our service providers).

For example, for software tools, we use the services of several software companies. Data collected in the course of using these software tools may be transmitted to servers located in the following countries: Switzerland, European Union countries (including France, Belgium, Germany), the USA (e.g. Microsoft, Adobe, Apple, 10 Zig), Cyprus (3CX), Russia (Kaspersky), Japan (e.g. TrendMicro) and China (e.g. Lenovo, Yealink).

Many countries outside Switzerland or the EU and EEA currently do not have laws guaranteeing an adequate level of data protection under the Federal Data Protection Act (DPA), such as the USA, Cyprus, Russia, Japan and China.

If a recipient is located in a country without adequate data protection, we may contractually oblige that recipient to comply with an adequate level of data protection. Exceptions may apply in the event of legal proceedings abroad, but also in the event of overriding public interests or if the provision of the Services requires such disclosure, if you have consented to it or if it concerns Data that you have made generally accessible, or that you have not objected to its processing.

In addition, we cannot impose contractual obligations on Business Partners with whom we do not negotiate specific contracts individually, but must accept the application of their 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 countries that do not offer the adequate level of protection provided by the DPA.

Please note that under the "Data Protection Framework" (DPF), the European Commission has also recognized the level of data protection of certain companies in the United States as safe under the Adequacy Decision of 10.07.2023. The list of certified companies and further information on CDP can be found on theUS Department of Commerce website.

9. Your data protection rights

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You have the following rights as a Data Subject. Please note that these rights are not absolute and, in some cases, are subject to specific conditions in accordance with applicable laws:

  • Access: You have the right to request information about how we process your Data and to obtain a copy of it by sending a request todata@ansam.ch. We may charge you a fee for this Service.
  • You have the right to request that inaccurate Data concerning you be rectified and that incomplete Data concerning you be completed.
  • You have the right to object to the processing of your Data, based on our legitimate interests (as described above).
  • You have the right to request the deletion of your Data (under certain conditions).
  • You have the right to ask us to restrict our processing of your Data, so that we no longer process this 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 this information transmitted to another organization under certain conditions.

In addition, you have the right to lodge a complaint with a supervisory authority (in Switzerland, the Swiss Federal Data Protection and Information Commissioner) if you believe that the way in which we process your Data breaches data protection law.

If you have any questions about the type of Data we hold about you, or if you wish to make a request and exercise any of these rights as a Data Subject, please send a written request to data@ansam.ch or to the postal address at the bottom of this Privacy Policy. While we will use reasonable efforts to respond to your request, we reserve the right to reject such requests for access or to impose restrictions or requirements on such requests if required or permitted by applicable law. In all cases, we will respond within one month.

10. Ansam Group's responsibility for your data

ANSAM GROUP CANNOT BE HELD RESPONSIBLE FOR ANY INTERRUPTION OR UNAVAILABILITY OF SERVICES. ANSAM GROUP CANNOT GUARANTEE THE CONTINUITY OF SERVICES PERFORMED REMOTELY VIA THE INTERNET, WHICH YOU ACKNOWLEDGE AND ACCEPT. ANSAM GROUP RESERVES THE RIGHT, IN CERTAIN CASES OF FORCE MAJEURE (E.G.: INTRUSION ON ITS SERVERS, MISUSE OF SERVICES BY USERS, REQUEST BY AN AUTHORITY, ETC.) TO SUSPEND SERVICES AND, IN PARTICULAR, ACCESS TO YOUR FILES.

ANSAM GROUP USES COMMERCIALLY REASONABLE EFFORTS TO ENSURE THE SECURITY OF DATA STORED ON ITS 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 CANNOT BE HELD LIABLE (WITHIN THE MEANING OF ARTICLES 100 AND 101 OF THE SWISS CODE OF OBLIGATIONS) FOR DAMAGE RESULTING FROM (I) USE OF THE SERVICES OR (II) FRAUDULENT INTRUSION BY A THIRD PARTY OR (III) MODIFICATION/LOSS OF DATA AND (IV) MORE GENERALLY, FOR ANY DIRECT OR INDIRECT DAMAGE, WHATEVER THE CAUSE, ORIGIN, NATURE OR CONSEQUENCES. ANSAM GROUP DECLINES ALL LIABILITY IN THE EVENT OF FAULT ON THE PART OF ITS AUXILIARIES, INCLUDING GROSS NEGLIGENCE.

11. Select your communication preferences

You may choose whether or not to receive marketing communications from Ansam Group by indicating your preferences. You may click "Unsubscribe" in any e-mail marketing communications or newsletters regarding our Services, or you may send us an e-mail at data@ansam.ch to unsubscribe and prevent us from creating a personalized profile about you.

All marketing communications from Ansam Group, or any third party acting on behalf of Ansam Group, will be made in accordance with applicable laws and will include (where appropriate) methods for you to express your preferences.

Please allow up to five business days for your e-mail preferences to take effect. As some marketing tools are developed in advance, you may occasionally receive marketing communications after you have requested your preferences.

12. Links to third-party websites and services

Please note that Ansam Group provides links to other web sites, which collect Data about you if you click on them. The information practices of those third-party Web sites linked to the Web Sites are not covered by this Privacy Policy.

13. Changes to this Privacy Policy

We may update this Privacy Policy in the future. If we make changes to this Privacy Policy or make substantial changes to the way we use your Data, we will revise this Privacy Policy to reflect those changes, but we will not send you notice of those changes and/or a new version of the Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Data.

14. Contact us

If you would like to contact us for any reason regarding our privacy practices, please e-mail us at data@ansam.ch or write to us at the following address: Ansam Holding SA, Rue des Marchandises 13, 1260 Nyon.

15. Applicable law & place of jurisdiction

This Privacy Policy and your relationship with Ansam Group shall be governed by and construed in accordance with Swiss law, without reference to principles of conflict of laws. The courts of the Canton of Geneva, Switzerland shall have exclusive jurisdiction over any dispute arising out of this Privacy Policy or your relationship with Ansam Group.

Effective date: September1, 2023

Cookie policy

Scope

This cookie policy ("Cookie Policy") explains how we, Ansam Group, use cookies, other analytical tools or similar technologies (collectively,"Cookies") in connection with our Website and web portals for policyholders and businesses.

This Cookie Policy is an integral part of our Privacy Policy.

Use of Cookies

Cookies are small text files downloaded to your device when you visit our Website or open our marketing-related e-mails. Cookies (including third-party cookies such as tracking technologies) are used in particular to improve the Website or for general marketing purposes by providing information about the interaction of unique browser-device pairs with our Website (such as number of sessions and time spent) ; statistical information about interaction with our Website (including user categories, markets, regions, languages, browser and device types and similar information) or statistical information about interaction with our marketing e-mails (such as whether they were opened or forwarded or whether links were clicked).

Business Partners may track your use of our Website, combine this information with information from other websites you have visited (which they also track) and use this combined information for their own purposes. If you have registered with the relevant Business Partners, they may be able to identify you. In such cases, their treatment of your Personal Data will be governed by their privacy policy.

You can modify your browser settings to delete and block Cookies. By continuing to use our website without changing your settings (or by using the add-on, if applicable), you consent to our use of Cookies and to that of our Business Partners.

Information

To find out more about Cookies, including how to see which Cookies have been set and how to manage, delete and block them, visitwww.aboutcookies.org orwww.allaboutcookies.org. You can also consult the help section of your web browser or electronic device for more specific instructions on how to manage Cookies.

Updates to this Cookie Policy

We may update this Cookie Policy from time to time. We encourage you to check this page regularly for the latest information on Cookies used with the Website.

Last update: September1, 2023