Table of Contents
1. What is this Privacy Notice about?
ACP Advanced Circuit Pursuit AG (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».
In this Privacy Notice, we describe what we do with your data when you use the newacp.ch website («website»). When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice.
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.
2. Who is the controller for processing your data?
ACP Advanced Circuit Pursuit AG (the «company») is the controller for ACP Advanced Circuit Pursuit’s data processing under this Privacy Notice, unless we tell you otherwise in an individual case.
You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:
ACP Advanced Circuit Pursuit AG
3. What data do we process?
We process various categories of data about you. The main categories of data are the following:
- Technical data: When you use our website, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for 6months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
- Communication data: When you are in contact with us by e-mail, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we have to determine your identity, for example in relation to a request for information, we collect data to identify you. We generally keep this data for 12months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years.
Much of the data set out in this Section 3 is provided to us by you when you use the website. You are not obliged or required to disclose data to us except in certain cases, due to legal obligations. When using our website, the processing of technical data cannot be avoided.
4. For what purposes do we process your data?
We process your data for the purposes explained below. Further information is set out in Sections 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.
- We process your data for purposes related to running and operating the website. For this purpose, we use in particular technical data.
- We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.
- We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).
5. On what basis do we process your data?
Where we ask for your consent forcertain processing activities, we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law).
Where we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.
6. What applies in case of profiling and automated individual decisions?
We do not automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3).
7. With whom do we share your data?
In relation to the website, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:
- Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.
All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).
Please note that the website may contain links to other resources that are not owned or controlled by us. We are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the website and to read the privacy statements of each and every resource that may collect data.
8. Is your personal data disclosed abroad?
As explained in Section 7, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed, in exceptional cases, in any country in the world.
Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.
9. How long do we process your data?
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
10. How do we protect your data?
We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.
However, no data transmission over the Internet or wireless network can be guaranteed.
In the event we become aware that the security of the website has been compromised or that user data has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.
In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the website.
11. What are your rights?
Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
- The right to request information from us as to whether and what data we process from you;
- The right to have us correct data if it is inaccurate;
- The right to request erasure of data;
- The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
- The right to withdraw consent, where our processing is based on your consent;
- The right to receive, upon request, further information that is helpful for the exercise of these rights.
If you wish to exercise the above-mentioned rights in relation to us please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable. If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.
12. Do we use online tracking?
We do not use techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website.
13. Can we update this Privacy Notice?
This Privacy Notice is not part of a contract with you. We reserve the right to modify this Privacy Notice or its terms related to the website at any time at our discretion.
When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided. The version published on this website is the current version.
This document was last updated on September 13, 2023.