CC Trust Group AG

Privacy Notice

1. What is this Privacy Notice about?

CC Trust Group AG (also “we“, “us“) collects and processes personal data that concern you but also other individuals (“third parties“). We use the word “data” here interchangeably with “personal data“.

CC Trust Group AG means CC Trust Group AG and its subsidiaries.

In this Privacy Notice, we describe what we do with your data when you use www.cctrust.ch (“website“), communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.

If you disclose data to us or share data with us about other individuals, we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

2. Who is the controller for processing your data?

CC Trust Group AG, Neuhofstrasse 12, 6340 Zug (the “CC Trust Group AG“) is the controller for CC Trust Group AG’s processing under this Privacy Notice, unless we tell you otherwise in an individual case, for example in additional privacy notices, on a form or in a contract. However, unless we tell you otherwise, this Privacy Notice also applies where a group company of CC Trust Group AG is the controller, instead of CC Trust Group AG. In particular, this applies where your data is processed by a group company in connection with its own legal obligations or contracts or where you share data with such a group company. In these cases, this group company is the controller and only if it shares your data with other group companies for their own processing (see section 6), will these other group companies also become controllers.

You may contact us for data protection concerns and to exercise your rights under Section 10 as follows:

CC Trust Group AG

Neuhofstrasse 12

CH-6340 Baar

info@cctrust.ch

3. What data do we process?

We process various categories of data about you. The main categories of data are the following:

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 11 and 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data. We keep this data to document our communication with you, for quality assurance and for follow-up inquiries.

The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting and quality assurance (for example in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone. Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an access request. Our processing also serves to document the communication and its content.

We process data for the conclusion, administration and performance of Contractual Relationships.

We process data for marketing purposes and relationship management, for example to send our customers incl. potential customers and other contractual partners personalized advertising for products and services from us and from third parties. This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events, etc.) and may also include free services (for example invitations, vouchers, etc.). You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 11).

For example, if you consent, we may send you information, advertising and product offers from us and from third parties within and outside the group (for example advertising partners), as printed material, electronically or by telephone. For this purpose, we process in particular communication and registration data. As most companies, we personalize communications so that we can provide you with customized information and offers that meet your needs and interests. Therefore, we combine data we process about you and collect preference data and use this data as a basis for personalization (see Section 3).

Relationship management includes addressing existing customers and their contacts, possibly personalized on the basis of behavioral and preference data. In the context of relationship management, we may also operate a customer relationship management system (“CRM”) in which we keep the data of customers, suppliers and other business partners that is required for relationship management, for example data about contact persons, relationship history (for example information about products and services purchased or supplied, interactions, etc.), interests, marketing measures (newsletters, invitations to events, etc.) and other information.

All this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.

We further process your data for market research, to improve our services and operations, and for product development.

We may also process your data for security and access control purposes.

We continuously review and improve the appropriate security of our IT and other infrastructure. Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. We therefore process data, for example, for monitoring, inspection, analysis and testing of our networks and IT infrastructures, for system and error checks, for documentation purposes and in the context of backups. We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes.

5. On what basis do we process your data?

Where we ask for your consent for certain processing activities (for example for marketing mailings), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 11. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.

6. With whom do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

7. Is your personal data disclosed abroad?

As explained in section 6, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in United States.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Many countries outside of Switzerland or the EEA currently do not have laws that ensure an adequate level of data protection under the DPA or the GDPR. The contractual arrangements mentioned compensate for this weaker or missing legal protection to some extent. However, contractual precautions cannot eliminate all risks (namely of government access abroad). You should be aware of these remaining risks, even though they may be low in an individual case.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

8. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 11. If there are no contrary legal or contractual obligations, we will delete your data once the storage or processing period has expired as part of our usual processes.

Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep it with it (for example in case of backups or document management systems).

9. How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

Technical and organizational security measures may include encryption of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely; residual risks are unavoidable.

10. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example by redacting content that concerns third parties or our trade secrets).

If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

11. Do we use online tracking and online advertising techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called “cookie”).

Cookies are individual codes (for example a serial number) that our server or a server of our service providers or advertising partners transmits to your system when you connect to our website, and that your system (browser, cell phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognized even if your identity is unknown.

Whenever you access a server (for example when you use a website or an app, or because an e-mail includes a visible or invisible image), your visits can therefore be “tracked”. If we integrate a provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in a particular case.

We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example by clicking a button), these providers can determine that you are using our website. If you have an account with that social media provider, it can assign this information to you and thereby track your use of online offers. These social media providers process this data as separate controllers.

We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):

12. What data do we process on our social network pages?

We may operate pages and other online presences (“fan pages”, “channels”, “profiles”, etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We receive data about you when you communicate with us through online presences or view our content on the corresponding platforms, visit our online presences or are active on them (for example publish content, submit comments). These platforms also collect technical data, registration data, communication data, behavioral data and preference data from you or about you, among other things (see Section 3 about these terms). These platforms usually perform statistical analysis of the way you interact with us, how you use our online presences and our content or other parts of the platform (what you view, comment on, “like”, forward, etc.) and combine this data with other information about you (for example information about your age and your gender and other demographic information). In that way, they create profiles about you and statistics on the use of our online presences. They use this data and profiles to display to you our or other advertisements and other personalized content on the platform and to manage the behavior of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. We can control the analysis that these platforms generate regarding the use of our online presence to some extent.

We process this data for the purposes set out in Section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 11) and for market research. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the following platforms:

13. Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Website Disclaimer

Please take notice of the following LEGAL DISCLAIMER:

Data privacy

The security of your personal data is extremely important to CC Trust Group AG. We handle the data entrusted to us with the utmost care, with strict confidentiality and in compliance with legal requirements. Our data privacy statement is intended to provide you with transparent information on what kind of data we collect, process and store and for what purpose.

Copyrights

© Copyright CC Trust Group AG. All rights reserved. Any text, images, graphics, animations, videos, sound files and other objects, as well as their arrangement on the website, are subject to copyright and other protective laws.

The content of this website may not be copied for commercial use, distributed, modified or made accessible to third parties without the prior written consent of CC Trust Group AG. Please note that some images contained on the website are subject to the copyrights of third parties.

Trademarks

Unless otherwise indicated, all trademarks on this website are subject to trademark rights for CC Trust Group AG. This particularly applies to brands, logos and emblems.

Licences

CC Trust Group AG wishes to present you with an innovative and informative website. The intellectual property contained therein is protected, including patents, brands and copyrights. No licenses are granted via this website for the use of the intellectual property of CC Trust Group AG or third parties, unless expressly stipulated otherwise.

Liability

CC Trust Group AG generates and updates the content presented on our website with the greatest possible care. However, we can offer no guarantee that the content provided is accurate, up to date and complete. Any liability for damages arising directly or indirectly from the use of this website shall, to the extent permitted by law, be excluded.

This limitation of liability shall not apply in the event of injury to life, limb and health or for damage caused due to an intentional or grossly negligent breach of duty on the part of CC Trust Group AG.

CC Trust Group AG assumes no responsibility for the technical functionality (particularly the absence of viruses) and content of any third-party websites to which there are references or links on this website.

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