1. Introduction

In this Privacy Policy, we—Silac AG, Euthalerstrasse 40, 8844 Euthal (hereinafter “we” or “us”)—explain how we collect and process personal data.

The purpose of this information is

• comprehensive information about how we process your personal data;
• an explanation of your rights regarding the processing of your personal data; and
• Providing the contact information for the entity responsible for processing your personal data and for the data protection officer at Silac AG.

Your trust is important to us, which is why we take data protection seriously and ensure appropriate security measures are in place. We are committed to handling your personal data responsibly. Of course, we comply with the provisions of the Federal Act on Data Protection (DSG), the Ordinance to the Federal Act on Data Protection (VDSG), and the Telecommunications Act (FMG). the European General Data Protection Regulation (GDPR), and, where applicable, other data protection regulations.

To help you understand what personal data we collect from you and for what purposes we use it, please review the information below.

2. What personal data do we process, and for what purpose?

Depending on your activity, we process the following personal data:

2.1 Visiting the Website

When you visit our websites, our servers temporarily store each visit in a log file. The following data is collected automatically without any action on your part and is stored by us until it is automatically deleted (no later than 12 months):

• the IP address of the requesting computer (truncated);
• the name of your Internet service provider (usually your Internet service provider);
• the date and time of access;
• the name and URL of the file accessed;
• the page and URL of the website from which you were redirected to our websites and, if applicable, the search term used;
• the country from which our website is accessed;
• your computer’s operating system and the browser you are using (provider, version, and language);
• the transmission protocol used (e.g., HTTP/1.1).

This data is collected and processed for the purpose of enabling the use of our websites (establishing a connection), ensuring long-term system security and stability, optimizing our online offerings, and for internal statistical purposes.

Only in the event of an attack on the network infrastructure or if there is suspicion of other unauthorized or abusive use of the website will the IP address be analyzed for investigative and defensive purposes and, if necessary, used in the context of criminal proceedings for identification and for civilor criminal action against the users in question.

The legal basis is our legitimate interest, as defined in Article 6(1), first sentence, subparagraph (f) of the GDPR, in providing a stable and fully functional website.

Finally, when you visit our websites, we use cookies and other cookie-based technologies. For more information, please see the “Cookies” section.

2.2 When establishing and maintaining a customer relationship

When establishing and maintaining a customer relationship, we process the following personal data:

• Last Name, First Name
• Address and/or email address
• Date of Birth
• Phone number

This data processing is necessary to enter into a contractual relationship with us.

In addition, this data is used to maintain our business relationship with you, provide our services, deliver products, and issue invoices.

If the customer is a legal entity, we process the contact information of its employees—such as their names and email addresses—for the purposes mentioned above.

The legal basis is the necessity for the performance of the contract within the meaning of Article 6(1)(b) of the EU GDPR.

3. From what sources do we collect your personal data?

Generally, we collect personal data directly from you (e.g., through forms, in the course of your communication with us, in connection with contracts, when you use the website, at trade shows, etc.).

To the extent that this is not prohibited, we also obtain data from publicly available sources (e.g., debt collection registers, land registries, commercial registries, the media, or the Internet, including social media) or receive data from government agencies and other third parties.

The categories of personal data we receive about you from third parties include, in particular, information from public records, information we obtain in connection with administrative and judicial proceedings, information related to your professional roles and activities, information about you in correspondence and meetings with third parties, credit reports, and information about you provided to us by people in your circle so that we can enter into or execute contracts with you or involving you.

4. Location

Your personal data is stored in Switzerland and/or in the EU/EEA.

5. Cookies

A cookie is a small piece of data stored in text files that are placed on your browser or another device when websites are loaded in the browser. Cookies are used to “remember” you and your preferences when you visit our website, either for a single visit (using a “session cookie”) or for multiple repeat visits (referred to as a “persistent cookie”). A session cookie is deleted when you close your browser or after a short period of time. A persistent cookie is stored for a specific period of time, after which it expires and is deleted.

Neither the technical data we collect nor cookies generally contain any personal data. However, personal data that we or third-party providers we have commissioned store about you (e.g., if you have a user account with us or these providers) may be linked to the technical data or to the information stored in cookies and derived from them, and thus potentially linked to you personally.

We use session cookies and persistent cookies on our website to provide our users with a consistent and efficient experience. Cookies also perform functions that allow users to remain logged in to the website, if applicable.

There are generally the following types of cookies:

• Strictly Necessary: These cookies are essential for enabling you to use our website and its features. The information collected by these cookies relates to the operation of the website, such as language detection, the website’s scripting language, and security tokens used to maintain secure areas of the website.
• Performance and Analytics: These cookies collect anonymous information about how you use our website, such as which pages you visit most often, whether you receive error messages, and how you arrived at our website. They are also used to track details such as the number of unique visitors and page views in order to improve the user experience. The information collected by these cookies is used solely to improve the user experience on my website and never to identify you. These cookies are sometimes set by trusted third-party providers.
• Functionality: These cookies store the choices you have made, such as the country from which you are visiting our website and any changes you have made to the text size or other customizable parts of web pages, to enhance your experience with our website and make your visits more personalized and enjoyable. The information collected by these cookies may be anonymized and cannot be used to track your browsing activity on other websites.
• Third-party / embedded content: These cookies enhance the user experience on the website. These cookies allow you to share your activities on our website with social media platforms such as Facebook and Twitter. We have no control over the information collected by these cookies.

Our website uses only functional cookies.

The legal basis for this is our legitimate interest under Article 6(1)(f) of the GDPR in providing a fully functional website, as well as your consent, which you can provide via the cookie management tool on the website.

6. Third-Party Plug-ins

Our website may use content from third-party providers (so-called plug-ins). We use LinkedIn, Facebook, Instagram, Vimeo, and Google Maps.

When you are on the website, a connection may be established with the respective website. This transmits the content of the buttons to your browser, which then integrates it into the website. As a result, the respective provider receives the information that you have visited the website. It does not matter whether you are a member of a social network or are not logged in. Furthermore, information is automatically collected by the website regardless of whether you actually use the embedded content. The following data may be transmitted in this context: IP address, browser information and operating systems, screen resolution, installed browser plugins (e.g., Adobe Flash Player), the visitor’s origin (if you followed a link), and the URL of the current page.

If you are logged in to a social network while using our website, information about your visit to the website may be linked to your account information and stored. If you are a member of a social network and do not want this data to be transmitted, you must log out of the social network before visiting our website.

We have no control over the scope of the data collected by social networks. For information on the nature, scope, and purpose of data processing, as well as details regarding the further processing of your data, your rights in this regard, and the settings available to protect your privacy, please refer to the privacy policies of the respective social networks. You also have the option of blocking social media plugins using add-ons in your browser, thereby preventing the transfer of data.

• LinkedIn: Our website uses features from the LinkedIn network. The provider is LinkedIn Inc. (U.S.). Every time you visit one of our pages that contains LinkedIn features, a connection is established to LinkedIn’s servers. This informs LinkedIn that you have visited our website using your IP address. If you click the LinkedIn “Recommend” button while logged into your LinkedIn account, LinkedIn can associate your visit to our website with you and your account. Please note that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it is used by LinkedIn.

For more information, please see LinkedIn’s Privacy Policy at: https://www.linkedin.com/legal/privacy-policy.

• Facebook: Our pages include plugins from the social network Facebook, provided by Meta Platforms Inc. (U.S.). You can recognize the Facebook plugins by the Facebook logo on our page. You can find an overview of Facebook plugins here: http://developers.facebook.com/docs/plugins/.

When you visit our website, the plugin establishes a direct connection between your browser and the Facebook server. This informs Facebook that you have visited our site using your IP address. This allows Facebook to associate your visit to our site with your user account. Please note that, as the provider of this website, we have no knowledge of the content of the data transmitted or how Facebook uses it. For more information, please refer to Facebook’s Privacy Policy at http://de-de.facebook.com/policy.php.

If you do not want Facebook to associate your visit to our pages with your Facebook account, please log out of your Facebook account.

• Instagram: Our website incorporates plugins from the social network Instagram, provided by Meta Platforms Inc. (U.S.). You can recognize the Instagram plugins by the Instagram logo on our website.

When you visit our website, the plugin establishes a direct connection between your browser and the Instagram server. This informs Instagram that you have visited our site using your IP address. This allows Instagram to associate your visit to our site with your user account. We would like to point out that, as the provider of this website, we have no knowledge of the content of the data transmitted or how Instagram uses it.

For more information on this topic, please see Instagram’s Privacy Policy at: https://help.instagram.com/155833707900388

If you do not want Instagram to be able to associate your visits to our pages with your Instagram account, please log out of your Instagram account.

• Vimeo: On our website, you will also find a link to the platform https://vimeo.com/silac. We have no control over the data processing carried out by com, Inc., 330 West 34th Street, 5th Floor, New York, New York 10001.
• You can view Vimeo’s privacy policy here: https://vimeo.com/privacy.
• Google Maps: To display interactive maps directly on our website and ensure a convenient user experience with the map feature, we integrate Google Maps, provided by Google LLC (U.S.), into our website. To use these services, the user’s IP address is transmitted to Google. The IP address is required to display this content but is used solely for the purpose of delivering it. Google does not collect your location data without your consent (typically as part of your device settings).

You can view Google’s privacy policy here: https://policies.google.com/privacy.

7. Is personal data shared with third parties?

We share your personal data with the following categories of recipients:

• Service Providers: We work with service providers in Germany and abroad who process data about you on our behalf or under joint responsibility with us, or who receive data about you from us under their own responsibility (e.g., IT providers, shipping companies, advertising service providers, login service providers, etc.).

We disclose to these service providers the data necessary for the services they provide, which may also pertain to you. These service providers may also use such data for their own purposes, e.g., information about outstanding debts and your payment history in the case of credit reporting agencies, or anonymized information to improve their services. In addition, we enter into contracts with these service providers that include provisions for the protection of your personal data. Our service providers may also process data regarding how their services are used, as well as other data generated in the course of using their services, as independent data controllers for their own legitimate interests (e.g., for statistical analysis or billing). Service providers provide information about their independent data processing activities in their own privacy policies.

• Government Agencies: We may disclose personal data to government agencies, courts, and other authorities both domestically and abroad if we are legally obligated or authorized to do so, or if it appears necessary to protect our interests. The government agencies then process this data under their own responsibility.

All of these categories of recipients may, in turn, engage third parties, which means that your data may also be made available to them. We can restrict the processing carried out by certain third parties (e.g., IT providers), but not by other third parties (e.g., government agencies, banks, etc.).

8. Transfer of Personal Data Abroad

Personal data is processed within the EU/EEA. If a recipient is located in a country without adequate legal data protection, we contractually require the recipient to comply with applicable data protection laws (for this purpose, we use the European Commission’s revised Standard Contractual Clauses, which are available here: [https://eur-lex .europa.eu/eli/dec_impl/2021/914/oj?] ), unless the recipient is already subject to a legally recognized framework ensuring data protection and we cannot rely on an exception. An exception may apply, in particular, in the case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires such disclosure, if you have given your consent, or if the data in question has been made publicly available by you and you have not objected to its processing.

Without exception, the recipients are located in Switzerland, the EU, or the EEA.

Please also note that data exchanged over the Internet is often routed through third countries. Your data may therefore be transferred abroad even if the sender and recipient are located in the same country.

9. Note on Data Transfers to the United States

Some of the third-party service providers mentioned in this Privacy Policy are based in the United States. For the sake of completeness, we would like to point out to users residing or headquartered in Switzerland that U.S. authorities have surveillance measures in place that generally allow for the storage of all personal data pertaining to any individual whose data has been transferred from Switzerland to the United States. This occurs without differentiation, restriction, or exception based on the intended purpose and without an objective criterion that would allow the U.S. authorities’ access to the data and its subsequent use to be limited to very specific, strictly limited purposes that could justify the intrusion associated with both access to and use of this data. Furthermore, we note that in the United States, there are no legal remedies available to data subjects from Switzerland that would allow them to obtain access to the data concerning them and to have it corrected or deleted, nor is there any effective judicial protection against the general access rights of U.S. authorities. We explicitly draw the attention of the data subjects to this legal and factual situation so that they can make a fully informed decision regarding their consent to the use of their data.

We would like to inform users residing in Switzerland that, from Switzerland’s perspective—due in part to the issues mentioned in this section—the United States does not provide an adequate level of data protection. To the extent that we have explained in this Privacy Policy that recipients of data (such as, for example, Google) are based in the United States, we ensure—through contractual arrangements with these companies and, where necessary, additional appropriate safeguards that protect the rights of individuals whose personal data is transferred to a third country—that your data is protected to an adequate standard by our partners.

10. Your Rights

You may object to the processing of your data at any time. You also have the following rights:

Right of Access: You have the right to request access to your personal data stored by us at any time and free of charge, provided that we are processing such data. This allows you to verify what personal data we are processing about you and to ensure that we are using it in accordance with applicable data protection regulations.

Right to Rectification: You have the right to have inaccurate or incomplete personal data corrected and to be notified of the correction. In such cases, we will inform the recipients of the data in question of the changes made, unless this is impossible or would involve a disproportionate effort.

Right to Erasure: You have the right to have your personal data erased under certain circumstances. In some cases, the right to erasure may not apply.

Right to Restrict Processing: Under certain conditions, you have the right to have us restrict the processing of your personal data.

Right to Object: You have the right to object to the processing of your data, particularly in the case of direct marketing.

Right to Data Portability: Under certain circumstances, you have the right to receive the personal data you have provided to us, free of charge, in a machine-readable format.

Right to Withdraw Consent: You generally have the right to withdraw your consent at any time, effective for the future. Processing activities carried out in the past based on your consent do not become unlawful as a result of your withdrawal.

Right to File a Complaint: You have the right to file a complaint with a competent supervisory authority, for example, regarding the manner in which your personal data is processed.

11. Retention Period for Personal Data

We retain personal data for as long as it is needed for the purpose for which it was collected, or for a period required by applicable laws, regulations, or contractual agreements, and for as long as we have an overriding interest in retaining it. After that, the data will be deleted.

Data retention requirements, which oblige us to retain data, stem from accounting regulations and tax laws. According to these regulations, business correspondence, executed contracts, and accounting documents must be retained for up to 10 years.

The legal basis for this data processing is our legitimate interest, within the meaning of Article 6(1)(f) of the EU GDPR, in the efficient management of user data.

12. Data Security

We implement appropriate technical and organizational security measures to protect personal data from unauthorized access and misuse. These include IT and network security solutions, access restrictions, encryption of data storage media and data transmissions, policies, training, and audits.

If third parties have access to our data, special measures are taken, as specified in the data processing agreement.

13. Contact

If you have any questions about data protection, would like to request information, wish to object to the processing of your data, or would like to have your data deleted, please contact us by sending an email to info@silac.ch.

Please send your inquiry by mail to the following address:

Silac AG
Euthalerstrasse 40
8844 Euthal

The representative of the data controller in the EU is:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

14. Adjustment

This Privacy Policy is not part of any contract with you. We may update this Privacy Policy at any time. The version published on www.silac.ch is the current version.

Last updated: October 27, 2023