Privacy policy
IMPORTANT NOTE: The German version of this document will govern our relationship – this translated version is provided for convenience only and will not be interpreted to modify the German version.
In this Privacy Policy, we, P4i AG (hereinafter referred to as “we” or “us”), explain how we collect and otherwise process personal data. This is not an exhaustive description; other terms and conditions and similar documents may govern specific matters. Personal data is understood to be all information that relates to an identified or identifiable person.
If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please make sure that these persons are aware of this privacy policy and only share their personal data with us if you are allowed to do so and if this personal data is correct.
This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection Act («revDPA»). However, whether and to what extent these laws are applicable depends on the individual case.
1. Responsible person / data protection officer / representative
Responsible for the data processing operations we describe here and representative in the EEA according to Art. 27 GDPR is:
Mark Neuhauser
Sumpfstrasse 18
6312 Steinhausen
Switzerland
If you have any data protection concerns, you can send them to us at the aforementioned contact address.
2. Collection and processing of personal data
We primarily process the personal data that we receive from our customers and other business partners in the course of our business relationship with them and other persons involved in it, or that we collect from their users in the operation of our websites, apps and other applications.
To the extent permitted, we also take certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet) or receive such data from other companies within the group of companies (ITG AG, 28 Vectors GmbH and pending companies), from authorities and other third parties (such as credit agencies, address dealers). In addition to the data about you that you give us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and legal proceedings, information in connection with your professional functions and activities (so that, for example, we can (so that we can, for example, conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people close to you (family, advisors, legal representatives, etc.) give us so that we can conclude or process contracts with you or with the involvement of you (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the use or provision of services by you (e.g. payments made, purchases made)), information from the media and Internet about you (where this is appropriate in the specific case, e.g. as part of a job application, press review, marketing/sales, etc.). e.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other sociodemographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of visit, pages and content accessed, functions used, referring website, location information).
3. Purposes of data processing and legal basis
We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of M&A transactions with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this capacity.
In addition, we also process personal data about you and other individuals, as permitted and as we deem appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest consistent with the purpose:
- Offer and further develop our offers, services and websites, apps and other platforms on which we are present;
- Communicating with third parties and handling their inquiries (e.g., job applications, media inquiries);
- Examination and optimization of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly available sources for the purpose of customer acquisition;
- Advertising and marketing (including the organization of events), unless you have objected to the use of your data (if we send you advertising as an existing customer of ours, you can object to this at any time, we will then put you on a blacklist against further advertising mailings);
- Market and opinion research, media monitoring;
- Assertion of legal claims and defense in connection with legal disputes and official proceedings;
- Prevention and investigation of crime and other misconduct (e.g., conducting internal investigations, data analysis to combat fraud);
- Warranties of our operations, especially IT, our websites, apps and other platforms;
Insofar as you have given us consent to process your personal data for certain purposes (for example, when you register to receive newsletters or carry out a background check), we process your personal data within the scope of and based on this consent, insofar as we have no other legal basis and we require such a basis. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.
4. Cookies / tracking and other technologies related to the use of our website
We do not use “cookies” or similar technologies on our websites that can identify your browser or device.
We also include visible and invisible image elements in some of our newsletters and other marketing emails, where permitted, that allow us to determine if and when you have opened the email by retrieving them from our servers so that we can measure and better understand how you use our offers and tailor them to you here as well. You can block this in your email program; most are preset to do so. By using our websites and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, then you must set your browser or email program accordingly.
5. Data transfer and data transmission abroad
Within the scope of our business activities and the purposes set out in section 3, we also disclose data to third parties, insofar as this is permitted and appears to us to be appropriate, either because they process it for us or because they want to use it for their own purposes. This concerns in particular the following entities:
- service providers of us within the group of companies as well as externally, such as banks, insurance companies, including order processors (such as IT providers);
- dealers, suppliers, subcontractors and other business partners;
- customers;
- domestic and foreign authorities, official agencies or courts;
- media;
- public, including visitors to websites and social media;
- competitors, industry organizations, associations, organizations and other bodies;
- acquirers or parties interested in acquiring business units, companies or other parts of the Group;
- other parties in potential or actual legal proceedings;
- other companies in the group;
all together in the following called recipient.
These recipients are partly domestic, but can be anywhere in the world. In particular, you must expect the transfer of your data to all countries where the group of companies is represented by group companies, branches or other offices, as well as to other countries in Europe and the USA, where the service providers we use are located (such as Microsoft, HubSpot, ...).
If a recipient is located in a country without adequate legal data protection, we contractually obligate the recipient to comply with the applicable data protection law (for this purpose, we use the European Commission's revised standard contractual clauses, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless it is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have consented or if it is a matter of data made generally available by you, the processing of which you have not objected to.
6. Duration of the retention of personal data
We process and store your personal data as long as it is necessary for the fulfillment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e., for example, for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the time during which claims can be asserted against our company and insofar as we are otherwise legally obligated to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as a matter of principle and to the extent possible. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less apply in principle.
7. Data security
We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization and controls.
8. Obligation to provide personal data
In the context of our business relationship, you must provide those personal data that are necessary for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations (you usually do not have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or perform a contract with you (or the entity or person you represent). Also, the website cannot be used if certain traffic-securing information (such as IP address) is not disclosed.
9. Profiling and automated decision making
We process your personal data partly automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to be able to inform and advise you about products in a targeted manner. In doing so, we use evaluation tools that enable us to provide needs-based communication and advertising, including market and opinion research.
For the establishment and implementation of the business relationship and also otherwise, we generally do not use fully automated automatic decision-making (as regulated, for example, in Art. 22 GDPR). Should we use such procedures in individual cases, we will inform you separately about this, insofar as this is required by law, and inform you about the associated rights.
10. Rights of the data subject
Within the scope of the data protection law applicable to you and insofar as provided therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restriction of data processing and otherwise the right to object to our data processing, in particular those for the purposes of direct marketing, profiling operated for direct advertising and other legitimate interests in the processing, as well as to the release of certain personal data for the purpose of transfer to another entity (so-called data portability). Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to rely on this) or require it for the assertion of claims. If you incur costs, 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 the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.
The exercise of such rights usually requires that you clearly prove your identity (e.g. by means of a copy of your ID card, where your identity is otherwise not clear or cannot be verified). To exercise your rights, you can contact us at the address given in section 1.
In addition, every data subject has the right to enforce his or her claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://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 applies. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.
As of: August 31, 2023