DATA PROTECTION NOTICE
TROJAN GROUP SA in Lausanne (subsequently referred to as “we”) greatly respects your privacy. As a result, we take the task of protecting your Personal Data such as name, date of birth, address, e-mail address, telephone number, etc., very seriously. This Data Protection Notice regulates the collection, processing and utilisation of your Personal Data if and insofar as the information is accumulated while using our Website and applies on past and future data.
When handling this data, we will proceed by taking into full account the relevant legal data protection regulations, in particular the Swiss Federal Data Protection Act (“FDPA”) and related data protection laws, as well as the EU General Data Protection Regulation (GDPR) and the following principles.
We do not gather any personal information when you are merely using the website for information purposes, i.e. when no log in or registration is carried out and no other kind of information is submitted, except for the information transmitted by your browser that allows you to visit the website.
- IP address
- Time and date of the inquiry
- Time difference from Greenwich Mean Time (GMT)
- Content of the request (specific pages)
- Access status/HTTP status code
- Each transmitted data volume
- Website from where the inquiry came
- Operating system and its interface
- Language and browser version
DATA AVOIDANCE AND DATA MINIMISATION
We will observe the principles of data avoidance and data minimisation. That means that we will collect, process and use as little Personal Data as possible.
PERSONAL DATA AND CONSENT
We will collect, process and use your Personal Data only if this is necessary for substantiating, implementing or terminating a contractual customer relationship or similar.
In the remainder of cases, we will only collect, process and use your Personal Data following your prior consent. Your Personal Data will only be used for the purpose and to the extent to which you have consented. For example, we will only inform you of our products and services once your consent has been received.
You have the following rights in relation to your Personal Data, unless in presence of a legal or regulatory obligation or an overriding legitimate interest of Trojan Group SA or of a third party:
- a right of access and request a copy of your Personal Data;
- a right of rectification where the information we hold about you is inaccurate;
- a right to request that your Personal Data be erased where for instance they are not necessary for the purpose for which they were collected or processed or if you withdraw your consent;
- a right to restrict the use of your personal information;
- a right to object to the processing of Personal Data;
- where applicable, a right to data portability;
- a right to withdraw your consent for the processing of Personal Data at any time. Please note that such withdrawal shall only apply for future data processing and shall not impact the processing that occurred in the past. Requesting the withdrawal of your data should be sent to the following email address: email@example.com with an ID card.
- A right to submit a complaint with the competent data protection authority if you believe that our processing of your Personal Data infringes applicable data protection laws. In Switzerland, the Federal Data Protection and Information Commissioner is competent to supervise private entities: firstname.lastname@example.org.
Please note that we may refuse certain of your requests, in particular provide access to your Personal Data, if the applicable data protection laws or other provisions allows or forces us to do so, in which case we will provide the grounds to our decision.
AUTOMATICALLY GENERATED DATA
In the course of using the pages on our websites Personal Data may be automatically processed. Typically, this relates to the name of your internet provider, your IP address, the browser you are using, your operating system, the web pages you visited on our website and the website from which you accessed our website. In all the above mentioned cases the processing of such data is carried out anonymously, that is to say it is impossible to assign and therefore identify any individual person from this data.
A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can obtain is information a user supplies him or herself.
A cookie cannot read data from your hard disk or read cookie files created by other sites. Cookies, however, enhance our web site performance in a number of ways, including providing a secure way for us to verify your identity during your visit to our web site and personalising your experience on our site, making it more convenient for you.
THIRD PARTY ACCESS TO YOUR PERSONAL DATA
The collection, processing and utilisation of Personal Data is carried out by ourselves and also by service providers authorised by us. In this latter case, we will ensure that group companies and service providers comply with the applicable data protection regulations and the resulting obligations from this Data Protection Notice. In the course of sending goods or promotional material, or in the case of competitions, it may, for example, result in the commissioning of service providers.
In the remainder of cases third parties will not have access to your Personal Data. We will not sell your data or use it for other means. Only as a result of magisterial or legal requirements, as well as obligations to notify, will your data be processed and in particular passed on to government authorities.
We have reinforced technical and organizational measures to protect your data against accidental loss, theft or unlawful use, unauthorized or accidental destruction, falsification or any other unauthorized processing. We take all reasonable and necessary administrative, technical and physical measures to ensure that the data collected is processed and stored securely and in accordance with this Data Protection Notice and to ensure the data’s confidentiality, integrity, availability and resilience.
DELETION AND BLOCKING
We will delete your Personal Data when the associated business objective ceases to apply or when the relevant legal data protection regulations call for this. For instance, we will delete the data collected for a competition if you have not consented to your data being collected, processed and used for any other purpose. In cases of consent being given, we will delete your data following the retraction of your approval or the discontinuation of the purpose of your consent. Requesting the withdrawal of your data should be sent to the following email address: email@example.com with an ID card.
If requested, we will totally block or partially block your Personal Data. With regard to this arrangement, you are to inform us of the extent and the duration that this should be carried out for. As long as this is technically and legally possible, you will be able here to exclude your data from being processed and used for certain purposes.
AMENDMENTS TO THIS DATA PROTECTION NOTICE
We keep this Data Protection Notice constantly up-to-date. As a result, it may be necessary to adapt this Data Protection Notice to accommodate any factual or legal changes to the basic conditions. By using our Website you have accepted these adaptations.
You are more than welcome to contact us at any time should you have questions relating to the collection, processing and utilisation of your Personal Data. We will also gladly provide you with general information regarding data protection. For this purpose, please contact us using the following address:
TROJAN GROUP SA
Rue Etraz 4