Privacy Policy

We, S-PRO AG, a company incorporated under the laws of Switzerland, located at Dammstrasse 16, 6300, Zug, Switzerland (referred to as “we”, “us” and the “Company”), have meticulously crafted and published this Privacy Policy (referred to as the “Policy”) to underscore our unwavering commitment to the responsible and serious treatment of the privacy of the information of our customers, candidates, and visitors of https://s-pro.io (referred to as the “Website”).

We are dedicated to ensuring your privacy and have taken every measure to protect your information.

This Policy explains:
what is personal data;
what personal data we collect;
our information practices when you provide your data;
whom we can share personal data with;
information on users’ privacy rights;
how to contact us if you have any questions regarding data processing.

Unless otherwise provided herein, the definition and formulation used in this Privacy Policy retain the meanings defined in the Federal Act on Data Protection (the “FADP”) and the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

1. PERSONAL DATA PROTECTION STATEMENT

At S-PRO AG, your personal data protection is our utmost priority. We strive to protect the personal data of our customers and Website users and make every effort to comply with all local data protection laws to the extent they apply to us.

We do not collect personal data when you visit our website unless you give us special consent or choose to provide us with some information about yourself. We want to make it clear that we do not require you to register and provide your personal data to browse our Website.

We inform you that the Company is the “Data Controller” for the FADP and GDPR when we control data collection methods and identify the goals for which such data will be used.

We will process your data only upon at least one of the following legitimate grounds for such processing, including but not limited to:

processing is required to execute or fulfil an agreement with you (including any offer and acceptance), including when you are using our services;
such processing is required under the legislation of the countries to which we provide our services or make our services available;
you consented to your data processing;
processing is required for any legitimate interests of the Company as the controller or third party (unless interests on fundamental rights and freedoms of the data subject that require data protection prevail over the above interests).

The Company does not request or collect special categories of data (“sensitive data”) of our customers and the Website’s users.

Please note this Policy may be updated from time to time, including if required by applicable law. The Company can notify you about the Policy changes by sending an email message if you provide us with your email address or by prominently posting a notice on our Website. We suggest that you review this Policy from time to time to see if there are any modifications. Your continued use of our services after this Policy has been updated means your consent to such an update. You may refuse to use our services if you disagree with the updates.

Anyway, you can permanently delete or change your data accordingly.

2. WHAT PERSONAL DATA DO WE PROCESS

(A) The following information about you can be collected and processed by the Company:

personal data you affirmatively choose to submit to us (such as your name, email address, company name, title, country, and phone number) to access various downloads, view specific content, subscribe to the Company newsletters and your preferences in receiving marketing from S-PRO and its third-party partners and your communication preferences, etc.;
information the Company receives from your use of the Website, such as the IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and country/state of all visitors to our Website;
location information when you use the Website (the Сompany uses «Google Analytics» to determine location); personal data that you provide to us when responding to a vacancy or voluntarily sending us your CV;
information considered aggregated data, such as statistical or demographic data, which the Company may use for any purpose. Aggregated data may be derived from your personal information but is not considered personal information in law as it does not directly or indirectly reveal your identity unless we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you;
the Company collects technical data from various third parties and public sources, such as analytics providers, advertising networks, search information providers, etc.
other information that we collect using cookies and similar technologies.

(B) In addition to the above, we can process other personal data if you voluntarily submit it to the Company.

(С) If the data processing is not required for using our Website and/or services by you or is not explicitly required by applicable law, we will delete it.

3. CHILDREN’S DATA

This Website and our services don’t intend to collect information about children under 16. Our services are not intended for use by children.

Acceptance of this Policy and continued use of the Website and/or our services means that the user/customer is not a child.

4. HOW WE OBTAIN PERSONAL DATA

The Company may obtain your data from various sources and with multiple aims, including, without limitation:

when you browse the Website;
when you contact us (via a web form, email, or by phone);

We can also gather information by analyzing actions taken during Website use (using cookies and similar technologies).

5. PURPOSES OF PERSONAL DATA PROCESSING

We use Personal data for the following purposes:

to provide you with access to and use of our Website’s functionality and our services (performance of a contract); to operate and improve the Company’s services (performance of a contract, legitimate interest);

to provide customers’ support (performance of a contract, legitimate interest); administrative, analytical and statistic purposes (legitimate interest);
direct marketing and efficiency assessment (legitimate interest);
protection against any malicious actions of users and in connection with other security considerations of the Company (legitimate interest);
the safeguarding of the Company’s legitimate interests (legitimate interest);
to comply with other legislative requirements, including providing timely feedback to requests of data subjects and supervisory/law enforcement authorities (legal obligation);
to personalise user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested (consent);
to provide promotional information about our services (consent);
subscription management and unsubscribing (consent).

Emailing you any advertising/marketing notifications (excluding direct marketing) requires your specific consent and may be revoked at any time.

6. PERSONAL DATA SHARING/DISCLOSURE AND THIRD PARTY LINKS

No personal data will be disclosed or transferred to any third parties outside the Company and its affiliated entities except in the following cases:

when we have your consent or according to your request;
to state, federal or other regulatory and/or administrative authorities/agencies as part of the title or ownership transfer process;
in response to court orders or an official request in other legal, administrative, regulatory, arbitration or similar process;
to establish or exercise the Company’s, or an affiliate of the Company, rights or defend against claims;
to investigate and/or prevent fraud by users/customers;
if we believe that doing so is required or is in the Company’s best interest to protect its rights or the rights of others affiliated with us.

Any personal data passively collected by the third-party website will not be transmitted or stored by the Company.

When you use the services, the codes of other Internet resources and third parties may be present on the pages of the Website, because of which such Internet resources and third parties receive your data. Therefore, these Internet resources can receive and process information you have visited these pages and other information that the User’s browser transmits. These Internet resources may include:

banner display systems (e.g. DoubleClick for Publishers, Admixer, AdRiver, etc.);
systems for collecting statistics on service visits (for example, Google Analytics counters);
social network plugins (e.g. Facebook, Twitter/X, LinkedIn, Instagram, Google).

These administration services are necessary for the operational analysis of visits to the Website, internal and external assessments of Website traffic, volume of views, and user activity. We do not retain personal data from these services. Accordingly, if you do not want these services to gain access to personal data, you can voluntarily log out of your account or profile and clear cookies (via a browser).

Our Website may contain hyperlinks to other 3rd party websites (such as Twitter/X, Facebook, etc.) that the Company does not own or control. The Company is providing this content to you only as a convenience, and including any link does not imply our endorsement of the linked website. Please be aware that we are not responsible for the privacy practices of these third-party websites. The Company encourages you to be aware when you leave the website and to read the privacy policies of each third-party website that collects and/or uses information about you.

If the Company is acquired by or merges with another company, to the extent permitted by applicable law, you agree that we may transfer your personal information to such company. In this event, we will notify you by email/or a prominent notice on the Website of any choices you may have regarding personal data before your data is transferred and becomes subject to a different privacy policy.

7. DURATION OF DATA PROCESSING/STORAGE

We will not keep your data longer than is necessary to achieve the purpose for which it is collected and processed or to comply with regulatory requirements. To identify the relevant storage period, we recognise the personal data’s nature and category, the processing’s purposes, and whether we can hit those purposes otherwise.

We can store customers’ data to comply with our tax, accounting, and/or financial reporting obligations, where we must retain the data according to our contractual commitments to our financial partners.

Please be informed that regulations of other countries may impose additional requirements, so the data storage period may vary. If a regulation of the country where our service user resides contains the limitation of action provisions defining the period during which you may file your claim or complaint against us, and we, accordingly, need relevant proof of legal relations with you, we may process personal data during this limitation of action period.

We also need to consider any periods when we might need to keep personal data to comply with our legal commitments to our customers and/or supervisory authorities.

Anyway, you can delete or change your data using your right to be forgotten. For that purpose, please get in touch with the Data Protection Officer (see contact details below). If you find out that some of the data we process is outdated, please notify us, too.

If we process personal data under your consent (specifically, with the purpose of marketing mailings), any subsequent processing may be terminated at any time. It only takes to revoke your consent to such processing. If an option is available, you may opt out by following the instructions in each communication.

8. TECHNICAL, ADMINISTRATION AND OTHER DATA PROTECTION MEANS

The Company takes the security of all personal data very seriously. We use generally accepted standards for technological and operational protection of information and personal data from loss, misuse, alteration, or destruction.

To ensure the secure storage of your data, we have implemented special technical and administrative tools that protect personal data against any unauthorised or unlawful processing and any unintentional data loss, destruction, or damage. We routinely test our security measures to ensure they remain operational and practical.

Particularly, we use regular Malware Scanning. The Company also uses Secure Socket Layer (“SSL”) encryption when transmitting certain kinds of personal data. An icon resembling a padlock is displayed on the bottom of most browser windows during SSL transactions that involve credit cards and other forms of payment.

Of course, we use other technical controls, such as encryption, firewalls, and password protections, to secure the information we collect online.

The Company adheres to the principle of data minimisation. We process only the information related to our users/customers that we need to perform certain functions and for specific purposes or the information that you (upon your consent) share with us beyond the scope of the necessary processing. Your data is only accessible to a limited number of personnel who need access to it to perform their duties. We provide access to information and personal data only to authorised employees who have agreed to ensure the confidentiality of such information. We train appropriate personnel on our privacy and security policies and compliance requirements.

Please note emailing may not necessarily be secure against interception. We suggest you do not send personal data (such as your ID and credit card details) to us via email.

In compliance with the FADP and the GDPR, the Company provides relevant protection for data disclosure to countries outside the European Economic Area based on the standard contractual clauses for transferring personal data approved by the European Commission or any other applicable provisions referred to in Article 46 of the GDPR.

9. COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are small text files placed on your device, such as a computer or mobile device, by websites you visit. The website will remember your preferences and actions for a certain period so that you will not have to set them up again. Our cookies do not identify a specific user; they only identify the device used.

Information collected using this type of file is stored to maintain the User’s session within the Website; they may improve the Website by making estimates regarding website usage statistics and help to assist in customising the products we provide to the individual preferences and actual needs of Users, speed up the search process, and may also allow the display of advertisements, both from websites managed by Company and from third party websites or otherwise, based on the analysis of the User’s browsing habits.

Our website’s cookies and other tracking technologies may be used in various ways, such as website operation, traffic tracking, or advertising. We use cookies and other tracking technologies to improve the quality and efficiency of our services.

The list of cookies and other tracking technologies the Company uses on its website is available in a separate Cookie Policy.

To learn more about what cookies are, how they work, and how to manage or delete them, please visit www.allaboutcookies.org

Please note that certain browsers’ settings prohibit cookies and other tracking technologies. Please be aware that switching some cookies off will result in a loss of functionality of our website or application. Accordingly, you will not be able to use all the options, and some features/services might not work correctly.

10. THE RIGHTS OF DATA SUBJECTS (INDIVIDUALS)

When you contact us, you should go through the identification process and submit your specific requirements so we can process your request and respond on legitimate grounds. We must provide you with the data list in Article 13 and Article 14 of the GDPR.

Please note that if we cannot identify you through messaging or your request to the support service or if we have reasonable suspicions about your identity, we may request that you provide us with specific information about you. Any additional information collected for verification will only be used to verify the individual.

We process requests as quickly as possible, but please remember that providing a complete and legitimate response regarding personal data is a complex process that may take up to a month or even longer. We will let you know if we need more time to prepare a response.

The GDPR has secured the following rights of data subjects to safeguard their data:

Right to be informed

This Privacy Policy lets you read general information about what personal data we process. If you want to know what personal data we process about you, you can request this information anytime by contacting our DPO.

Right of access

You have the right to obtain confirmation from the Company as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data.

Right to rectification

If you discover that some of the data we process is incorrect or outdated, please notify us accordingly, including via the DPO’s contacts.

In some instances, we cannot modify Personal data. For example, when your Data has already been used in the offer and acceptance agreement and/or is contained in any written instrument executed and submitted to any state agency or otherwise according to applicable law.

Right to erasure (‘right to be forgotten’)

If we process your Personal data under processing consent (specifically, with the purpose of marketing mailings), any subsequent processing may be terminated at any time. It only takes to revoke your consent to such processing. If an option is available, you may opt out by following the instructions in each communication.

The Company reserves the right to send you certain communications relating to our services, including, without limitation, notifications, service announcements, and administrative messages. Generally, you may not opt out of these communications which are not promotional/marketing.

In cases referred to in Article 17 of the GDPR, the Company will delete the personal data being processed, other than the data we are obliged to keep under applicable law. If personal data collected from a user/consumer is needed to comply with a legal obligation (e.g., a statute that requires that the Company maintain documentation relating to the user/consumer, a preservation hold issued as part of a legal process, or a statute that requires that the Company maintain some data as part of its overall security), we are not required to delete the data.

If you are a parent of a child under 16 (or any other age established by applicable law), and you believe that your child disclosed any information to us, please notify us immediately, and we will erase this information.

Right to data portability

Sometimes, you may obtain or request that we provide your data to any third party in a structured, commonly used and machine-readable format.

Right to restrict processing

You may request to restrict your data processing so only we can keep it. This means demanding that we terminate data processing other than storage under certain circumstances.

Right to object

You have the right to object to processing Personal data in certain circumstances and have an absolute right to stop your Data from being used for direct marketing.

However, in these circumstances, the right to object is not absolute, and you must give specific reasons why you object to processing your Data.

Right not to be subject to a decision based solely on automated processing

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Automated decision-making takes place when an electronic system uses personal information to make decisions without human intervention.

There are no fully automated decision-making or profiling systems within the Company, so this right does not currently apply to any processing activities.

Right to lodge a complaint

If you want to make a complaint, you may write to the Federal Data Protection and Information Commissioner (FDPIC), which is an independent Swiss Confederation authority (Website and contact forms: https://www.edoeb.admin.ch)

12. HOW TO CONTACT US

If you have any questions about this Policy or complaints regarding your data, please contact us electronically or send physical mail.

We have designated the Data Protection Officer (DPO) as a single point of contact for any questions or comments regarding data protection and privacy issues.

You may submit your request to the DPO in writing:

Dammstrasse 16, 6300, Zug, Switzerland, or

E-mail: privacy@s-pro.io

(Last Updated: Jul 18th, 2024)