Data Protection Statement of Vorhall KLG

With this Data Protection Statement we, the Vorhall KLG, describe how we collect and further process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements [or General Terms and Conditions, Conditions of Participation or similar documents] are applicable to specific circumstances.

The term "personal data" in this Data Protection Statement to 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 family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and such personal data is correct.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA»). However, the application of these laws depends on each individual case.

1. Controller

The "controller" of data processing as described in this data protection statement (i.e. the re- sponsible person) is the Vorhall KLG. You can notify us of any data protection related concerns using the following contact details:

Vorhall KLG
Brückfeldstrasse 40
CH-3012 Berne
info@vorhall.com

2. Collection and Processing of Personal Data

We primarily process personal data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our website and other applications.

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., debt registers, land registries, commercial registers, press, internet) or we may receive such information from affiliated companies of XXX, from authorities or other third parties (such as e.g., [credit rating agencies, ][list brokers]). 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 from public registers, data received in connection with administrative or court proceedings, 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.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery-address, powers of attorney), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g., payments made, previous purchases), information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with job applications, media reviews, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our website (e.g., IP address, MAC address 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 clients and business partners, in particular in connection with providing consulting and implementation services to our clients and the procurement of products and services from our suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a client 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:

• providing and developing our products, services and website and other platforms, on which we are active;
• communication with third parties and processing of their requests (e.g., job applications, media inquiries);
• 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, media surveillance;
• asserting legal claims and defense in legal disputes and official proceedings;
• prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
• ensuring our operation, including our IT, our websites, apps 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 Vorhall KLG.

If you have given us your consent to process your personal data for certain purposes (for ex- ample when registering to receive newsletters), 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 and Other Techniques Regarding the Use of our Website

Our website https://vorhall.com currently does not use any cookies.

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 permitted 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 concerned:

• Our service providers (such as e.g. banks, insurances), including processors (such as e.g. IT providers);
• dealers, suppliers, subcontractors and other business partners;
• clients;
• domestic and foreign authorities or courts;
• the media;
• the public, including users of our website and social media;
• competitors, industry organizations, associations, organizations and other bodies;
• other parties in possible or pending legal proceedings;

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 any country in which our service providers are located.

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 anonymized, 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 solutions, access controls and restrictions, encryption of data carriers and transmissions and pseudonymisation.

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 performance 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 website cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).

9. Profiling [and Automated Individual Decision-Making]

Vorhall KLG does not currently use profiling.

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 personal 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 consequences 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 verified 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 com- plaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner.

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Disclaimer:
This data protection statement is based on the freely available template "General Privacy Policy Version 2.01a" from datenrecht.ch.