Phosym, Mauro (“we”, “us”, “our”, or “Phosym”) respects the privacy of individuals and is fully committed to protecting their personal data and using them in accordance with data protection laws.

This statement (the “Privacy Policy”) describes how we collect, use and process personal data from you – that is, data that you provide to us when you visit our website www.phosym.ch (the “Site”). By visiting the Site or filling in an exchange form, you indicate that you understand the terms and conditions set out in the Privacy Policy.

Whether you consult the Site for your personal use (natural person) or for your organisation (legal person), you are considered a “user” who submits personal data and, for the purposes of the European General Data Protection Regulation (“GDPR”) and the Swiss Federal Act on Data Protection (“FADP”), we are the data controller.

As such, we maintain internal standards and conditions for the processing of personal data as well as a register of processing operations.

Please note that although the Site may contain links to other websites or services, we are not responsible for the privacy practices of each respective website or service and we encourage you to be aware of this when you leave the Site. Similarly, we encourage you to carefully read the privacy statements of each and every website and service you visit. The Privacy Policy does not apply to third party websites and services.

If you wish to contact Phosym regarding your personal data or the Privacy Policy, please write to contact@phosym.ch.

Information collected about users and how we use it

When you use the Site, cookies linked with both the Google Analytics and the Google ReCAPTCHA services are generated (please see official documentation : GA and ReCAPTCHA).

Cookies enable us to collect data such as your type of device, your geographical position (via your public IP address), information filled in during your visit to the Site, your interaction with the Site.

Data from cookies are use for analysis, marketing and targeting activities (including unique visits, return visits, duration of the session, actions carried out on the web page).

When you contact us through an exchange form, we will collect information that may contain the following personal data :

• Your first and last name,
• The name of your organization (where applicable),
• An email address and phone number.

We will process this data via our contact database, if necessary and always punctually, to send you information and/or promotional material.

At any time, you can request to stop receiving the above information (by unsubscribing or via a formal email to contact@phosym.ch).

Finally, when you contact us by telephone, if we are are absent, your call may be recorded in order to guarantee a follow-up and a response as soon as possible. In this case, the recording is kept for a maximum of 3 months.

List of cookies used on the Site (name of the cookie, lifetime and purpose…)

• “_ga”, session, User identification (distinction, unique login).
• “_gid”, session, Identification of daily users.
• “_gat”, 1 minute, Used to throttle the demand rate. If Google Analytics is deployed via the Google Tag Manager, this cookie will be named _dc_gtm_.
• “_gac_”, session, Contains campaign information for the user, this cookie can be linked to the Google Ads add-on service if necessary.
• “_GRECAPTCHA”, session, Allows to set security score based on the user interactions with the Site.

Information provided to our subcontractors or partners

Our subcontractors and partners undertake to comply with the applicable laws and regulations regarding privacy and the protection of personal data. They may not carry out more processing than we do, nor may they use the data for purposes other than those relating to their collaboration with Phosym.

To the extent reasonably necessary to defend our legal rights, we may share your personal data with our legal advisors. We will only share personal data with third party service providers who have agreed to comply with the obligations set out in applicable data protection laws.

In certain circumstances, we are required to share information with third parties to comply with legal requirements or requests, as well as to protect our or a third party’s legitimate interests. We will also only disclose your information to third parties inside and outside your country to the extent permitted by applicable law, including : (i) to a prospective purchaser or a purchaser acquiring all or substantially all of our business, (ii) to a third party in the event we sell or buy a business or enter into a merger, in which case we may disclose your information to the prospective purchaser of that business, and (iii) to a third party if we sell, purchase, merge or combine with other companies or businesses, or are subject to reorganization, bankruptcy or liquidation, or (iv) if we enter into a business transaction or sell all or part of our assets (in such transactions, your information may be among the transferred assets).

We do not retain your personal data beyond the periods indicated in the Privacy Policy.

The explicit consent you give when using the Site in connection with the receipt of informational and/or promotional material from Phosym is active until cancelled.

Cancellation will stop the processing of personal data for the related purposes.

In accordance with the applicable data protection regulations, you have certain rights regarding your personal data. You have the right to request access, correction, modification, deletion or restriction of use of your personal data.

In addition, you may object to the processing of your personal data in certain circumstances (in particular, when we are not required to process your data to meet a contractual or other legal requirement). These rights may be limited, for example, if the fulfilment of your request reveals personal data about another person, or if you ask us to delete information that we are legally required to retain.

Finally, if you believe that we have unlawfully processed your personal data, you have the right to file a complaint: (i) to the contact details provided below, (ii) to your data protection supervisory authority (for Switzerland, the Federal Data Protection and Information Commissioner – FDPIC).

We strive to use reasonable organizational, technical and administrative measures to protect the confidentiality, integrity and availability of personal data. We encourage you to take care of the personal data in your possession, especially those you process online, by limiting access to your equipment, web browsers and by regularly cleaning your browser caches.

Any information you provide may be transferred to or accessed by our sub-contractors, partners or service providers. When these are located abroad (i.e., outside the territory of the Swiss Confederation), we transfer your information by taking the necessary measures to ensure adequate protection.

Any changes we make to the Privacy Policy in the future will be posted on this page. We therefore encourage you to review it frequently when using the Site.

If you have any questions about your personal data or the Privacy Policy, or if you wish to make a complaint about the way we handle your personal data, please contact us by email at contact@phosym.ch, or by using the contact details below :

Phosym, Mauro
Route du Nant-d’Avril 150
1217 Meyrin
Switzerland

Last update: April 18th, 2021.