WCG is committed to protect the personality and fundamental rights of individuals using our Services ("Users") whose Personal Data (as defined below under section 1) is processed, and to comply with the new Act on Federal Data Protection ("nFADP") and the EU General Data Protection Regulation ("GDPR")
This Privacy Policy is separate from and in addition to any confidentiality obligations we may have to Users. Users shall refer to the terms and conditions, applicable to their engagement, for further details on confidentiality.
By using our Services, Users expressly agree that WCG may process their Personal Data (as defined under section 1) in accordance with the provisions of this Privacy Policy.
1. What Personal Data is processed
Personal Data is all information relating to an identified or identifiable natural person. The Personal Data processed by WCG includes:
- First name and last name of the User
- Email of the User
- Phone number of the User
- All information necessary for WCG to carry out its contractual and legal obligations as described below (see section 4)
2. What Personal Data processing means
Any operation relating to Personal Data, regardless of the means and processes used, including collection, recording, storage, use, modification, disclosure, archiving, deletion or destruction of data.
3. Who processes the Personal Data
The processor is WeCanGroup SA, CHE-414.469.523, a company located at Cours des Bastions 13, 1205 Geneva, Switzerland.
Email: contact@wecangroup.ch.
4. Why we collect and process Personal Data
Personal Data may only be collected for specific purposes recognisable to the User and must be further processed in a manner compatible with those purposes.
WCG is obliged to ensure, by means of appropriate pre-settings, that the processing of Personal Data is limited to the minimum required for the purpose pursued.
The Personal Data collected and processed by WCG may be used to:
- Identify the User;
- Contact the User;
- Provide Services;
- Monitor and improve the use of the Services;
- Process and respond to requests, enquiries or complaints received from the User;
- Manage and administer the User business relationship with WCG, including processing payments and billing;
- Send newsletters or any other marketing and communication material;
- Perform our contractual duties regarding the User or for any other legitimate business purpose or overriding interest of WCG;
- Comply with any legal obligation where WCG is required to process the Personal Data, such as keeping records for legal purposes (Know Your Customer, Anti-Money Laundering, tax, corporate);
- Establish, exercise or defend the legal rights of WCG or for the purposes of legal proceedings;
- For any other legitimate business purpose or overriding interest of WCG.
5. Who are the recipients of Personal Data
5.1 WCG
The employees of WCG may access your Personal Data to provide the Services and comply with WCG's contractual and legal duties.
5.2 Recipient of exchange platforms
As WCG Platforms are data exchange platforms, Users choose the recipients of their Personal Data.
5.3 Sub-Processors
The User hereby expressly authorises WCG to delegate certain tasks to Sub-Processors, such as IT services and infrastructure, server location, maintenance, and other services. WCG ensures that the Sub-Processor is able to guarantee Personal Data security. The exhaustive list of Sub-Processors for each Platform of WCG is available by contacting contact@wecangroup.ch.
5.4 Others
The User further expressly authorises WCG to transfer Personal Data to third parties in the event of a merger, sale, liquidation or transfer of all or a portion of WCG's assets.
5.5 Legal Authorities
WCG may transfer Personal Data to third parties such as local or foreign governmental authorities, law enforcement agencies, regulatory bodies or courts, when such transfer is reasonably necessary to comply with provisions of the law or a mandatory legal request or to protect an overriding interest of WCG.
5.6 Cookies, tracking and other similar techniques
To optimise your experience on our Services, cookies and similar tracking techniques may be used. These are small files that are saved on the web browser and that store certain configurations and data in the web browser to exchange them with WCG's system. These are not used under any circumstances to store your Personal Data. You may refuse the use of cookies in the settings of your web browser. Your attention is drawn to the fact that by disabling their use, you may not have access to our Services functions in full.
Our Services may use Google Analytics, which is a service provided by Google Inc. located in the United States of America. This tool may use cookies to collect anonymous information and generate reports in usage statistics of the Website and/or Platforms without the User being personally identifiable. If the User does not wish Google Analytics to record the User's visit data, the User can install a browser add-on to disable Google Analytics.
Our Services may use social plugins for various social network websites (hereinafter referred to as "Social network"). When the User visits a website that contains Plugins, the User's browser will directly connect to the servers of the respective Social network. The content of the Plugin is directly transmitted to the User's browser from each Social network and is integrated into our Services. By integrating the Plugin, the Social network receives the information that the User has visited our Services. If you are logged on a Social network, it can associate your visit to the account of the respective Social network. If you interact with the Plugin, the corresponding information from your browser is directly sent to the respective Social network and stored there. For more information on the purpose and scope of data collection and further processing and use of data by the respective Social network as well as your rights and ways to protect your privacy, please contact WCG to see the privacy policy of the respective Social network.
6. What level of security for the Personal Data
WCG takes all reasonable and necessary measures to ensure that Personal Data is processed and stored securely and in accordance with this Privacy Policy.
WCG is certified ISO/IEC 27001:2013.
This certification demonstrates that WCG is committed to developing, maintaining and continually improving an Information Security Management System (ISMS) to provide the highest level of information security to its customers, partners, shareholders and employees.
WCG's ISMS preserves the data Confidentiality, Integrity and Availability, and ensures that authorised users have access to the systems and the resources they need when requested. To achieve this, WCG performs information security risks assessments at planned intervals and conducts internal audits. Certificates are available on WCG website https://wecangroup.ch/.
7. Where are processed the Personal Data
Personal Data is entered into electronic systems and paper files that are processed and stored physically and electronically on servers located in Switzerland.
Personal Data may be communicated abroad if the Federal Council has established that the State concerned has legislation guaranteeing an adequate level of protection or that an international body guarantees an adequate level of protection.
In derogation of the above, Personal Data may be communicated abroad in the following cases:
- The data subject has expressly given his or her consent to the disclosure
- The disclosure is directly related to the conclusion or performance of a contract
8. How long to retain Personal Data
WCG retains Personal Data as long as necessary for the purposes mentioned above, to provide our Services and to satisfy our contractual and legal obligations (such as reporting or accounting obligations).
If the Personal Data is no longer required for the execution of our contractual duties, it will be returned or deleted unless such data is necessary to implement a legal duty, in particular retention duties pursuant to tax or commercial law. This includes in particular the Swiss code of obligations, the Swiss Anti-Money Laundering Act, the Swiss VAT Act, and Swiss tax law.
9. What rights the User has towards his/her Personal Data
The Personal Data subject may request, unless it requires disproportionate effort, WCG to:
- Provide his/her Personal Data in a commonly used electronic format;
- Rectify incorrect his/her Personal Data;
- Delete his/her Personal Data;
Express consent from the User to process his/her Personal Data shall be obtained by WCG in the case of processing sensitive data, which are:
- Data relating to religious, philosophical, political or trade union opinions;
- Data concerning health, private life, racial or ethnic origin;
- Genetic data;
- Biometric data uniquely identifying a natural person;
- Data relating to criminal and administrative proceedings or sanctions;
- Data relating to social protection measures. Please note that WCG may nevertheless process your Personal Data in presence of legal obligations or an overriding interest of WCG, including exercising its legal rights.
WCG cannot be held responsible for any situation that may arise due to us having any inaccurate, incomplete, inauthentic, or otherwise deficient personal data that you or a third party has provided to us.
This Privacy Policy may be amended at any time. WCG shall inform you of any such amendments.
10. Miscellaneous
The User shall inform WCG as soon as possible if any of his/her Personal Data changes (including correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide our Services.
The User is liable for the accuracy and extensiveness of the data transferred to WCG and for providing updates should your Personal Data change.
WCG cannot be held responsible for any situation that may arise due to us having any inaccurate, incomplete, inauthentic, or otherwise deficient Personal Data that the User or a third party has provided to us.
This Privacy Policy may be amended at any time and the last version is stored on WCG website https://wecangroup.ch/.
If you have any questions or requests, please send us an email at the following address: contact@wecangroup.ch