In this data protection declaration, we, Sieber + Partner MRB GmbH, Kirchstrasse 1, 6003 Lucerne, represented by Daniela Sieber, explain how we collect and otherwise process personal data. This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation and similar documents may govern specific matters. Personal data means all information that relates to a specific 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 (“revDSG”). However, whether and to what extent these laws are applicable depends on the individual case.
1. person responsible / data protection officer / representative
The person responsible for the data processing we describe here is:
Sieber + Partner MRB GmbH
Hirschmattstrasse 23
6003 Lucerne
Switzerland
Represented by:
Daniela Sieber
If you have any data protection concerns, you can send them to us at the following contact address: info@sieber-partner.ch.
Data protection officer:
Daniela Sieber
+41 41 521 01 05
info@sieber-partner.ch
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, public authorities and other third parties (such as credit agencies). 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 we can, e.g. (e.g. so that we can 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 involving you (e.g. references, your address for deliveries, full addresses, etc.). 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. in the context of a job application, press releases, 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, so in particular as part of our core business 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 process personal data of you and other persons, to the extent permitted and deemed appropriate, also for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:
– Offering and further developing our offers, services and websites, apps and other platforms on which we are present;
– Communicating with third parties and processing their requests (e.g. applications, media inquiries);
– Advertising and marketing (including the holding of events), insofar as you have not 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, and we will then place you on a blocking list 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 criminal offenses and other misconduct (e.g., conducting internal investigations, data analyses to combat fraud);
– Guarantees of our operations, in particular IT, our websites, apps and other platforms;
– Video surveillance to maintain housekeeping rights and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone records);
– Purchase and sale of business units, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and insofar as necessary to comply with legal and regulatory obligations as well as internal regulations of Sieber + Partner MRB GmbH.
If you have given us consent to process your personal data for specific purposes (for example, when you register to receive newsletters or conduct a background check), we process your personal data within the scope of and based on this consent, unless we have another 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 in connection with the use of our website
We typically use “cookies” and similar technologies on our websites to identify your browser or device. In addition to cookies that are used only during a session and deleted after your visit to the website (“session cookies”), cookies may also be used to store user preferences and other information for a period of time (e.g., two years) (“persistent cookies”). However, you can set your browser to reject cookies, store them for one session only, or otherwise delete them early. Most browsers are preset to accept cookies. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.
5. data disclosure and data transfer 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. In particular, this concerns the following entities:
– Service providers of us (within Sieber + Partner MRB GmbH as well as externally, such as banks, insurance companies), including order processors (such as IT providers);
– dealers, suppliers, subcontractors and other business partners;
– domestic and foreign authorities, official agencies or courts;
– Media in the context of self-promotion;
– The 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 Sieber + Partner MRB GmbH;
– other parties to potential or actual legal proceedings;
all joint recipients.
These recipients are partly in Germany, but can be anywhere in the world. In particular, you should expect your data to be transferred to all countries where Sieber + Partner MRB GmbH is represented by group companies, branches or other offices, as well as to other countries in Europe and the United States where the service providers we use are located (such as [Microsoft], [APPLE], etc.).
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 revised standard contractual clauses of the European Commission, 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. 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), generally shorter retention periods of twelve months or less apply.
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, controls.
8. obligation to provide personal data
Within the scope 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 generally 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 information to ensure data traffic (such as IP address) is not disclosed.
9. profiling and automated decision making
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 DSGVO). Should we use such procedures in individual cases, we will inform you separately about this, provided that this is legally required and inform you about the associated rights.
10. rights of the data subject
Within the framework of the data protection law applicable to you and to the extent provided therein (such as in the case of the GDPR), you have the right of access, rectification, erasure, the right to restrict data processing and otherwise object to our data processing, in particular those for the purposes of direct marketing, profiling 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 identity card, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.
Every data subject also 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 (http://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 shall apply. If the Privacy Policy is part of an agreement with you, we will notify you of the change by e-mail or other appropriate means in the event of an update.
Source: This privacy policy is based on the template of the DSAT – Privacy Self Assessment Tool and has been adapted to the actual circumstances of the website www.sieber-partner.ch.