1. Preamble and Consent
This Website Privacy Policy (“Policy“) governs your relationship with the website Keyfocus.ch (the “Website“) and our dedicated pages on the following social media networks and platforms: Facebook, X, Instagram, YouTube, and LinkedIn, all operated by Keyfocus and its affiliates (“Keyfocus“, “we“, “our“), with its registered office at Chemin de Rossan 30A, 1132 Lully. Please read this Policy carefully, which explains how your personal data will be collected, used, and protected, before using the Website and our dedicated social media pages and platforms. Your access to and use of the Website and social pages is conditioned on your acceptance of and compliance with this Policy. By Browse our Website, you agree to be bound by this Policy and you accept and consent to the collection, use, and processing of personal data in accordance with this Policy. If you do not agree to the terms of this Privacy Policy, we kindly ask you not to use our Website or our dedicated social media pages. Please also note that you have the right to withdraw your consent at any time, provided that such withdrawal:
- Will not affect the lawfulness of processing based on your consent before its withdrawal;
- May prevent you from using certain functionalities of our Website or our dedicated social media pages.
2. Data Protection Officer
Feel free to contact us at site@keyfocus.ch if you have any questions. We would be happy to answer any questions.
3. General Principles
3.1 Information provided by our Website and social media platforms
- 3.1.1 Information about the services offered by our organization, its subsidiaries, and its members;
- 3.1.2 Different channels to get in touch with us (contact forms, links to social media accounts, etc.);
- 3.1.3 Information about conferences and other events;
- 3.1.4 Links to other websites and social media platforms;
- 3.1.5 Information on job vacancies and an associated application form.
3.2 Collection and Processing of Personal Data
This Privacy Policy sets out our policies and procedures regarding the collection and processing of any information identifying you (i.e., “Personal Data“), which you might, for example, provide to us when visiting our Website or social media platforms or when using one of the services described in paragraph 3.1.
3.3 Application of the Policy
This Privacy Policy applies only to our Website and our dedicated social media pages. Please also note that if you access our dedicated social media pages, the information you provide will also be subject to the social media platform operator’s privacy policy.
3.4 Offline Services
This Privacy Policy does not apply to offline services offered by our organization.
4. Personal Data We Collect and Why We Collect It
A. Sources of Collection
- 4.1 The data we collect via our Website and social media is divided into three main categories:
- 4.1.1 Cookies, analytics, and other similar tools (hereinafter B.),
- 4.1.2 Personal Data you provide to us (hereinafter C),
- 4.1.3 Data from other sources (hereinafter D).
B. Cookies, Analytics, and Other Similar Tools
a) What are cookies and what information do they collect?
- 4.2 Cookies are files containing a small amount of data that are sent to your browser from a website and stored on your device (computer or mobile device). Tracking technologies are also used to collect and track information and to improve and analyze our Website.
- 4.3 Through cookies and other tracking technologies, we may collect Personal Data about you when you visit our Website or our dedicated social media pages. In particular, we may record usage data when you view or click on content.
- 4.4 The following information and Personal Data are collected via the cookies and other tracking technologies we use:
- 4.4.1 IP address of the requesting internet device,
- 4.4.2 Location of the requesting internet device based on the IP address,
- 4.4.3 Date and time of access,
- 4.4.4 Resources accessed on the Website,
- 4.4.5 Name and URL of the retrieved file,
- 4.4.6 Website/application from which the access was made (referrer URL).
- 4.5 The following information and Personal Data are collected via your web browser:
- 4.5.1 The browser you use,
- 4.5.2 If necessary, the operating system of your internet-connected computer and the name of your access provider.
- 4.6 To control/limit the collection of this information, you can:
- 4.6.1 If available, configure your browser to refuse all cookies or to indicate when a cookie is being sent,
- 4.6.2 When accessing our Website, select which cookies you allow and which cookies you wish to block,
- 4.6.3 Delete cookies and clear your Browse data directly from your browser settings. However, please note that if you do not accept some cookies, you may not be able to use certain features of our Website.
- 4.7 List of cookies and scripts we use:
- 4.7.1 Essential Cookies: Cookies used to operate our Website, such as:
- Cookies that store your cookie settings for this Website.
- 4.7.2 Analytics Cookies: Cookies used to collect standard Internet log information and visitor behavior patterns, such as:
- 4.7.2.1 Google Analytics, which allows us to know, for example, the number of visitors to different parts of the Website and to monitor Website traffic, identify potential service problems, improve our services, and generate statistics.
- 4.7.2.2 Google Tag Manager, which is a Google tool related to Google Analytics enabling personalized tracking.
- 4.7.2.3 Google Doubleclick, which is a Google tool related to Google Analytics allowing Google to provide personalized advertising.
- 4.7.1 Essential Cookies: Cookies used to operate our Website, such as:
b) Why we collect information via cookies (purpose)?
- 4.8 We use cookies and the Personal Data collected to:
- 4.8.1 Allow access to our Website,
- 4.8.2 Make the functionalities of our Website available to you and offer you additional features,
- 4.8.3 Improve the Website or our dedicated social media pages,
- 4.8.4 Store information about your preferences, allowing us to customize our Website according to your individual interests,
- 4.8.5 Speed up your searches,
- 4.8.6 Compile behavioral and statistical information about the use of our Website or our dedicated social media pages, particularly to estimate our audience size and usage patterns,
- 4.8.7 Produce aggregated information that does not identify you,
- 4.8.8 Identify and record your usage, recognize you when you return to our Website, track activity on our Website, and retain certain information.
- 4.9 We ensure that Personal Data collected via Google Analytics, Google Tag Manager, Google Doubleclick does not allow anyone to be identified, even when transferred to third parties such as Google; for information on Google’s or Facebook’s data processing and use, as well as related rights and setting options for protecting your privacy, please refer to the privacy policy of the selected provider.
c) Legal Basis for Processing
- 4.10 The purpose of implementing all of the above is to maintain and monitor the performance of our Website and to constantly seek to improve the site and the services it offers to our users. The legal basis on which we rely to process your Personal Data is Article 6(1)(f) of the GDPR, which allows us to process personal data when necessary for the purposes of our legitimate interests.
- 4.11 Furthermore, cookies and other functionalities mentioned above that would go beyond the purposes of our legitimate interests (e.g., analytics cookies) are implemented based on your acceptance through our cookie banner.
C. Personal Data You Provide to Us
a) What Personal Data do you provide to us?
We collect Personal Data that you voluntarily provide to us when, on our Website, you:
- 4.12.1 Fill out a contact form,
- 4.12.2 Fill out an application form.
- 4.13 This data may include your names, employer, email address, phone number, as well as all data contained in your CV, such as title, gender, date of birth, nationality, marital status, photo, home and work addresses, country of residence, professional details, and qualification records.
b) Why we collect such Personal Data (purpose)?
- 4.14 We use the Personal Data you provide to us for the following purposes:
- 4.14.1 To allow you to participate in the interactive features of the Website when you choose to do so,
- 4.14.2 To provide customer support,
- 4.14.3 To evaluate your application,
- 4.14.4 To fulfill the purposes for which you provide the data.
c) Legal Basis for Processing
- 4.15 The legal basis on which we rely to process the Personal Data you provide to us is Article 6(1)(a) of the GDPR, which allows us to process personal data when the data subject has given consent to the processing of his or her personal data.
D. Personal Data Collected About You from Other Sources
a) What information do we collect from other sources?
- 4.16 We may collect Personal Data about you available on Facebook if you are logged into your account when Browse our Website.
b) Why we collect information via these other sources?
- 4.17 We collect and use Personal Data about you available on Facebook to perform behavioral retargeting, in a manner that does not allow anyone to be identified even when transferred to Facebook; for information on Google’s or Facebook’s data processing and use, as well as related rights and setting options for protecting your privacy, please refer to the privacy policy of the selected provider.
c) Legal Basis for Processing
- 4.18 The legal basis for collecting your Personal Data from the sources mentioned above is your acceptance through our cookie banner, specifically the Facebook pixel cookie. The legal basis on which we rely to process your Personal Data is Article 6(1)(a) of the GDPR.
5. Personal Data Collected by Third Parties (Link to Other Websites and Social Media)
- 5.1 When we provide links to other organizations’ websites, this privacy policy does not cover how that organization processes your Personal Data. We encourage you to read the privacy policies relating to the other websites you visit.
- 5.2 Our Website and our dedicated social media pages contain links that direct you to social networks such as Facebook, X, Instagram, YouTube, and LinkedIn (the “Social Network“) or to another website, in order to connect with the content displayed on these platforms. When you access a Social Network or another website via our Website or one of our dedicated social media pages, the responsibility for data protection compliance must be guaranteed by the respective providers.
- 5.3 If you establish a connection with the Social Network of your choice or another website, your browser connects directly to the provider’s servers. Through this integration, the Social Network or the other website receives information that your browser previously accessed the corresponding page of our Website or our dedicated social media page, even if you do not have a profile or are not currently logged into your account. This information (including your IP address) will be transmitted directly from your browser to the provider’s server and stored there. If you are logged into your account, the provider can immediately attribute the visit to our Website or our dedicated social media page to your profile. If you interact with the Website or our dedicated social media page, for example by clicking a “Like” or “Share” button, this information will also be transmitted directly to the provider’s server and stored there.
- 5.4 For information on the purpose and scope of data collection and further data processing by the Social Network or the requested other website, as well as related rights and setting options for protecting your privacy, please refer to the privacy policy of the selected provider.
6. Sharing Your Personal Data with Third Parties
- 6.1 As mentioned above, we may compile usage statistics relating to our Website or our dedicated social media pages, particularly based on your Personal Data.
- 6.2 Your Personal Data may be transferred to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Keyfocus.ch‘s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, in which personal information held by Keyfocus.ch about our Website users is among the assets transferred.
- 6.3 We may give certain independent and affiliated subcontractors access to the Personal Data you have provided to us via our Website or our dedicated social media pages to assist us in the operation of our Website or our dedicated social media pages, as well as in data management and marketing activities. As of now, there are no partners.
- 6.4 We will take all necessary steps to ensure that your Personal Data is treated securely and in accordance with this privacy policy and applicable laws. All such contractors are required to sign contracts in which they undertake to protect Personal Data using procedures similar to ours, unless otherwise provided by this privacy policy.
- 6.5 The purpose of sharing your Personal Data with the third parties mentioned above is to support our business and to constantly maintain and improve our Website and the services it offers to our users. The legal basis on which we rely to process your Personal Data is Article 6(1)(f) of the GDPR, which allows us to process personal data when necessary for the purposes of our legitimate interests.
7. Transfer of Your Personal Data to Authorities
- 7.1 We may also transfer your Personal Data (including your communications) if we believe it is necessary for security reasons, to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm other users of our Website or our dedicated social media pages. Therefore, we may share or transfer your Personal Data to investigate, respond to, and resolve complaints and issues relating to our Website or our dedicated social media pages.
- 7.2 It is possible that we may be required to disclose your Personal Data if required by law or if we have good reason to believe that disclosure is necessary to:
- 7.2.1 Investigate, prevent, or take action regarding suspected or actual illegal activities or to assist law enforcement agencies,
- 7.2.2 Enforce our agreements with you,
- 7.2.3 Investigate and defend ourselves against any third-party claims or allegations,
- 7.2.4 Protect the security or integrity of our Website or our dedicated social media pages,
- 7.2.5 Exercise or protect the rights and safety of our users, our staff, or others.
- 7.3 We try to inform users of legal requests regarding their Personal Data where appropriate in our judgment and technically feasible, unless prohibited by law or court order or where the request is an emergency. We may challenge such requests when we believe, in our discretion, that the requests are too broad, vague, or lack adequate authority, but we do not promise to challenge every request.
- 7.4 The purpose of sharing your Personal Data with the authorities mentioned above is to support our obligation within the meaning of Article 6(1)(c) of the GDPR, which allows us to process personal data when necessary to comply with a legal obligation to which we are subject.
8. No Commercial Disclosure of Your Personal Data
- 8.1 We will not sell your Personal Data to third parties. We will not share or otherwise make available your Personal Data to third parties, except as otherwise provided in this Privacy Policy.
9. How and Where We Store Your Personal Data
- 9.1 We take data protection issues seriously and have chosen to store your Personal Data on the servers of Oriented.net GmbH, located in Switzerland.
10. Cross-Border Data Transfer
- 10.1 For some of the third-party service providers, we may transfer your data to one of their databases outside of Switzerland or the European Economic Area, potentially to countries that may not offer an adequate level of protection for your Personal Data compared to that provided in Switzerland or the European Economic Area. In such a case and unless otherwise provided by this Privacy Policy, we enter into agreements with such third parties ensuring an adequate level of protection for your Personal Data.
- 10.2 By providing us with your Personal Data or accepting analytical cookies, you agree that we may transfer, store, and process your Personal Data outside of Switzerland and the European Economic Area – particularly to the United States – and acknowledge that appropriate safeguards are in place to protect your Personal Data in accordance with this Privacy Policy.
11. Security of Your Personal Data
- 11.1 We implement commercially reasonable efforts to prevent unauthorized exposure or disclosure of your Personal Data. In particular, we put in place and maintain measures (including administrative, physical, and technical safeguards) to manage the unauthorized disclosure or exposure of your Personal Data.
- 11.2 In the event of a data breach, or if we suspect a data breach, we will (i) do our best to notify you promptly, when technically possible, and (ii) cooperate with you to investigate and resolve the data breach, including, without limitation, providing you with reasonable assistance in notifying affected third parties. We will promptly give you access to records related to a data breach that you may reasonably request; provided that we are not required to provide you with records belonging to other users or compromising their security.
- 11.3 In the event of a data breach, or if we suspect a data breach, we will also notify the competent authorities in accordance with applicable law.
12. Managing Your Personal Data (Your Rights)
- 12.1 Right to access, update, or delete information we hold about you: Wherever possible, you can access your Personal Data, update it, or request its deletion by contacting us at: site@keyfocus.ch
- 12.2 Right of rectification: You have the right to have your Personal Data rectified if it is inaccurate or incomplete.
- 12.3 Right to object: You have the right to object to our processing of your Personal Data.
- 12.4 Right of restriction: You have the right to request that we restrict the processing of your Personal Data.
- 12.5 Right to data portability: You have the right to receive a copy of the Personal Data we hold about you in a structured, machine-readable, and commonly used format.
- 12.6 Right to withdraw consent: You have the right to withdraw your consent at any time when we rely on your consent to process your Personal Data.
- 12.7 Right to lodge a complaint with an authority: You have the right to lodge a complaint with a data protection authority regarding our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or Switzerland.
- 12.8 Please note that we may ask you to prove your identity before responding to requests based on the preceding rights or otherwise related to your Personal Data.
13. Retention of Your Personal Data
- 13.1 We retain the Personal Data you provide to us to the extent necessary to allow you to access and use the features of our Website or our dedicated social media pages (such as our newsletters), as well as to the extent necessary to comply with our legal obligations (e.g., if we are required to retain your data to comply with applicable laws), to resolve disputes, and to enforce our legal agreements and policies.
- 13.2 The retention period for cookies depends on their purpose and is the same for everyone.
- 13.3 We may retain depersonalized (anonymous) information after the deletion of your Personal Data.
14. Security of Your Personal Data
- 14.1 The security of your Personal Data is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable technical and organizational means to protect your Personal Data from manipulation, partial or complete loss, and unauthorized access by third parties, we cannot guarantee its absolute security.
15. Personal Data Relating to Children
- 15.1 We do not directly provide services to children and do not proactively collect their Personal Data.
16. Changes to This Privacy Policy
- 16.1 We may modify this Privacy Policy at any time by posting a new version on this page or a subsequent page, without prior notification. If we make changes to this Policy, we will notify you by a notice on the Website’s homepage. By continuing to access or use our Website or our dedicated social media pages after these revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Website and our dedicated social media pages.
- 16.2 However, we will always process your Personal Data in accordance with the Privacy Policy in effect at the time of collection.
- 16.3 The new version will take effect on the date of its publication, which will be indicated at the top of the page as the new effective date.
17. Miscellaneous
- 17.1 Our failure to enforce any right or provision of this Policy will not be considered a waiver of those rights.
- 17.2 If any provision of this Policy is held to be invalid or unenforceable by a court, the remaining provisions of this Policy will remain in effect.
- 17.3 This Policy constitutes the entire agreement between us regarding the Privacy Policy of our Website and our dedicated social media pages, and supersedes and replaces any prior agreements we might have had between us regarding the Website and our dedicated social media pages.
18. Questions or Complaints?
- 18.1 If you have any questions or complaints about this Privacy Policy, please contact us online at site@keyfocus.ch
- 18.2 You can also reach us by mail at Keyfocus.ch, Chemin de Rossan 30A, 1132 Lully, Switzerland.
- 18.3 Please also note that you have the right to lodge a complaint with a supervisory authority if you believe that your Personal Data is not being processed in accordance with this Privacy Policy or applicable regulations.