This Privacy Policy explains the nature, scope, and purpose of the collection and use of personal data on our website www.circular-food-solutions.com (hereinafter “Website”) by Circular Food Solutions Switzerland AG (hereinafter “we” or “us”), and provides information about the rights available to you. These rights are governed by applicable data protection legislation.
1. Data Controller and Contact
The controller responsible for data processing on this website and the contact person for data protection matters is:
Circular Food Solutions Switzerland AG
Industriestrasse 40
8404 Winterthur
+41 76 580 36 56
christoph@circular-food-solutions.com
2. Collection and Processing of Personal Data
Personal data is processed in the following categories:
- Customer data of clients for whom we provide or have provided services.
- Personal data we have received indirectly from our clients in the course of providing services.
- Digital visitor data when our website is accessed.
- Customer data relating to personal profiles or interests based on participation in one of our events.
- Various data when we communicate in any form (varying by location, time, and subject matter).
- Data in the context of other contractual relationships, e.g. as a supplier, service provider, or consultant.
- Personal data in connection with job applications.
- Data where we are required to process it for legal reasons.
- Data used in connection with data protection or legal compliance.
More detailed information can be found in section 4.
3. Categories of Personal Data
The type and scope of personal data processing depends on the relationship between you and Circular Food Solutions Switzerland AG, as well as the purpose or reason for which we process the data. In addition to your contact details, we also process other information about you or about persons related to you. If this information constitutes particularly sensitive personal data, this has further implications for our processing and internal procedures.
Depending on the purpose, the following categories of personal data may be collected:
- Contact information (e.g. surname, first name, address, telephone number, email)
- Personal customer information (e.g. date of birth, nationality, marital status, occupation, title, job title, AHV number)
- Data on your creditworthiness, corporate law data, and financial information (bank accounts)
- Data in connection with specific orders or contracts
- Website data (e.g. IP address, device information (UDI), browser information, website usage (analysis and use of plugins, etc.))
- Application data (e.g. CV, employment references)
- Advertising and marketing information and personal interests (e.g. newsletter sign-up, interest in specific topics, specialisations)
- Security and network data (e.g. visitor lists, access controls, network and mail scanners, telephone call logs)
Where permitted, we also obtain data from publicly accessible sources (e.g. debt enforcement registers, land registers, commercial registers, press, internet), or receive such data from our clients and their employees, from authorities, (arbitration) courts, and other third parties. In addition to data you provide directly to us, the categories of personal data we receive from third parties about you include in particular: information from public registers; information we learn in connection with official and judicial proceedings; information relating to your professional roles and activities; information about you in correspondence and meetings with third parties; credit reports; information about you provided by persons in your circle (family, advisors, legal representatives, etc.) to enable us to enter into or process contracts with you or involving you (e.g. references, your address for deliveries, powers of attorney); information for compliance with legal requirements such as anti-money laundering and export restrictions; information from banks, insurers, distribution partners, and other contractual partners regarding services used or provided by you (e.g. payments made, purchases made); information from media and the internet about you (where appropriate in the specific case, e.g. in the context of a job application); your addresses and, where applicable, interests and other socio-demographic data (for marketing purposes); data in connection with the use of the website (e.g. IP address, MAC address of smartphone or computer, information about your device and settings, cookies, date and time of visit, pages and content accessed, functions used, referring website, location data).
4. For What Purpose Do We Process Data?
When you contact us (e.g. by telephone, contact form, or email), when we contact you, or in the context of our business relationship with clients and other contractual relationships with business partners and other parties involved, we process the personal data necessary for this purpose.
The personal data involved includes in particular:
- Contact information (e.g. surname, first name, address, telephone number, email, other contact details)
- Personal information (e.g. date of birth, nationality, marital status, occupation, title, job title, passport/ID number, AHV number, family circumstances, etc.)
- Data on your creditworthiness and entries in various registers or sanction lists, as well as data in specialised databases and from digitally accessible public sources
- Financial information (e.g. bank account details, investments, or shareholdings)
- Business data, depending on the order or contract
We process this personal data for the described purposes on the basis of the following legal grounds:
- Conclusion or performance of a contract with or for the benefit of the data subject, including pre-contractual steps and any enforcement (e.g. supply contract, sales contract, service contract)
- Fulfilment of a legal obligation (e.g. where we are legally required to collect and/or disclose data)
- Pursuit of legitimate interests (e.g. for administrative purposes, to improve our quality, ensure security, manage risk, enforce our rights, defend against claims, or assess potential conflicts of interest)
- Consent (e.g. to send you marketing information, create image material, for the use of cookies or the newsletter)
4.1 Website
No personal data needs to be disclosed in order to use our website. However, with each access the server records a number of user details, which are temporarily stored in the server’s log files.
When this general information is used, no assignment to a specific person takes place. The collection of this information and data is technically necessary in order to display our website and to ensure its stability and security. This information is also collected to improve the website and analyse its use.
4.2 Events
When you attend an event organised by us, we collect personal data in order to organise and run the event and to send you any follow-up information. We also use your information to inform you about future events. At these events, we may photograph or film you and publish this material internally or externally.
5. Tracking Technologies
We use cookies on our website. These are small files that your browser automatically creates and stores on your device (laptop, tablet, smartphone, etc.) when you visit our site.
Information is stored in the cookie that arises in connection with the specific device being used. This does not, however, mean that we thereby gain direct knowledge of your identity. Cookies are used, on the one hand, to make the use of our offering more convenient for you. We use session cookies, for example, to recognise that you have already visited individual pages of our website.
In addition, we use temporary cookies to optimise user-friendliness; these are stored on your device for a specified period. When you visit our site again to use our services, it is automatically recognised that you have visited before and what inputs and settings you made, so that you do not have to enter them again. We also use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offering. These cookies allow us to automatically recognise on a repeat visit that you have been to our site before.
The data processed via cookies is necessary for the stated purposes. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer, or so that a notice always appears before a new cookie is created. Completely disabling cookies may, however, mean that you are unable to use all functions of our website.
6. Web and Newsletter Analytics
To gain insight into the use of our website, to improve our online offering, and to be able to target you with advertising on third-party websites or social media, we use the following technologies: Google Analytics, Google Maps, Google reCAPTCHA, Adobe Fonts, Social Media Plugins.
These tools are provided by third parties. As a rule, the information collected for this purpose about the use of a website is transmitted to the third party’s server via cookies or similar technologies. Depending on the third party, these servers may be located abroad.
Data is normally transmitted with IP addresses shortened, which prevents identification of individual devices. Information is only passed on by third parties on the basis of legal requirements or within the scope of commissioned data processing.
6.1 Google Analytics
We use Google Analytics, the web analytics service of Google LLC, Mountain View, California, USA; the entity responsible for Europe is Google Limited Ireland (“Google”). To opt out of Google Analytics, Google provides a browser plug-in at https://tools.google.com/dlpage/gaoptout?hl=en. Google Analytics uses cookies — small text files that enable specific, user-related information to be stored on the user’s device. These enable Google to analyse the use of our website. The information collected by the cookie about your use of our pages (including your IP address) is generally transmitted to and stored on a Google server in the USA. We note that on this website, Google Analytics has been extended with the code “gat._anonymizeIp();” to ensure anonymised collection of IP addresses (IP masking). When anonymisation is active, Google shortens IP addresses within member states of the European Union or in other contracting states of the Agreement on the European Economic Area, meaning no conclusions about your identity are possible. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. Google may link your IP address with other data held by Google. For data transfers to the USA, Google has committed to signing and complying with the EU Standard Contractual Clauses.
6.2 Google Maps
We use Google Maps (API) from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; entity responsible for Europe: Google Limited Ireland, “Google”) on our website. Google Maps is a web service for displaying interactive maps to present geographical information visually. This service is used to show you our location and make it easier to find us. When you access the subpages on which the Google Maps map is embedded, information about your use of our website (such as your IP address) is transmitted to and stored on Google servers in the USA. This occurs regardless of whether Google provides a user account through which you are logged in, or whether no user account exists. If you are logged in to Google, your data is assigned directly to your account. If you do not want your data to be associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and analyses them. For data transfers to the USA, Google has committed to signing and complying with the EU Standard Contractual Clauses.
6.3 Google reCAPTCHA
We use Google reCAPTCHA from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; entity responsible for Europe: Google Limited Ireland, “Google”) on our website. Google reCAPTCHA is used to verify whether data entry on this website (e.g. in a contact form) is being carried out by a human or by an automated programme. For this purpose, Google reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis begins automatically as soon as the visitor enters the website. For the analysis, Google reCAPTCHA evaluates various pieces of information (e.g. IP address, time spent on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google. These analyses run entirely in the background; website visitors are not informed that an analysis is taking place. For data transfers to the USA, Google has committed to signing and complying with the EU Standard Contractual Clauses.
6.4 Adobe Fonts
This website uses web fonts from Adobe for the consistent display of certain typefaces. The provider is Adobe Systems Incorporated, 345 Park Avenue, San Jose, CA 95110-2704, USA (Adobe). When this website is accessed, your browser loads the required fonts directly from Adobe in order to display them correctly on your device. In doing so, your browser establishes a connection to Adobe’s servers in the USA. This allows Adobe to learn that this website was accessed via your IP address. According to Adobe, no cookies are stored when the fonts are provided. Data transfers to the USA are based on the EU Commission’s Standard Contractual Clauses.
6.5 Social Media Plugins
Our website uses so-called social media plugins (“plugins”) from third-party providers. The plugins are identifiable by the logo of the respective social network. Via the plugins, we offer you the opportunity to interact with social networks and other users. We use the following plugins on our website: LinkedIn, YouTube.
When you access our website, your browser establishes a direct connection to the third-party provider’s servers. The content of the plugin (e.g. YouTube videos) is transmitted directly from the respective third-party provider to your browser and integrated into the page. Data is shared to display content regardless of whether you have an account with the third-party provider and are logged in. If you are logged in to the third-party provider, the data collected from you on our site is assigned directly to your existing account with that provider. If you activate the plugins, the information is also published on the social network and displayed to your contacts.
For information on the purpose and scope of data collection, further processing and use of data by third-party providers, and your rights and settings options to protect your privacy, please refer to the privacy notices of the respective third-party providers. The third-party provider stores the data collected about you as usage profiles and uses these for the purposes of advertising, market research, and/or tailoring its website to demand. If you wish to prevent third-party providers from assigning data collected via our website to your personal profile on the respective social network, you must log out of that social network before visiting our website. You can also completely prevent plugins from loading using specialised browser add-ons such as “Ghostery” (https://www.ghostery.com/) or “NoScript” (http://noscript.net/).
7. Data Disclosure and Transfer
We only pass your data on to third parties where this is necessary for the provision of our services, where those third parties provide a service on our behalf, where we are legally or officially required to do so, or where we have an overriding interest in disclosing the personal data. We will also pass personal data on to third parties if you have given your consent to do so or have requested us to do so.
Not all personal data is transmitted in encrypted form as standard. Unless explicitly agreed otherwise with the client, all data is transmitted without encryption.
The following categories of recipient may receive personal data from us:
- Other service providers (e.g. IT service providers, hosting providers, suppliers)
- Third parties in the context of our legal or contractual obligations, authorities, public bodies, courts.
We enter into contracts with service providers who process personal data on our behalf, obliging them to ensure data protection. Our service providers are predominantly located in Switzerland or in the EU/EEA. Certain personal data may also be transferred to the USA (e.g. Google Analytics data) or, in exceptional cases, to other countries worldwide. If a transfer of data to countries that do not have an adequate level of data protection is required, this is carried out on the basis of EU Standard Contractual Clauses (e.g. in the case of Google) or other suitable instruments.
8. Retention Period for Personal Data
We process and store your personal data for as long as is necessary to fulfil our contractual and legal obligations, or otherwise to achieve the purposes pursued by the processing — that is, for example, for the duration of the entire business relationship (from initiation and execution through to termination of a contract) and beyond, in accordance with statutory retention and documentation obligations. It is possible that personal data may be retained for the period during which claims can be asserted against our company (i.e. in particular during the statutory limitation period) and insofar as we are otherwise legally required to do so, or legitimate business interests require it (e.g. for evidentiary and documentation purposes). Once your personal data is no longer required for the above purposes, it will as a rule be deleted or anonymised to the extent possible. Shorter retention periods of twelve months or less generally apply to operational data (e.g. system logs).
9. Data Security
We take appropriate technical and organisational security measures to protect your personal data:
- against unauthorised access (confidentiality)
- to ensure it is available when needed (availability)
- against misuse and alteration (integrity)
- to ensure processing is traceable (accountability)
This may be achieved through the issuance of policies, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymisation, and audits.
The person responsible for data protection at Circular Food Solutions Switzerland AG is to be involved in new projects from the outset and regularly reviews data security in accordance with applicable principles and legal requirements.
10. Obligation to Provide Personal Data
Within the scope of our business relationship, you must provide the personal data that is necessary for the initiation and conduct of a business relationship and the fulfilment of the associated contractual obligations (as a rule, you are not under a statutory obligation to provide us with data). Without this data, we will not be able to enter into or process a contract with you (or the entity or person you represent). The website also cannot be used if certain information required to ensure data traffic (such as IP address) is not disclosed.
11. Your Rights
In connection with our processing of personal data, you have the following rights:
- Right to information about personal data stored about you, the purpose of processing, its origin, and the recipients or categories of recipients to whom personal data is disclosed.
- Right to rectification if your data is incorrect or incomplete.
- Right to restriction of the processing of your personal data.
- Right to request the deletion of personal data being processed.
- Right to data portability.
- Right to object to data processing or to withdraw consent to the processing of personal data at any time without giving reasons.
- Right to lodge a complaint with a competent supervisory authority, where provided for by law.
To exercise these rights, please contact the address given in section 1.
Please note, however, that we reserve the right to invoke the restrictions provided for by law, for example where we are obliged to retain or process certain data, have an overriding interest in doing so (to the extent we are entitled to rely on this), or need the data to assert claims. If costs arise for you, we will inform you in advance.
