This data protection statement provides you with information regarding the manner in which we process your personal data when you use our website.
We will always process your personal data in accordance with the applicable data protection regulations (including the Swiss Data Protection Act “FADP” and, where applicable, the EU General Data Protection Regulation “GDPR”; hereinafter together referred to as the “applicable data protection law”).
A. Who is your data controller ?
The SWC is responsible for processing data concerning you which is collected or received in connection with our offers or our work with you or which is processed for the purposes set out in this data protection statement.
The SWC’s contact details are set out below :
The Source World Connection GmbH
Baarerstrasse 14
6300 ZUG
Switzerland
contact@thesourceworldconnection.com
B. How do we collect your data ?
We collect your data directly from you or receive it from your authorised representatives (e.g. lawyers, bankers, family officers etc.).
C. Scope, purpose and legal basis for the processing of your data
We process your data when you post listings, when you work with us, or when you contact us in any other way.
We process your data for the following purposes :
- to perform and comply with any contractual or legal obligations ;
- to verify access authorisation and manage the user account (if any) ;
- to provide information about updates or changes to our offers or events and amendments to our General Terms and Conditions (“GTC”), data protection statements and to the advertising guidelines on our portal and our website ;
- to prevent fraud and misconduct ;
- to develop and maintain customer relations ;
- to devise and improve our offers and products ;
- to evaluate user behaviour.
We set out below a detailed summary of the data we process in connection with our offers and the reason why we process it.
I. Viewing our offers (log files)
When accessing our website, the web server technology we use automatically saves general technical browsing data in log files. This includes the IP address of the device used to visit the site, data about the type of browser, the Internet service provider and the operating system used, the offers viewed, the landing/exit pages, and the date and duration of the session.
This information is collected and processed in order to enable use of our website (“establish a connection”), to ensure and increase the security and stability of our systems and offers, to analyse the use of our offers and services, to collect general demographic information and enable us to optimise our offering, as well as for internal statistical purposes. The user is not identified in this context. This information is collected automatically and is not matched with any personal data stored by us.
Insofar as your personal data is processed, for the purposes described above, when you view our offers, that processing is intended to allow you to use our website (“establish a connection”), to ensure and increase the security and stability of our system and offering, to analyse, statistically evaluate, adapt and improve the use of our offers, and to optimise our Internet offering.
II. Opening a user account
Your registration and the creation of a user/member account may be required in order to use personalised services or access protected areas, or to process requests and manage your subscriptions. For this purpose, you will need to enter some personal data. This includes, for example, the following information:
- to perform and comply with any contractual or legal obligations ;
- to verify access authorisation and manage the user account (if any) ;
- to provide information about updates or changes to our offers or events and amendments to our General Terms and Conditions (“GTC”), data protection statements and to the advertising guidelines on our portal and our website ;
- to prevent fraud and misconduct ;
- to develop and maintain customer relations ;
- to devise and improve our offers and products ;
- to evaluate user behaviour.
In addition to any data that is flagged as mandatory for use of a given offer, you are free to provide and save other personal data. By confirming the entry and transfer of your user account data during registration, you guarantee that the data you have entered is correct.
We will use the data to provide and manage our digital offerings, to check the plausibility of the data provided, i.e. in order to verify or organise the content, to implement and amend the contractual relationship entered into with you concerning your user account, and for billing you for paid services in due form.
III. Use of our offers as a registered user
When registered users take advantage of our services, we collect data for statistical purposes in order to ensure the proper functioning of the portal and to analyse and optimise our offers and services. In this way, we collect data about your use of our digital offerings, in particular about the types of listings viewed, in order to optimise, develop and improve our offering.
If you use our services as a registered user, statistical data can be viewed by other registered users. This data is only made available to other registered users in anonymous and/or aggregate form.
IV. Use of mobile applications
If you use our mobile application with a mobile device and have enabled the transfer of your GPS data to third parties in your mobile device settings, we may collect information about the location of your mobile device (longitude and latitude, horizontal accuracy information) using the GPS data.
We use location data to improve your user experience.
You can withdraw your consent at any time, or disable or object to the collection, processing and transfer of your location data, even after you have given your consent. If you do not wish to receive location-based online advertising and content, you can refuse access to your location or disable location services in your mobile device settings at any time.
V. Purchase/acquisition of a paid service
When you use a paid service, you are required to provide some information, such as your first and last name, your address (full postal address, postcode, location) and possibly some other data (e.g. billing address, payment information etc.); we need this information in order to be able to perform the contract with you in accordance with applicable data protection law.
If you choose an online payment option such as credit card, PayPal, etc. for the purchase of a paid service, payment is made via the online payment system of the relevant provider. In this case, the provider of the relevant payment system will process the personal data and payment data directly. We will not be informed of your payment data and will not save it. The online payment system provider’s data protection regulations will also apply.
We may save the following information about your purchases and contracts, whether now or in the past, i.e. products, services, number of products and services per purchase and the payment amount, and use it to optimise, improve and develop our offering, or for marketing and statistical purposes.
VI. Contacting customer service or using the designated contact form
If you contact our customer service department, we may process your contact details (such as your title, first and last name, telephone number, email address or postal address), as well as the content of the conversation, in order to handle your request and provide you with accurate and relevant information.
If you fill in a contact form to access our offers, we will process the personal data provided (such as your title, first and last name, telephone number, email address or postal address and the content of the request). It is also in our legitimate interest to provide you with accurate and relevant information and to process your request correctly (in accordance with applicable data protection law).
VII. Participation at events
If you choose to participate at events, we will use the data you have provided, such as your title, first and last name, email address and postal address. This data is used for the organisation and running of the events. In this context, your data may also be transferred in accordance with section E below, for example if we have engaged a third party to organise or evaluate the event or if the event is organised by a third party via our offering.
You may only post listings for goods that you have the right to sell and that do not violate laws or moral standards. If you are buying or selling on behalf of someone, you must ensure that they comply with the GTU. If not, The SWC may suspend or terminate your account.
VIII. User surveys and market research
If you willingly take part in a survey or other market research activities that we are conducting, we will collect your personal data, such as your title, first and last name, contact details and other information that you will be asked to provide as part of the survey. The data you provide will only be used to improve the user experience and to develop our products, which is in our legitimate interest (in accordance with applicable data protection law). The survey findings will only include aggregate and anonymous data.
IX. Marketing and analysis purposes
When you create an account, we may also use your data for our own personalised advertising campaigns. Personalised advertising campaigns include, in particular, the personalisation of advertising by means of digital advertisements regarding our web offering and our mobile application, sent by email, e.g. emails containing general information or advertising (newsletter), by telephone, post, text messages, multimedia messages and on instant messaging services. At the end of each of our emails you will find a link that allows you to unsubscribe from the newsletter at any time. You can also unsubscribe from the newsletter by email at any time.
We will only send you our newsletter if it concerns similar offers or if you have given your express consent. Otherwise, the delivery of personalised content and advertisements, e.g. on our portal, is in our legitimate interest, in accordance with applicable data protection law, in order to offer you products or services that may be of interest to you and in order to market our products in an optimal manner. If your prior consent is required, in particular for your data to be processed by affiliated companies or by our shareholders, we will ask for it in advance.
For this purpose, various analytical tools may be used to provide an ongoing link between historical and future, user-specific data in our possession, and to analyse, aggregate, pseudonymise and anonymise user behaviour across all our offerings. We may use publicly available data or data from third party providers in order to improve our database. Other participating companies may analyse and evaluate observations on how you use our offer as part of the analysis of user behaviour. In such event, data processing is carried out using pseudonymised or anonymised data. You can object to the processing of your data at any time by email.
In addition, we process your data for analytical purposes, e.g. to continuously improve our digital offering, to adapt it to requirements and to make it more secure. In accordance with the applicable data protection law, it is in our legitimate interest to adapt our offer to our client needs, to improve it in keeping with the market and to ensure its security.
In principle, by creating a user account, you automatically subscribe to our newsletter and your email address may therefore be used to send you advertisements about similar offers made by us, until you unsubscribe from the relevant newsletter.
For the purposes described in this statement, we may also engage subcontractors for the technical implementation of advertising campaigns and publicity on our behalf. These subcontractors will only process your data for the purposes described above (see section E below).
X. Prevention of fraud, disputes and legal processing obligations
We may also process any of your data that we collect and process pursuant to sections CI to CIX above for the prevention of fraud or in the event of a dispute, which is in our legitimate interest under applicable data protection law, in order to protect our business and pursue any claims we may have. In addition, we may process your data in order to comply with our legal obligations under applicable data protection law.
D. Profiling and personality profiles
Personality profiles and/or profiling may be carried out for the purposes stated above for our own internal database.
E. Transfer of your data to processors
We work together with or engage other companies or persons to process and record data in accordance with this data protection declaration. These may be processors who have been engaged by us. These processors may have access to your personal data, but only to the extent required for the performance of the tasks assigned to them or for the purposes described in this data protection declaration.
The transfer of your data pursuant to mandatory legal obligations remains limited.
I. Transfer to service providers
We transfer your data to third parties insofar as required for the performance of the contract in accordance with the applicable data protection law. For this purpose, we may transfer the required data to transport companies, banks and other service providers, such as hardware or software suppliers. These service providers will only use your data to process the order and not for any other purpose. Insofar as required, data may also be transferred abroad if that transfer is directly related to the execution or performance of our contract, e.g. for the delivery of goods.
II. Transfer to other third parties
We will only transfer your data, in accordance with applicable data protection law, if we have your express consent, if there is a legal obligation to do so or if required in order to enforce our rights, in particular any rights resulting from the contractual relationship, which is of paramount importance to us.
In the event of a sale, merger or any other restructuring of all or part of our company’s assets or rights, personal data may be transferred, sold or otherwise shared with third parties as part of the said transaction or restructuring.
In the event of an advance payment, e.g. in the event of a purchase on account, we may, in order to safeguard our legitimate interests to enter into contracts with creditworthy customers (in accordance with the applicable data protection law), ask for a credit check to be carried out by a credit information company using mathematical and statistical methods. For this purpose, we transfer the personal data required for the credit check to a credit information company and we use the information received on the statistical probability of a payment default to make a decision on the formation, performance or termination of the contractual relationship. The credit check may include probability values (credit scores) which are calculated using scientifically recognised mathematical and statistical methods and which include contact data in their calculations. Your legitimate interests are taken into account in accordance with the legal provisions.
F. Use of cookies, tracking and analysis tools as well as plug-ins and other integrations of third party offers
I. Cookies
Cookies help to make your visit to our website easier, more enjoyable and more useful, and ensure that our offer and portal function properly; they are also used to offer you services based on your interests. Cookies are files containing information that the Internet browser automatically saves on your computer’s hard drive when you visit our website. In principle, our digital offering can be used without cookies, but certain functions may then be limited.
When you use our website, the cookies we use may collect and save user data such as the IP address of your device, the pages viewed, the browser you used, the date, time, etc. In principle, this data does not identify you, unless you are logged in to your user account. When you close your browser, the cookies are saved on your computer in a text file and are retrieved the next time you connect to the server. Cookies do not damage your computer’s hard drive, nor do they transfer users’ personal data to us.
For example, we use cookies to recognise you after your first visit to our website. In principle, it is not you as a user who is identified, but only the computer, mobile device or browser used. We also use cookies to find out who has viewed our offers and portals and thus infer how often certain pages or offers are viewed, which parts of the portal are particularly popular and how the portal is generally used. We use other cookies so that you can browse freely on our portal and use its features, for example when accessing protected areas, for seamless browsing across various pages and in order to save your preferences. These cookies may also be required in order to use the basket and payment functions. Using cookies also allows us to implement the choices you have made or the decisions you have taken as settings, in order to make your visit to our portal more enjoyable. In general, cookies are used to improve our services and to make them more efficient and secure. Cookies also collect information in order to provide you with advertisements that might be of interest to you. Finally, our cookies help to select online advertisements that are more relevant to your potential interests and thus help to exclude advertisements that may be of little or no interest to you.
Most Internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are saved on your computer or so that you are always informed when you receive a new cookie (please refer to your browser settings). You can also delete cookies from your computer or mobile device using the relevant function on your browser.
You can decide at any time whether or not to receive targeted advertisements tailored to your possible interests. However, opting out does not mean that you will no longer see any online advertising. It simply means that the advertising displayed on the websites will no longer be chosen according to your supposed interests and may therefore be of less interest to you.
Most of the cookies we use are temporary session cookies, which are automatically deleted from the computer or mobile device at the end of the browsing session. However, we also use permanent cookies. These are saved on the computer or mobile device after the end of the browsing session. Depending on the type of permanent cookie, they will be stored on the computer or mobile device for a period of between one month and five years and will be automatically deactivated only when the scheduled period has expired.
II. Tracking and analysis tools
Use of our digital offering is also measured and analysed by various technical systems, mainly from third-party providers such as Google Analytics. These measurements may or may not be anonymous. In this context, it is possible that either we or the third-party providers of these technical systems may transfer the collected data to third parties for processing.
We use Google Analytics, a service provided by Google Inc. In this context, your IP address may, in principle, be transferred to a Google server in the USA. However, IP addresses are anonymised so it is impossible to link an IP address to a specific person. The IP address transferred by your browser in connection with Google Analytics will not be correlated with any other data held by Google. You can object to the capture and processing of this data by Google Analytics by installing an opt-out cookie, which prevents any further capture of your data when your browse our website.
The “Hotjar” tool is used on websites to analyse the use of our portal without any personal details and for statistical evaluation. In this context, information is saved concerning the operating system, browser, geographical origin (only the country), the pages viewed during the visit and any interactions (e.g. mouse movements, clicks and data entries on the website).
III. Plug-ins and other integrations of third party offers
Our digital offering is connected in various ways to third-party functions and systems, for example through the integration of plug-ins from third-party social networks such as Instagram, YouTube or LinkedIn etc.
If you have a user account with these third parties, they may be able to measure and analyse your use of our digital offering. Other personal data such as your IP address, personal browser settings and other parameters may be transferred to these third parties and saved by them.
G. How long do we keep your data ?
We will keep your data for as long as required by law or for processing purposes, notably in order to perform the mandate or contract and to comply with our legal obligations.
If we save data pursuant to a contractual relationship with you, that data will be saved throughout the duration of the contractual relationship, but only until the end of the statute of limitations for any claims we may have or for as long as there is a legal or contractual obligation to keep it.
We are required by law to keep the contents of the contact form and the resulting email exchanges for a period of six months. Data entered via the contact form on The Source platform is kept for 13 months for anti-fraud purposes.
After this period, we endeavour to anonymise the data so that it can continue to be used for statistical purposes. If this is not possible for any reason, your data will be deleted, if no longer required for the purposes stated above and we are no longer required to keep it by law.
H. How do we protect your data ?
We take appropriate technical IT and organisational security measures to ensure that your data is properly protected against any loss, destruction, falsification, manipulation or unauthorised access. We use secure data networks that comply with the relevant technical standards. We are constantly improving and adapting our security measures in line with technological developments. If you register with us as a user, your user account can only be accessed by means of your personal password. We recommend that you always keep access information confidential and that you close the browser window when you have finished communicating with us, especially if you share a computer with other persons.
Our employees and the employees of the service providers we have engaged are bound by a duty of confidentiality and by the legal provisions on data protection.
I. What rights do you have in relation to your data ?
In accordance with applicable data protection law, you have the following rights :
– Right of access :
You have the right to know at any time whether we are processing your personal data and what that data is.
– Right to rectify your data :
You have the right to have your personal data rectified at any time if you become aware that we are processing incorrect data concerning you.
– Right to delete your data :
If the processing of your personal data is no longer necessary, for example because you are no longer contractually bound to us or because you no longer consent to the processing of your data, you may ask for it to be deleted. We will delete your personal data, provided that we no longer have any obligation (e.g. a legal obligation to keep it) or any overriding interest (e.g. in connection with legal proceedings) to keep or process your personal data for a further period. In such event, we will only keep your data for these purposes and will no longer process it in any other way.
After the deletion of your personal data, you may no longer be able to benefit from or use the services that you registered for.
– Right to restrict or block the processing of your data :
You have the right to have the processing of your data restricted or blocked at any time, provided we are not under any other obligation to keep or process it for a certain period of time.
– Right to data portability :
In some circumstances, you have the right to ask us to transfer your personal data to you or to a third party designated by you or to receive it in a commonly used format.
– Right to object :
You may object at any time to the processing of your data for marketing and analysis purposes and to the transfer of your data.
This objection does not completely exclude the collection of personal data, but only concerns the collection of data for marketing and analysis purposes and the transfer of your data within The Source pursuant to section CIX above.
– Withdrawal of your consent :
Where consent is required, you have the right to withdraw it at any time. If we are informed that you have withdrawn your consent, we will stop processing your personal data for the purposes for which it was collected, unless authorised to do so by another legitimate interest. Withdrawal of your consent will have no effect on any data processing carried out beforehand.
– Claim made to a supervisory authority :
You also have the right to submit a claim with the appropriate supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner. You can exercise this right by contacting the supervisory authority for your place of residence, your place of work or the place where the data protection breach is alleged to have taken place.
You can exercise your rights at any time by informing us in writing and providing proof of your identity.
For this purpose, please use the email account with which you registered with us. This will enable us to verify your identity. We also reserve the right to verify your identity by means of a copy of your passport, a copy of the front and back of your identity card, a copy of your Swiss driver’s licence or by any other means. We may communicate with you in connection with your request to exercise your rights.
Please note that the exercise of your rights may be refused or partially restricted for legal reasons or under data protection law. If required or permitted by law, we will inform you of the reasons for our decision.
J. How can you contact us ?
If you have any questions concerning the processing of your data, if you would like to obtain information or request the deletion of your data, please send an email to contact@thesourceworldconnection.com
Our data protection officer’s contact details are as follows:
Amendments to this data protection statement
This data protection statement, published on our website, is binding.
We regularly update this data protection statement to reflect the latest developments in the use and protection of personal data. Registered users will be informed of any substantial amendments to the data protection statement by email sent to the email address provided at the time of registration or by means of a notice to that effect which will be displayed in an appropriate manner after log-in to the user account.
Please re-read this data protection statement on a regular basis so that you are kept informed of the latest developments regarding your personal data and the manner in which you can exercise your rights.