1. General Information
a) Introduction
Boltonshield AG (hereinafter referred to as the “Company” or “Boltonshield”, “We” or “Us”) is aware and strives to comply with its legal obligations under all applicable laws and regulations regarding the protection of personal data which are applicable to it and takes steps to ensure that all information is kept confidential and secure and to otherwise protect and respect your privacy.
b) Controller
This website is operated by Boltonshield AG.
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the applicable Laws (Swiss Data Protection Law and EU General Data Protection Regulation) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
All enquiries in respect of this Privacy Notice or any requests to exercise any of the rights set out above should be directed to the Data Protection Officer via info@boltonshield.com or by post at:
Data Protection Officer, Minervastrasse 3, 8032 Zurich, Switzerland
Processing of Personal Data during Your Use of Our Website
We collect personal information about you when you access our website. We collect this personal information from you either directly, such as when you register to use our portals or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).
Your visit to our website and/or use of our online services will be logged. The IP address currently used by your device, date and time, the browser type and operating system of your device, the pages accessed may be recorded. This data is collected for the purposes of optimizing and improving our website as well as our online services. Additionally, your personal data is only stored if you provide it to us on your own account, e.g. as part of a registration, a survey or access to your results via our portals (performance of a contract).
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. These measures include, but are not limited to, encryption, access control, internal audit etc. Furthermore, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We use this personal information to:
- customize our website and its content to your particular preferences.
- notify you of any changes to our website or to our services that may affect you;
- improve our services;
This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.
When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- Consent: where you have given us clear consent for us to process your personal information for a specific purpose;
- Contract: where our use of your personal information is necessary for a contract, we have with you, or because you have asked us to take specific steps before entering into a contract;
- Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations);
- Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests);
Cookies
To make your visit to our website more pleasant and to enable the use of certain functions, we may use “cookies” on various pages. Cookies are small text files that are stored on your terminal device. Some of the cookies we use are deleted after the end of the browser session. Other cookies remain on your device and enable us or our partner companies to recognize your browser on your next visit. You can set your browser in such a way that you are informed about the setting of cookies separately and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. For more information, see the help function of your Internet browser. If cookies are not accepted, the functionality of our website may be limited.
To find out more about how we use cookies you can access our “Cookie Policy”.
3. Data Recipients
We may use third party service providers to process your personal data. These service providers may be located in countries within and outside the European Union (EU) and the European Economic Area (EEA). We ensure that these service providers process personal data in accordance with Swiss Data Protection law as well as with European data protection regulation to guarantee an adequate data protection level, even if personal data are transferred into a country outside the EEA. Transfers of personal data to other recipients is not performed, except where we are obliged to do so by law.
4. Retention Period
Personal data provided to us via our website will only be stored until the purpose for which they were processed has been fulfilled. Insofar as retention periods under commercial and tax law must be observed, the storage period for certain data can be up to 10 years. However, storage periods may also be amended due to our legitimate interest (e.g. to guarantee data security, to prevent misuse or to prosecute criminal offenders).
5. Your Rights
As a data subject, you can contact us at any time with a notification under the contact information mentioned above under Section 1 to make use of your rights. These rights are the following:
- The right to receive information about the data processing and a copy of the processed data;
- The right to demand the rectification of inaccurate data or the completion of incomplete data;
- The right to demand the erasure of personal data;
- The right to demand the restriction of the data processing;
- The right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller;
- The right to object to the data processing;
- The right to withdraw a given consent at any time to stop a data processing that is based on your consent;
- The right to file a complaint with the
- competent supervisory authority:
Should you believe that any personal information we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted by contacting us at the email address dpo@boltonshield.com
In the event that you wish to complain about how we have handled your personal data, you may contact us at the above email address and telephone number. We will then look into your complaint and work with you to resolve the matter.
5. Changes to this privacy policy
This privacy notice was published on 25th May 2020 and last updated on 19th August 2020. We may change this privacy notice from time to time and when we do, we will inform you via our website or other means of contact;