Privacy Notice
We recognize the importance of your privacy and of transparency in our processing of your personal data.
At Kalssium SA (we, our or Kalssium), we recognize the importance of your privacy and of transparency in our processing of your personal data. This online privacy notice (Privacy Notice) informs you on the personal data we collect and process by using our Services – electronic when subscribing to our newsletter, when using the contact form, through a personal contact from someone inside our organization.
By accessing and using our Services, or otherwise providing us your information, you expressly acknowledge that we may collect and process your personal data in accordance with this Privacy Notice.
Data controller
Kalssium SA, with registered office at Rue de la Porcelaine 11, 1260 Nyon, Switzerland, is responsible for the processing of personal data referred to in this document.
Kalssium manages personal data in accordance with Swiss and EU data protection laws.
Contact us
If you have any questions or comments regarding your personal data or data privacy at CSEM, contact us at:
Kalssium SA
Rue de la Porcelaine 11
1260 Nyon
Switzerland
Phone: +41 79 583 0927
Email: contact@kalssium.com
We have appointed a data protection adviser.
If you believe your personal data has been used in a way that is not consistent with this Privacy Notice, or if you have any questions or queries regarding the collection or processing of your personal data, please contact our data protection advisor at data@kalssium.com.
1. Brief summary of our Privacy Policy
Kalssium SA is responsible for the processing, as controller, of your personal data. This Privacy Notice, however, only applies to our Services – use of our website (www.kalssium.com), or through a personal contact from someone inside our organization –, and not to those of third party providers (even if we link to their services or contents) (see section 2).
We may collect personal data which is provided to us by you, your Organization, or which we collect automatically when you interact with our Services (see section 3).
We process such personal data in compliance with Swiss laws and other laws applicable to us, mainly for the purpose of providing our Services. We may also process your personal data to communicate with you, process your orders and payments, send our newsletter, analyze and improve the use of our Services, comply with our legal obligations, and for the other legitimate purposes indicated in this Privacy Notice (see section 6, as well as sections 4 and 5);
We host your personal data in Switzerland. We do not share it with third parties or transfer it abroad unless this is both necessary for the operation of our Services and permitted by applicable laws. This may for instance be the case when we use service providers or must interact with third parties to conduct our professional activities;
We do not store your personal data for longer than necessary for us to fulfill the purposes set out in this Privacy Notice (see section 9);
We apply security measures and strive to protect your personal data. However, no IT infrastructure is completely secure and we cannot guarantee that our is (see section 10);
You may contact us (data@kalssium.com) to exercise your rights pertaining to your personal data (see section 11 and “Contact us“).
2. Who is responsible for the processing of your personal data
Kalssium SA, rue de la Porcelaine 11, 1260 Nyon, is responsible for the processing, as controller, of your personal data. You will find our contact details above.
This Privacy Notice only applies to processing undertaken by or on behalf of us. Whilst we may provide links to third party websites, contents, or services, we are not responsible for their policies in relation to personal data. In such circumstances, the collection and use of your personal data are governed by the privacy policy of those third party providers, which you should carefully review to learn more about their personal data processing practices.
3. How we collect your personal data
We collect the personal data that you or your Organization provide to us.
We collect the personal data that you provide to us when interacting with us and/or using our Services, for example through web forms you fill, when you subscribe to our newsletter or communicate with us.
Some information is mandatory and some is optional.
It is mandatory that you complete the data fields identified as such. If one or more mandatory data fields are not completed, we will not be able to provide access to our Services. You are not required to complete the optional data fields in order to access our Services. These fields may be completed at any time through your account settings (if you have one).
Certain personal data are also collected in an automated manner.
We also automatically collect personal data, including by means of cookies and other active elements, as further described in this Privacy Notice.
You may define certain authorizations relating to the automatic collection of your personal data when you configure your device or your internet browser according to available functionalities. For more detailed information, please see the Cookie Policy.
4. How we process your personal data
We process your personal data manually or by automated means for the purposes indicated in this Privacy Notice and in accordance with applicable law.
We process your personal data in compliance with applicable law, in particular Swiss data protection laws and, to the extent they apply to us, other data protection legislations, such as the EU General Data Protection Regulation (GDPR) or its equivalent in the United Kingdom, using computers or computer tools, in line with the purposes set out in this Privacy Notice.
We do not process your personal data to create a profile about you (profiling).
We also do not make decisions exclusively on the basis of an automated processing which have legal effects on the data subjects or affect them significantly (automated individual decision).
We may combine your personal data with other information (aggregate) or erase any information that allows us to identify you (anonymize), so that it is no longer considered personal data under applicable data protection law, in which case this Privacy Notice will no longer apply and we may use such data for purposes not contemplated by this Privacy Notice (e.g. for benchmarking or analytics purposes, or to develop and market new services).
We take the technical and organizational appropriate security measures to prevent unauthorized access, disclosure, modification, alteration or destruction of your personal data, as specified in section 10 below.
5. On which legal ground do we process your personal data
We process your personal data only if we have a valid legal ground to do so.
We only process your personal data when it is necessary for the provision of our Services or if we can rely on one of the following legal ground:
- The processing is necessary to fulfill our contractual obligations to you or to take pre-contractual steps at your request (Contractual Necessity);This is the case in particular when processing your personal data is strictly required to provide you with the Services, as further specified in section 6 below. When the GDPR applies, Contractual Necessity is based on Article 6(1)(b) GDPR;
- The processing is necessary for the fulfillment of our legitimate interests, and only to the extent that your interests or fundamental rights and freedoms do not require us to refrain from processing (Legitimate Interest);Our Legitimate Interests include in particular (i) ensuring that our Services are provided in an efficient and secure way (e.g. through internal analysis of the Services’ stability and security, updates and troubleshooting, as well as support services); (ii) improving and developing the Services (including monitoring the use of our Services, and for statistical purposes); (iii) benefiting from cost-effective services (e.g. we may opt to use certain services offered by suppliers rather than undertaking the activity ourselves); and (iv) achieving our corporate goals. When the GDPR applies, Legitimate Interest is based on Article 6(1)(f) GDPR.
- We have obtained your prior consent in a clear and unambiguous manner (Consent);
When the GDPR applies, Consent is based on Article 6(1)(a) GDPR.
- The processing is necessary to comply with our legal or regulatory obligations (Legal Obligation);
Finally, we will process your personal data if we are required by law to do so, as further specified in section 6 below. When the GDPR applies, Legal Obligation is based on Article 6(1)(c) GDPR.
6. Purposes for which we process your personal data
We process your personal data for legitimate and clearly identified purposes.
Your personal data is collected and processed for the purpose of operating the Services and for the other legitimate purposes explicitly specified below, only to the extent relevant to achieve these purposes, and is not further processed in a manner that is incompatible with them.
We process your personal data for the following purposes:
a) To contact you and respond to your queries.
You have the option of contacting us via the contact form, by email, phone, or via personal contact. In this context, we process the data which you provide to us (including your contact information and the subject-matter of the request). This data is used for the purpose of providing you with the requested information and services, based on our Contractual Necessity.
b) To send you our newsletter and other advertising information.
If you subscribe to our newsletter, we will collect your contact details (name and email address) and use it to provide you with our newsletter, based on your Consent. You may unsubscribe from the newsletter service at any time, in which case your contact details will be deleted.
We also process the time of registration and your opt-in confirmation based on our Legal Obligation to demonstrate compliance. We also analyze your use of our newsletter, e.g. whether you have opened it or clicked on certain links, and process this data to optimize and improve our newsletter, based on our Legitimate Interest.
We use the services of third parties to provide our newsletter service, which will have access to your login data in order to provide you with the service.
Independently from your subscription to our newsletter, we may also contact you by email to inform you about our activities if you have previously subscribed to one of our similar Services and if you have not objected to the corresponding use of your email address. You can object to the use of your email address for this purpose at any time by contacting us (see “Contact us“). The legal basis for the corresponding processing of your data is our Legitimate Interest to advertise certain sales offers and activities relating to our previous interactions with you.
c) For internal analysis and statistical purposes in order to improve our Services.
Unless you object to such processing, we may process your personal data, in particular data relating to your use of our Services and your habits and preferences (e.g. the content you accessed, date and time of access and your preferences), for internal analysis and statistical purposes, in order to better understand the needs of our users, to optimize their experience, and in general to improve the ergonomics and functionality of our website. You may object to such processing activities at any time (see our section 11 for additional information on your rights).
We do not link this information to you. We use analytics tools provided by known market providers – such as Google Analytics– which provide to us only aggregated, non-identifiable data. The privacy policy of those service providers is applicable in this context.
You will find additional information here in relation to the use of cookies for this purpose, including on the duration for which data collected are stored.
d) To comply with our other Legal Obligations or for other Legitimate Interests.
We may further process your personal data if we have a Legal Obligation to do so or for other Legitimate Interests. This will for instance be the case if we need to disclose certain information to public authorities or retain such information for tax or accounting purposes, or for the establishment, exercise or defense of legal claims.
The personal data that we process for this purpose are those that we collected for one of the purposes indicated elsewhere in this section. We retain the personal data for the duration of the legal obligation imposed on us.
e) If we have obtained your consent.
In addition to the above, we may process your personal data if we have obtained your prior unambiguous consent for specific purposes. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.
7. The circumstances in which we share your personal data with third parties
We may share your personal data with third parties if this is necessary for the operation of our Services, if there is a legal obligation or permission to do so, or if there is another valid reason to do so.
We may share your personal data with third parties in connection with the operation of the Services or our business operations and with subcontractors such as IT service providers, cloud service providers, database providers, automated marketing solutions providers and consultants, including Google and Infomaniak as hosting providers. Detailed information on these providers can be found in the section 6.
We may also disclose your personal data to third parties where we have a legal obligation to do so or a legitimate interest in doing so.
We may also disclose your personal data where we have a legitimate interest in doing so, for example (i) to respond to a request from a judicial authority or in accordance with a legal obligation; (ii) to bring or defend against a claim or lawsuit; or (iii) in the context of restructuring, in particular if we transfer our assets to another company.
8. International transfers
Your personal data is stored in Switzerland, but may in certain circumstances be disclosed in other countries.
We store your personal data on servers located in Switzerland.
In principle, we do not transfer your personal data to other countries or make it available there. However, in certain circumstances, in particular in connection with the operations of our subcontractors, your personal data may be made available to recipients located abroad (e.g. Google is headquartered in the U.S, from which locations some data may be available). In such cases, we will ensure that suitable safeguards are in place, in accordance with applicable data protection laws, for instance by relying on standard contractual clauses adopted by the European Commission.
If you transmit information and data to us, you are expressly deemed to consent to such data transfers. You may request additional information in this regard and obtain a copy of the relevant safeguards upon request by sending a request to the contact address indicated in section “Contact us “.
9. How long we store your personal data?
Your personal data will not be stored longer than necessary.
We will erase or anonymize personal data as soon as it is no longer necessary for us to fulfill the purposes set out in section 6 of this Privacy Notice. This period varies, depending on the type of data concerned and the applicable legal requirements. More information on each type of processing can be found in section 6 above.
In view of the legal obligations incumbent upon us, certain information relating in particular to the contractual relationship must be retained for at least 10 years.
10. Security
We maintain physical, technical and procedural safeguards to keep secure your personal data.
We are committed to the security of your personal data, and have in place physical, administrative and technical measures designed to keep secure your personal data and to prevent unauthorized access to it. We restrict access to your personal data to those persons who need to know it for the purpose described in this Privacy Notice. In addition, we use standard security protocols and mechanisms to exchange the transmission of data. When you enter information on our Platforms, we encrypt it using Transport Layer Security (TLS) technology.
Although we take appropriate steps to protect your personal data, no IT infrastructure is completely secure. Therefore, we cannot guarantee that data you provide to us is safe and protected from all unauthorized third-party access and theft. We waive any liability in this respect.
The internet is a global environment. As a result, by sending information to us electronically, such data may be transferred internationally over the internet depending upon your location. Internet is not a secure environment and this Privacy Notice applies to our use of your personal data once it is under our control only. Given the inherent nature of the internet, all internet transmissions are done at your own risk.
If we have reasonable reasons to believe that your personal data have been acquired by an unauthorized person, and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other channel of communication.
11. Your rights with regard to the processing of your personal data
You have the right to access your personal data we process and may request in particular that they be removed, updated, or rectified.
You may contact us directly to exercise your rights. Unless otherwise provided by law, you have the right to know whether we are processing your personal data, to know the content of such personal data, to verify its accuracy, and to the extent permitted by law, to request that it be supplemented, updated, rectified or erased. You also have the right to ask us to cease any specific processing of personal data that may have been obtained or processed in breach of applicable law, and you have the right to object to any processing of personal data for legitimate reasons.
If you request us to delete your personal data from our systems, we will do so unless we need to retain your data for legal or other legitimate reasons. Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request.
Where we rely on your consent to process your personal data, we will seek your freely given and specific consent by providing you with informed and unambiguous indications relating to your personal data. You may revoke at any time such consent (without such withdrawal affecting the lawfulness of processing made prior to).
The above does not restrict any other rights you might have pursuant to applicable data protection legislation under certain circumstances. In particular, if the GDPR applies to the processing of your personal data the GDPR grants you certain rights as a data subject if the respective requirements are met:
- Right of access (Art. 15 GDPR) – you have the right to access and ask us for copies of your personal data.
- Right to rectification (Art. 16 GDPR) – you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure (Art. 17 GDPR) – you have the right to ask us to erase your personal data in certain circumstances.
- Right to restriction of processing (Art. 18 GDPR) – you have the right to ask us to restrict the processing of your personal data in certain circumstances.
- Right to data portability (Art. 20 GDPR) – you have the right to ask that we transfer in a structured, commonly used and machine-readable format the personal data you gave us to another organization, or to you, in certain circumstances.
- Right to object to processing (Art. 21 GDPR) – you have the right to object to the processing of your personal data which is based on our Legitimate Interests, in certain circumstances. In such case, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defense of legal claims.
As a rule, you are not required to pay any charge for exercising your rights and we will respond to your request within one month.
You will find further details of your rights in sections 4 and 6 of this Privacy Notice in connection with each processing activity we perform. If you want to exercise any of your rights, or want additional information about them, please contact us using the contact detailed listed in “Contact us“.
You have the right to lodge a complaint with the competent authority.
If you are not satisfied with the way in which we process your personal data, you may lodge a complaint with the competent data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in addition to the rights described above.
Although this is not required, we recommend that you contact us first, as we might be able to respond to your request directly.
12. Updates
This Privacy Notice may be subject to amendments. Any changes or additions to the processing of personal data as described in this Privacy Notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you (including by email and/or via the Platforms, e.g. banners, pop-ups or other notification mechanisms). If you do not agree to the changes made, you must stop accessing and/or using the impacted Services.