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Privacy Policy

Version effective as of [13. Okt. 2024]

With this Privacy Policy we Digital Principles GmbH, 8152 Opfikon, Switzerland (hereinafter Digital Principles, we or us), describe how we collect and further process personal data.

The term 'personal data' in this Privacy Policy shall mean any information that identifies or could reasonably be used to identify any person.

If you provide us with personal data of other persons (such as employees, end clients, fami-ly members, work colleagues), please make sure the respective persons are aware of this Privacy Policy and only provide us with their data if you are allowed to do so and such per-sonal data is correct.

This Privacy Policy is aligned with the EU General Data Protection Regulation («GDPR») and the Swiss Data Protection Act («DPA»). However, the application of these laws de-pends on each individual case.

1. Controller / Data Protection Officer / Representative

The 'controller' of data processing as described in this Privacy Policy (i.e. the responsible person) is Digital Principles. You can notify us of any data protection related matters using the following contact details of Digital Principles or info+dpa@scopy.me

2. Collection and Processing of Personal Data

We primarily process the following personal data that we obtain from our clients/users and other business partners as well as other individuals in the context of our business relation-ships with them or that we collect from clients/users when operating our platform websites and applications («Platform»):
  • Full name (first name, middle name, last name and gender)
  • Address
  • E-mail address
  • Telephone and/or mobile number
  • Passport and/or ID number
  • Bank account number
  • Credit and/or debit card number
  • Social security number
  • IP addresses
  • Further personal data you may upload in your discretion

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g. debt registers, commercial registers, press, internet) or we may receive such information from affiliated companies of Digital Principles, from authorities (e.g. traffic de-partments, courts), or other third parties. Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information in connection with your professional role and activities (e.g. in order to conclude and carry out contracts with your employer), information about you in correspondence and discussions with third parties, credit rating information (if we conduct business activities with you personally), information about you given to us by individuals associated with you (family, consultants, legal representatives, etc.), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insuranc-es as well as data in connection with your use of the Platform (e.g. IP address, MAC ad-dress of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).

3. Purpose of Data Processing and Legal Grounds

We primarily use collected data in order to conclude and process contracts with our cli-ents/users and business partners, in particular in connection with providing consulting, ad interim management (both in the fields of IT and management) as well as an online Platform solution in the field of corporate strategy as well as digital creators or any other strategical processes and related software, products or services, as well as in order to comply with our domestic and foreign legal and regulatory obligations. You may also be affected by our data processing in your capacity as an employee of such a client/user or business partner.

In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:
  • Offer, provide and develop our Platform services.
  • Review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition.
  • Advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings).
  • Market and opinion research.
  • Asserting legal claims and defense in legal disputes and official proceedings.
  • Prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud).
  • Ensuring our operation, including our IT, our websites, software (including the Platform) and other appliances.
  • Acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of Digital Principles.

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or carrying out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

4. Cookies / Tracking and Other Techniques Regarding the Use of the Platform

We typically use 'cookies' and similar techniques on our websites or software (including the Platform), which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your com-puter or mobile device, when you visit our website or install our software (including our Plat-form). If you revisit our website or use our software (including the Platform), we may recog-nize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the Platform ('session cookies'), we may use cookies in order to save user configurations and other information for a certain time period (e.g. two years) ('permanent cookies'). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies for the purpose of saving user configuration (e.g. language, automated log in), in order to understand how you use our services and content, and to enable to show you customized offers and advertisement (which may also happen on websites of other companies; should your identity be known to us, such companies will not learn your identity from us; they will only know that the same user is visiting their website has previously visited a certain web-site). Certain cookies are sent to you from us, others from business partners with which we collaborate. If you block cookies, it is possible that certain functions (such as, e.g. language settings, shopping basket, ordering processes) are no longer available to you.

In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing e-mails. If such image files are retrieved from our servers, we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting.

By using our websites, software (including the Platform) and consenting to the receipt of newsletters and other marketing e-mails you agree to our use of such techniques. If you object, you must configure your browser or e-mail program accordingly or uninstall the soft-ware (including the Platform), should the respective setting not be available.

We may use Google Analytics, Vercel or similar services on our Platform. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google Ireland Ltd. (located in Ireland), Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both «Google»), www.google.com and in case of Vercel Inc is located in the United States, www.vercel.com) and which allow us to measure and evaluate the use of our Platform (on an anonymized basis). For this pur-pose, permanent cookies are used, which are set by the service provider. Although we can assume that the information we share with Google and/or Vercel is not personal data for Google or Vercel, it may be possible that Google or Vercel may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google or Vercel accounts of these individuals for its own purposes. If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not any personal information of you).

In addition, we may use plug-ins from social networks such as TikTok, WeChat, Facebook, Twitter, YouTube, Pinterest or Instagram on our Platform. This is visible for you (typically based on the respective symbols). We have configured these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks may record that you are on our Platform and where on our Platform you are exact-ly and may use this information for their own purposes. This processing of your personal data lays in the responsibility of the respective operator and occurs according to its data protection regulations. We do not receive any information about you from the respective operator.

5. Datatransfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is per-mitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be con-cerned:
  • Our service providers and subcontractors, including processors (e.g. IT providers, cloud storage providers, third-party payment providers, analytics service providers).
  • Domestic and foreign authorities or courts.
  • Acquirers or parties interested in the acquisition of Digital Principles or business divisions or other parts of Digital Principles.
  • Other parties in possible or pending legal proceedings.
  • Affiliates of Digital Principles.

together Recipients.

Certain Recipients may be within Switzerland, but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to countries of the EU, EFTA and/or EEA, the UK and the USA where some of our service providers are locat-ed (such as cloud computing/storage providers).

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with appropriate data protection standards (for this purpose, we use the revised European Commission's standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recip-ient is subject to a legally accepted set of rules (like the Swiss-U.S. Data Privacy Framework or the EU-U.S. Data Privacy Framework) to ensure data protection, unless we can rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclo-sure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

6. Retention Periods for your Personal Data

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g. for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anony-mized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g. system logs).

7. Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as IT and network security solu-tions, access controls and restrictions, encryption of data carriers and transmissions, pseu-donymisation, inspections.

8. Obligation to Provide Personal Data To Us

In the context of our business relationship, you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the perfor-mance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the Platform cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).

9. Profiling and Automated Individual Decision-Making

We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products, applications, features or tools suitable or relevant to you. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise you as required. In establishing and carrying out a business relationship, we generally do not use any fully automated individual decision-making (such as pursuant to article 22 GDPR). Should we use such procedures in certain cases, we will inform you separately on this and advise you of your relevant rights if required by law.

10. 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 right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain per-sonal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in conse-quences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.

In general, exercising these rights requires that you are able to prove your identity (e.g. by a copy of identification documents where your identity is not evident otherwise or can be veri-fied in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.

In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection au-thority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Data Processing Agreement

If we are processing personal data as a processor, we will conclude a Data Processing Agreement (DPA) with you for this purpose.

12. Amendments of this Privacy Policy

We may amend this Privacy Policy at any time without prior notice. The current version published on our Platform shall apply. If the Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.

Updates

When we do, we will revise the updated date at the top of this page. Continued use of the Website and Service after any such changes shall constitute your consent to such changes. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us at info+privacy@scopy.me