Privacy Notice of Silent Gliss International Ltd.
1. Data protection
Silent Gliss is committed to protecting and respecting your privacy and complying with the applicable data protection laws, in particular the EU General Data Protection Regulation (“GDPR”).
This Privacy Notice provides you with information about how the company of the Silent Gliss Group referred to in section 2 (hereinafter Silent Gliss, we or us) is collecting and processing data, what we do with this information, and what rights you have.
2. Data controller
Silent Gliss International Ltd.
3. What types of personal data do we process?
Silent Gliss will, depending on the purpose why we collect and process your personal data (if any), we may collect and process personal data about you including:
- personal details such as your name, phone number, physical and electronic address;
- your photograph, where necessary, for the purpose of identifying you in the course of our legitimate business;
- if you are an employee of Silent Gliss: your social security number, date of birth, citizenship, family details such as the name of your spouse, partner or children as well as other data from the employment relationship (for example, time recording data, leave times, work incapacity times, bank details);
- if you are a prospect employee of Silent Gliss: professional information about you, such as you job title, details about your education, your work experience, letter of reference;
- if you are a prospect employee or an employee of Silent Gliss: information supplied by third parties such as references from former employers and information from criminal records checks (if necessary for your role);
- when you access our website, data transmitted by your browser and automatically recorded by our server, including date and time of the access, name of the accessed file as well as the transmitted data volume and the performance of the access, your web browser, browser language and requesting domain, and IP address;
- when you register to the partner area of our website we will ask you to provide the following information:
- Full address
- Phone number
- E-mail address
4. On which legal basis and for which purposes do we process personal data?
4.1. Legal basis for processing
Depending on the purpose of the processing activity (see 4.2), the processing of your personal data will be one of the following:
- Necessary for the legitimate interest of Silent Gliss, without unduly affecting your interest or fundamental rights and freedoms, however, provided that such interests are not overridden by your privacy interests (see below);
- Necessary for taking steps to enter into or executing an employment contract with you, or for carrying our obligations under such a contract;
- Necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as when we use your data for some of the purposes in sections 4.2;
- When we use special categories of personal data, necessary for establishing exercising or defending legal claims or where the processing relates to personal data manifestly in the public domain;
- In limited circumstances, processed with your consent which we obtain from you from time to time (for instance where required by laws), or processed with your explicit consent in the case of special categories of personal data such as your medical information;
- We may have other legitimate interests and we will make clear to you at the relevant time what those legitimate interests are;
- In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
If we ask you to provide personal data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
4.2. Purposes of processing
Partner area of our website
You may wish to sign-up to our partner area of our website to get more detailed information about our products and specifications. We will process your personal data provided to us in the signing-up process to verify your identity, provide products and services to you and ensuring their proper execution, manage the relationship with you, including communication with you in relation to the products and services you obtain from us.
We may also handle customer service-related queries and complaints through the partner area.
We ask you on our website whether you want to "Sign up" to receive information from us. Where you enter your personal data into this box you agree that we may process such personal data to send you advertisement such as the latest case studies, events updates and product news by e-mail, phone, text message and post. You can unsubscribe at any time by contacting us using the contact details at section 9.
Communication to us by email, contact form etc.
From time to time, you may wish to contact us with queries or complaints regarding our products and services. You may contact us by e-mail, phone and our in-website contact form. We will use any details which you provide to us as set out in section 3 to investigate and resolve your query or complaint and to improve our service in the future.
Where we collect and process personal data of our dealers and customers, we will use these for the purpose of performing the respective contracts, providing products and services to you and the customer, ensuring their proper execution, managing the relationship with you, including communication with you in relation to the products and services you obtain from us.
We may also collect and process personal data of our dealers and customers to handle customer service-related queries and complaints.
We may use your e-mail address to send you marketing communications or newsletters by email, either where you have actively consented to these or where we are entitled to do so by law. If at any stage you no longer wish to receive these types of email, please use the opt-out link at the bottom of every email or contact us using the contact details at section 9. Please note that even where you have opted-out of marketing communications, we may still need to send you service messages, for example, a confirmation email about a product you have ordered.
Cookies / Tracking and Other Techniques regarding the use of our website
You may configure your browser settings in a way that it rejects cookies or deletes them prematurely. Most browsers are preset to accept cookies.
Performing employment contracts
Where we collect and process information about our employees, we will use these for the purpose of performing the respective employment contract, for the purpose of managing the Silent Gliss Group of Companies and for administrative purposes. This includes using information to enable us to comply with the employment contract and with any legal requirements, keep a record of employee performance, absence and disciplinary processes pursue our legitimate interests and protect our legal position.
When you telephone Silent Gliss your call may be recorded for training and quality purposes. We will only do this in order to make sure that our Care Centre staff are operating as well as they can, allowing us to provide you with our greatest level of customer service. We do not use call recordings for any other purposes.
5. Our disclosure of your information / Categories of Recipients
We do not sell or rent any of your personal data to any third party.
We may disclose your personal data to the following categories of recipients:
- to Silent Gliss Group companies in order to ensure a consistent high service standard across our group, and to provide services and products to you;
- to our third-party services providers who provide data processing services to us (for example, to support the performance of our website, enhance the security of our website or process salary data);
- our service providers including our group companies and companies outside our group;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
- to our legal and other professional advisers for them to advise us and to our insurers and insurance brokers in the event of a claim or to manage or administer our insurance policies;
- to any other person with your consent to the disclosure.
Our servers are based in Switzerland and the European Economic Area ("EEA") and we generally store and process your personal data within the European Economic Area ("EEA") and Switzerland (“CH”). If at any time we need to make an ad-hoc or ongoing transfer of your personal data outside of the EEA and CH, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA and CH, including by entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - US Privacy Shield. Our website servers are located in Switzerland. If you would like more details of the mechanism under which your data is transferred outside of the EEA and Switzerland, please contact us using the contact details in section 9.
6. Security of your information
We employ appropriate technical and organisational security measures in an effort to protect your personal data from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. However, it is important to remember that no web-based platform can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is outside of our control.
If we become aware of any breach of your personal data, we will take steps to promptly assess and remediate the breach. Where appropriate, and in accordance with our legal obligations, we may also take steps to notify you about the breach, where we believe that the breach has resulted in a high risk to your rights and freedoms.
7. Retention of your information
We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements.
In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
8. Your rights
In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the following rights in respect of your personal data:
If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details in section 9.
In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details in section 9.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details in section 9.
Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
We will respond to and manage any requests which you make in relation to the rights set out above in accordance with data protection laws. In addition to the above, you have the right to lodge a complaint with the competent data protection authority. However, we are keen to address any issues with our use of your personal data or the exercising of your rights, and in the first instance we would ask that you attempt to resolve the problem with us directly. However, in relation to all these rights, please contact us using the details given below. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In addition, you have the right to enforce your rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority is the office of the Federal Data Protection and Information Commissioner (FDPIC): www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html
9. Contact us
If you have any questions about this Notice, or any queries or complaints about how your personal data is processed, or if you wish to exercise any of your information rights, please contact us:
Silent Gliss International Ltd.
10. Changes to personal data
We are committed to keeping your personal data accurate and up to date. Therefore, if your personal data changes, please inform us of the change as soon as possible.
11. Status of this Privacy Notice
Version effective as of 1.11.2018
We may amend this Privacy Notice at any time without prior notice. The current version published on our website shall apply. If the Privacy Notice is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an anmendment.