2.Which Personal Data Do We Process and for What Purposes?
We process a wide range of personal data for different reasons and purposes. Further information is provided in this section, in possible declarations of consent and, in many instances, in the applicable general terms and conditions, conditions of participation, and additional privacy policies. We generally collect personal data directly from you, e.g. when you transfer data to us or communicate with us. However, personal data may also be collected from other sources, especially in the case of the following data:
information from public registers, e.g. the debt enforcement register;
information obtained from private providers such as credit reference agencies, mailing list brokers, data-bases to prevent fraud and money laundering, etc.;
information obtained from the internet, the media and media monitoring agencies;
information obtained from online service providers, e.g. providers of web analytics services;
information relating to payment transactions carried out by financial services providers;
information obtained from any company you work for, e.g. name, contact details, title, role, etc.;
information concerning you that other parties have supplied to us, e.g. in the course of any administrative or court proceedings, or during any interactions with us.
The purposes for which we process personal data concerning you in particular include the following:
communicating with you and with third parties;
providing customer services;
providing, managing, backing up and customizing websites, apps, online offers and other infrastructure, e.g. Wi-Fi;
entering into and performing contracts with you;
entering into and performing contracts with suppliers, customers and business partners that are connected to you and managing relationships with customers and suppliers;
gaining a better understanding of our end customers and their behavior and interests, evaluating and im-proving acceptance levels for our products and services as well as our communications in relation to prod-ucts and services;
advertising and marketing, e.g. staging events, conducting competitions, etc. and sending targeted infor-mation and marketing communications by post and electronically (unless the recipient has objected to di-rect marketing);
conducting market research and opinion polls;
preparing and undertaking corporate takeovers and sales as well as similar transactions;
administration and management of IT and other resources;
accounting, archiving, training and other administrative purposes;
reviewing and improving our internal processes and sharing personal data within Eurocentres;
ensuring the safety of our employees and premises as well as areas;
reviewing and meeting legal requirements, including court orders or orders issued by authorities, for com-pliance purposes and for the purpose of detecting and investigating abuses;
enforcing our rights and the rights of affiliated companies and defending any claims against us, our employees, our affiliated companies and against our contracting and business partners in court or in relation to the authorities, within or outside Switzerland.
3.To Whom Do We Disclose Personal Data?
Our employees have access to your personal data to the extent required for the purposes defined and for the perfor-mance of the activities of the employees in question. These include employees in other departments/branches and in support roles, e.g. IT. Our employees act in accordance with our instructions and are bound by confidentiality and non-disclosure obligations in handling your personal data. We may transfer your personal data to any third parties that sup-ply services to us (e.g. IT service providers, Partner schools) both within and outside Eurocentres.
Furthermore, personal data may be transferred to other companies which may (also) use such data for their own pur-poses. In such cases, the data recipient is legally responsible as the controller of the data. This would apply in the fol-lowing circumstances, for example:
Corporate management services, for example accounting or asset management
Advisory services, for example the services of tax advisors, lawyers, and management consultants, as well as the services of advisors in the fields of personnel recruitment and placement
IT services, for example in the areas of hosting, cloud services, the delivery of email newsletters, and data analysis and enhancement
Credit assessments, for example if you want to make a purchase on account
If we are required to transfer personal data to another company in relation to transactions contemplated or carried out by us, including company mergers or the acquisition or sale of individual parts of a company or its assets.
We may disclose your personal data to third parties (e.g. to the courts and authorities within Switzerland and abroad) if this is required by law. We also reserve the right to process your personal data in order to satisfy a court order or for the purpose of enforcing or defending legal rights or claims or if we consider such processing to be necessary on any other legal grounds. We may also disclose your personal data to other parties involved in any proceedings.
If we transfer claims against you to other companies, such as collection agencies.
4.When Do We Transfer Your Personal Data Abroad?
The recipients of your personal data may be located abroad – including outside of the EU or EEA. The countries in question may not have laws in place that afford your personal data the same level of protection as provided in Switzerland or in the EU or the EEA. In transferring your personal data to such a country, we are required to ensure the protection of your personal data in a suitable manner. One means of doing so is to conclude data transfer agreements with the recipients of your personal data that ensure the required level of data protection. Please contact us if you would like a copy of our data transfer agreements.
5. How Do We Process Personal Data in relation to websites and email newsletters?
If we distribute newsletters by email, we may be able to establish whether or when you opened the email, allowing us to assess your use of the email and provide offers that better match your interests. You can stop the processing of such data in your email program.
Our websites also incorporate functions from social networks such as Facebook, Twitter, YouTube, Google+, and Instagram. These functions are disabled by default. Enabling such functions may allow social network providers to log your visit to our website. Such providers may use this information for their own purposes, under their own responsibility and in accordance with their own data protection rules.
6.Do We Conduct Profiling and Use Automated Decision-Making?
"Profiling"refers to a procedure during which personal data is processed on an automated basis in order to as-sess, analyze, or predict personal aspects, for example an individual's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. We often conduct profiling, for example in analyzing shopping behavior, selecting job applicants or evaluating contractual partners, etc.
"Automated decision-making"refers to any decision that is made on an automated basis, i.e. with no relevant human influences, and may have negative legal implications or other similar adverse consequences for you. We will provide separate information on any automated decision-making deployed by us in specific cases, insofar as such information is legally required.
7.For How Long Do We Store Your Personal Data?
We store your personal data in a personalized form for as long as it is required for the specific purpose for which it was collected. In the case of contracts, personal data is stored for at least the duration of the contractual relationship. We also store personal data if we have a legitimate interest in doing so, e.g. for documentation and evidential purposes or to safeguard and defend legal rights. We also store your personal data if it is subject to a statutory retention requirement.
8.How Do We Protect Your Personal Data?
We take appropriate technical measures (e.g. encryption, pseudonymization, record keeping, access restrictions, data backups) and organizational measures (e.g. instructions issued to employees, confidentiality agreements, audits) in order to safeguard your personal data, protect you against unauthorized or unlawful processing activities, and to address the risk of loss, unintentional changes, inadvertent disclosure, or unauthorized access. In general, however, security risks cannot be completely ruled out; certain residual risks are unavoidable in most cases.
9.What Rights Do You Have in Connection with the Processing of Your Personal Data?
You may object to the processing of your personal data at any time, especially to data processing related to direct advertising (e.g. advertising emails).
Under the law applying to you, you also have the right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to object to the processing of data, and the right to receive personal data that you have provided to us in a readable format and free of charge. You also have the right to withdraw your consent, which will not affect the lawfulness of processing based on consent before its withdrawal. You can also lodge a complaint with the competent data protection authority.
10.What Else Do You Need to Bear in Mind?
We process your personal data in particular on the basis of the following principles:
the conclusion of a contract with the data subjects or for pre-contractual measures requested by the data subjects;
legitimate interests: these include, for example, interests in connection with customer support and com-munications with customers, including outside the framework of a contract; interests in the performance of marketing activities; our interest in getting to know our customers and other individuals better; our interest in improving existing products and services and developing new ones; our interest in facilitating intra-Group management and communication, which is necessary for a Group that requires cooperation between parties; our interest in combating fraud, for example in online shops, and in the prevention and investigation of offenses; our interest in protecting customers, employees and other individuals and data, as well as secrets and assets of Eurocentres; our interest in ensuring IT security, especially in connection with the use of websites, apps and other IT infrastructure; our interest in safeguarding and organizing business operations, including the running and further development of websites and other systems; our interest in ensuring corporate management and development; any interest in selling or purchasing companies, parts of companies, or other assets; any interest in the enforcement or defense of legal rights and claims; and our interest in complying with Swiss law and internal rules and regulations;
consent provided by you where we have separately requested such consent;
compliance with legal requirements.
Incidentally, there is no general obligation to disclose personal data to us unless you have entered into a contractual relationship with us that establishes such an obligation. We will, however, be required to collect and process any per-sonal data that is necessary or legally prescribed for the purposes of commencing and performing a contractual relationship and meeting related obligations. Otherwise, it will not be possible for us to conclude or continue the contract in question. It is also necessary, in practice, to process log data and certain other types of data in connection with website use. In relation to any communications with us, it is also necessary for us, as a minimum, to process personal data that you transfer to us or that we transfer to you.
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