GIST Impact Privacy Statement
GIST Advisory Switzerland S.A. doing business as GIST Impact (“GIST Impact”, “we” or “us”) provides various digital and consultancy services (jointly “Services”) for the purpose of measuring and managing the impact of companies and value chains on people, the environment, society and the economy. In this Privacy Statement we explain how we process the data of our users using the Services or other parts of our website.
In this Privacy Statement, the word “User” or “you” refers both to unregistered and registered users.
This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on our website.
This Privacy Statement applies to processing of personal data carried out by GIST Impact as data controller. For clarity we emphasise that this Privacy Statement does not address and is not applicable to the processing of personal data collected by third parties.
GIST IMPACT’S CONTACT DETAILS
Name: GIST Advisory Switzerland S.A.
Company ID: CH-5184.108.40.2065-9
Correspondence address: 21 Avenue Perdtemps, 1260 Nyon, Switzerland
E-mail address: email@example.com
PERSONAL DATA PROCESSED AND SOURCES OF DATA
You may register to the Services as a User by providing us with your email address and other relevant information as instructed on the Services. You may also use the Services as an unregistered User.
The personal data collected and processed by us in connection with your registration to and use of the Services can be divided into two general data categories: User Data and Analytics Data.
User Data is personal data collected directly from you or generated by our Services or us based on your use of the Services. We may collect User Data from our Users in a variety of ways, including, when they register to and use the Services, subscribe to a newsletter or fill out a form.
We may process the following User Data relating to our Users:
first and last name
marketing opt-ins and opt-outs
data you have entered into the Services
data relating to your use of the Services
analytics data generated by us based on your use of the Services (such as reliability ratings)
The logging systems used by our website automatically log certain Analytics Data when you visit our website. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognised from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with our website:
Device Information. We collect the following information relating to the technical device you use when using the Website:
device and device identification number, device IMEI
browser type and version
name of your Internet service providers
advertising identifier of your device
Usage Information. We collect information on your use of the Website and the Services, such as:
time spent on the Website and the Services
interaction with the Website and the Services
the time and date of your visits to the Website and the Services
the searches you made on the Services
We use various technologies to collect and store Analytics Data and other information when the Users visit our website, including cookies, pixel tags and web beacons.
WEB ANALYTICS SERVICES
Our website uses Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve our website and the Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
1. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
There are several purposes of the processing of your personal data by GIST Impact:
TO PROVIDE YOU THE SERVICES
GIST Impact processes your personal data to be able to make the Services available to you and to the entity you are representing.
If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
FOR OUR LEGAL OBLIGATIONS
GIST Impact processes data to enable us to administer and fulfil our obligations under the law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
FOR CLAIMS HANDLING AND LEGAL PROCESSES
GIST Impact may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
FOR CUSTOMER COMMUNICATION AND MARKETING
GIST Impact processes your personal data to contact you regarding the Services and to inform you of changes relating to it. Your personal data are also used for the purposes of marketing the Services and our other relevant products and services to you.
FOR QUALITY IMPROVEMENT AND TREND ANALYSIS
We may also process information about your use of our website and the Services to improve their quality e.g. by analysing any trends in their use. In order to ensure that our website and the Services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
LEGAL GROUNDS FOR PROCESSING
GIST Impact processes your personal data primarily to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer and other business relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymised or non-personally identifiable data when possible.
If you are a registered to the Services for your own account, we process your personal data also in order to fulfil our contractual obligations to you.
We may also process your personal data in order to comply with legal obligations.
In some parts of our website (including the Services), you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
2. TRANSFERS TO COUNTRIES OUTSIDE EUROPE
We have service providers in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards.
We only share your personal data within our organisation if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of GIST Impact’s organisation unless one of the following circumstances applies:
FOR THE PURPOSES SET OUT IN THIS PRIVACY STATEMENT AND TO AUTHORISED SERVICE PROVIDERS
To the extent that third parties need access to User Data in order for us to provide the Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorised service providers who perform services for us (including data storage, accounting, sales and marketing service providers) to process it for us and to payment service providers to process your payments to us.
When your personal data is processed by third parties as data processors on behalf of GIST Impact, GIST Impact has taken the appropriate contractual and organisational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link somewhere on our website, the processing is typically based on their policies and standards.
FOR LEGAL REASONS AND LEGAL PROCESSES
We may share your personal data with third parties outside our organisation if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of GIST Impact, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
FOR OTHER LEGITIMATE REASONS
If GIST Impact is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
WITH YOUR EXPLICIT CONSENT
We may share your personal data with third parties outside GIST Impact when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
4. STORAGE PERIOD
GIST Impact does not store your personal data longer than is legally permitted and necessary for the purposes of providing you the Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
Most personal data relating to a registered User will be deleted after a period of 6 months has lapsed after the User in question has terminated their registration with the Services. Thereafter, some of the personal data may be stored by us only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes.
We will store Analytics Data of unregistered Users for a period of 6 months.
5. YOUR RIGHTS
RIGHT TO ACCESS
You have the right to access and be informed about your personal data processed by us. We give you the possibility to request a copy of your personal data.
RIGHT TO WITHDRAW CONSENT
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our website and the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
RIGHT TO RECTIFY
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
RIGHT TO ERASURE
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
RIGHT TO OBJECT
You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the provision of our website or the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our website and the Services.
RIGHT TO RESTRICTION OF PROCESSING
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our website and the Services.
RIGHT TO DATA PORTABILITY
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
HOW TO USE YOUR RIGHTS
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
6. DIRECT MARKETING
The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
7. LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Switzerland, the local supervisory authority is The Federal Data Protection and Information Commissioner (FDPIC) (https://www.edoeb.admin.ch).
8. INFORMATION SECURITY
We use administrative, organisational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymisation, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test our website and the Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.