“We”, ADB GLOBAL [Advanced Digital Broadcast SA, with company registration number CH-660-091001-7 and registered address Route de Lausanne 319, CH-1293 Bellevue, Switzerland and its affiliates] (“ADB”) are responsible for the processing of personal data that we collect from or about “you”. For example we collect your personal data during a business relationship or when you visit our website or use our software applications. We process your personal data in compliance with applicable European data protection laws REG.EU 679/2016 and other statutory provisions.
WHAT ARE PERSONAL DATA?
Personal data are information that directly or indirectly identifies you as an individual, indirectly meaning when combined with other information, for example your name, postal address, email address and phone number, or a unique device identifier.
WE APPLY THE FOLLOWING RULES WHEN PERSONAL DATA PROCESSING AND PRIVACY OF INDIVIDUALS IS CONCERNED:
We are committed to safeguarding your privacy;
We only use your personal information to help us service your request, to improve our services to you, and to provide you with product or service you have requested; we also use your personal data for recruitment purposes, technology cups or internships we organize from time to time in case you apply for them and agree for your data to be processed;
We do not sell, rent or exchange your personal information with any third party for commercial reasons;
We may share selected information to agencies and contractors working on behalf of us as part of normal business operations (e.g. to email you about a service issue or send you some information you have requested or to inform you about additional products and service enhancements that may be of interest to you);
you are entitled to obtain a copy of your personal data held by us.
USE OF PERSONAL DATA
Registration data and direct communication For many services we collect your personal data, like: name, postal address, phone number and email address (“Registration Data”). We use your Registration Data to communicate with you about our services and let you know about our policies and terms. We also use your Registration Data as well as the content of our communication to respond to you when you contact us.
Use of your personal data for recruitment and other HR related purposes For any recruitment purposes as well as for any other programs we run in order to attract talents, new employees, students or technology champions we need your personal data such as name, surname, phone number, e-mail address, your education details. We will not use your personal data for such purposes unless you have freely given your explicit and prior consent. We use your personal data in order to stay in contact with you during such a process as well as we may keep your records in our database for future similar activities. However we will remove your data permanently within maximum 2 years from their collection.
Use of your personal data for advertising purposes To continuously improve and enhance our services, we may send you marketing communications via email relating to our business which may be of interest to you. You can choose the types of communications you want to receive at any time by updating your email preferences. You may also unsubscribe at any time by contacting us at [email protected]. We will not use your personal data for advertising purposes unless you have freely given your explicit and prior consent. However, for existing customers, we may use your email address that we obtained from you in the context of our existing customer relationship to provide you with marketing materials relating to similar products or services that you have previously requested, used or participated in. You may, however, object to such use at the time of collection and each time a message is sent to opt-out of email marketing, follow the instructions within the email that you receive; you can always use by contacting us at [email protected] to inform us about any changes you wish us to apply for our personal data processing.
Legal obligations and legal defense We may be required to use and retain personal data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention, fraud or any other abuse of our services and IT systems. We may also use your personal data to meet our internal and external audit requirements, information security purposes, or to protect or enforce our rights, privacy, safety, or property, or those of other persons.
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Third party websites As a convenience to our visitors, this website contains links to a number of websites that are not affiliated with, controlled, or managed by us. The policies and procedures we describe here do not apply to those websites. We are not responsible for the security or privacy of any data collected by these third parties. We suggest contacting those websites directly for information on their privacy policies.
INDIVIDUALS’COMPLAINTS ON US
When we receive a complaint from a person, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We may from time to time compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to people involved in handling the complaint. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
When we take enforcement action against someone, we may disclose the identity of the defendant. Usually we do not identify any complainants unless the details have already been made public.
PEOPLE WHO USE OUR SERVICES
We may offer various services to the public. For example, we distribute an electronic newsletter. Where we use a third party for such purposes, they are only allowed to use your personal data for this specific service.
We have to keep records of your personal data in order to enable us to provide this service to you and for other closely related purposes. For example, we might use information about you in order to carry out a customer satisfaction survey. Please note you have the right to unsubscribe any time by contacting us at [email protected].
We use IP addresses to analyze trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Additionally, for systems administration, detecting usage patterns and troubleshooting purposes, our web servers automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within ADB on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above without your explicit permission.
HOW WE SHARE PERSONAL DATA
We will disclose your personal data only for the purposes and to those third parties, as described below. ADB will take appropriate steps to ensure that your personal data are processed, secured, and transferred according to applicable law.
External service providers Where necessary, we will commission other companies and individuals to perform certain tasks contributing to our services on our behalf within the framework of data processing agreements. We may, for example, provide personal data to agents, contractors or partners for hosting our databases and applications, for data processing services, or to send you information that you requested. We will only share with or make accessible such data to external service providers to the extent required for the respective purpose. This data may not be used by them for any other purposes, in particular not for their own or third party purposes. ADB’s external service providers are contractually bound to respect the confidentiality of your personal data.
Public bodies We will only disclose your personal data to public bodies where this is required by law. ADB will for example respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
Legal entities within ADB Group ADB Group’s legal entities outside the European Union have entered into intra-company data protection agreements using standard contractual clauses adopted by the European Commission to safeguard your privacy and legitimize international data transfers.
Other third parties outside the EU / EEA Any transfers of personal data to third parties outside the ADB Group will be carried out with your prior knowledge and, where applicable, with your consent. Any transfers of personal data into countries other than those for whom an adequacy decision regarding the level of data protection was made by the European Commission, as listed on http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm, occur on the basis of contractual agreements using standard contractual clauses adopted by the European Commission or other appropriate safeguards in accordance with the applicable law.
PROCESSING OF SENSITIVE DATA
We may, in certain cases, process special categories of personal data concerning you (“sensitive data”). Sensitive data refer to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health or a natural person’s sex life or sexual orientation. We may for example process sensitive data that you manifestly have made public. We may also process sensitive data as necessary for the establishment, exercise or defense of legal claims. We may also process your sensitive data if you have freely given your prior, express and separate consent in a specific context for a specific purpose.
ADB takes data security seriously. We apply an appropriate level of security and have therefore implemented reasonable physical, electronic, and administrative procedures to safeguard the data we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. Our information security policies and procedures are closely aligned with widely accepted international standards and with the European data protection regulation and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. Access to your personal data is granted only to those personnel, service providers or ADB affiliates with a business need-to-know or who require it in order to perform their duties. In the event of a data breach containing personal data, ADB will follow all applicable data breach notification laws.
YOUR LEGAL RIGHTS
The following list contains information on your legal rights which arise from applicable data protection laws:
Right to withdraw consent Where the processing of personal data is based on your consent you may withdraw this consent at any moment by following the procedures described in the respective consent form or directly by contacting us at [email protected]. We ensure that consent can be withdrawn by the same means as it was given – e.g., electronically.
Right to rectification You may obtain from us rectification of personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.
Right to restriction You may request your personal data processing to be restricted, where one of the following applies:
you contest the accuracy of your personal data, for the period we need to verify accuracy thereof;
the processing is unlawful and you request the restriction of processing rather than erasure of your personal data;
we do no longer need your personal data but you require them for the establishment, exercise or defense of legal claims, or;
you object to the processing while we verify whether our legitimate grounds override yours.
Right to access You may ask from us information regarding personal data that we hold about you, including information as to which categories of personal data we have in our possession or control, what they are being used for, where we collected them, if not from you directly, and to whom they have been disclosed, if applicable. You may obtain from us one copy, free of charge, of personal data we hold about you. We reserve the right to charge a reasonable fee for each further copy you may request.
Right to portability At your request, we will transfer your personal data to another controller, where technical feasible, provided that the processing is based on your consent or necessary for the performance of a contract. Rather than receiving a copy of your personal data you may request that we transfer the data to another controller, specified by you, directly.
Right to erasure (“right to be forgotten”) You may obtain from us the erasure of your personal data, where
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you have withdrawn your consent for processing of your personal data and there is no other legal ground for the processing;
you have filed the objection against further processing of your personal data due to your specific situation although such processing would be normally allowed as related to public or legitimate interest and/or in the exercise of official authority; in such case we will remove your data unless such processing is absolutely required to protect our interest or defend our position in case of potential law suit;
the personal data have been unlawfully processed,
Please however note that we are allowed not to erase your personal data in case they are necessary for:
compliance with a legal obligation which requires processing from us;
in particular for statutory data retention requirements;
for the establishment, exercise or defense of legal claims.
Right to object You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you wish the erasure of your personal data or the restriction of its processing by us.
Right to lodge a complaint In case of an alleged infringement of applicable privacy laws, you may lodge a complaint with the data protection supervisory authority in the country you live in or where the alleged infringement occurred.
Time period We will try to fulfill your requests communicated to us concerning your legal rights within 30 days. However, the period may be extended due to justified reasons related to specific circumstances or complexity of your request.
Restriction of access In certain situations we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will advise you of the reason for the refusal.
No identification In some cases, we may not be able to look up your personal data due to the identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification.
RETENTION OF YOUR PERSONAL DATA
In general, we will delete the personal data we collected from you if they are no longer necessary to achieve the purposes for which they were originally collected. However, we may be required to store your personal data for a longer period due to statutory provisions.
In addition, we will not delete all of your personal data if you requested from us to refrain from re-contacting you in the future. For this purpose, ADB keeps records which contain information on people who do not want to be re-contacted in the future. We qualify your request as consent to store your personal data for the purpose of such record keeping unless you instruct us otherwise.
HOW TO CONTACT US
You have the right to access and correct your personal information and privacy preferences at any time. Any requests can be emailed to [email protected] or sent by mail to:
Advanced Digital Broadcast SA,
Route de Lausanne, 319
CH – 1293 Bellevue, Switzerland,
Last revised: May 22nd 2018