GIST Impact Privacy Statement
GIST Advisory Switzerland S.A. doing business as GIST Impact (“GIST Impact”, “we” or “us”) provides various digital and consultancy services (jointly “Services”) for the purpose of measuring and managing the impact of companies and value chains on people, the environment, society and the economy. This Privacy Statement explains why and how we collect and use personal data and provides information about individuals’ rights in relation to personal data. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
In this Privacy Statement, the word “User” or “you” refers both to unregistered and registered users, (including representatives of entities) and the data subjects whose personal data is processed on legitimate grounds or for legitimate interests This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on our website.
This Privacy Statement applies to processing of personal data carried out by GIST Impact as data controller.
GIST IMPACT’S CONTACT DETAILS:
Name: GIST Advisory Switzerland S.A.
Company ID: CH-518.104.22.1685-9
Correspondence address: 21 Avenue Perdtemps, 1260 Nyon, Switzerland
E-mail address: firstname.lastname@example.org
PERSONAL DATA PROCESSED AND SOURCES OF DATA
You may register to the Services on GIST Impact’s website by providing us with your email address and other relevant information as instructed on the Services. You may also use the Services as an unregistered User by connecting with us otherwise on the website.
The personal data collected and processed by us in connection with your registration to and use of the Services can be divided into two general data categories: User Data and Analytics Data.
User Data is personal data collected directly from you or generated by our Services or us based on your use of the Services. We may collect User Data from our Users in a variety of ways, including, when they register to and use the Services, subscribe to a newsletter or fill out a form.
We may process the following User Data relating to our Users:
- first and last name
- email address
- payment details
- marketing opt-ins and opt-outs
- data you have entered into the Services
- data relating to your use of the Services
- analytics data generated by us based on your use of the Services (such as reliability ratings)
You may access our website without having to disclose any details on your identity. The logging systems used by our website automatically log certain Analytics Data when you visit our website. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with our website:
Device Information: We collect the following information relating to the technical device you use when using the Website:
- Device and device identification number, device IMEI
- IP address
- Browser type and version
- Operating system
- Name of your Internet service providers
- Advertising identifier of your device
Usage Information: We collect information on your use of the Website and the Services, such as:
- Time spent on the website and the Services
- Interaction with the website and the Services
- Time and date of your visits to the website and the Services
- Searches you made on the Services
WEB ANALYTICS SERVICES
Our website uses Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve our website and the Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
(i) TO PROVIDE YOU THE SERVICES
GIST Impact processes your personal data to be able to make the Services available to you and to the entity you are representing and to fulfill our contracts obligations. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
(ii) FOR OUR LEGAL OBLIGATIONS
GIST Impact processes data to enable us to administer and fulfil our obligations under the law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
(iii) FOR CLAIMS HANDLING AND LEGAL PROCESSES
GIST Impact may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
(iv) FOR QUALITY IMPROVEMENT AND TREND ANALYSIS
We may also process information about your use of our website and the Services to improve their quality e.g., by analyzing any trends in their use. In order to ensure that our website and the Services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
(v) FOR CUSTOMER COMMUNICATION AND MARKETING
GIST Impact processes your personal data primarily to pursue our legitimate interest pursuant to Article 6 (1) lit. of General Data Protection and Regulation (GDPR) for the purpose of optimizing our online offering, and web presence to maintain customer and other business relationships. We process your personal data for marketing our Services and products and to inform you about the related changes. Towards this we may collect prospecting data from third parties for qualified lead generation. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and provide you with easy to use opt-out from our marketing communications. Your data is not used for any other purposes or shared with third parties.
TRANSFERS TO COUNTRIES OUTSIDE EUROPE
We have service providers in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in jurisdictions outside the European Economic Area or the User’s domicile. We provide adequate protection as per GDPR for transfer of personal data to countries outside of the European Economic Area. Apart from conducting due diligence of the service providers, we ensure that the service providers have adequate technical measures, confidentiality and other safeguards for protection of data through standard contractual clauses.
We only share your personal data within our organisation if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of GIST Impact’s organisation unless one of the following circumstances applies:
FOR THE PURPOSES SET OUT IN THIS PRIVACY STATEMENT AND TO AUTHORISED SERVICE PROVIDERS
We only share your personal data within our organization if and as far as reasonably necessary for the purposes of this Privacy Statement. We do not share your personal data with third parties outside of GIST Impact’s organization unless one of the following circumstances applies:
(i) FOR THE PURPOSES SET OUT IN THIS PRIVACY STATEMENT – TO AUTHORISED SERVICE PROVIDERS
To the extent that third parties need access to User Data in order for us to provide the Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing service providers) to process it for us and to payment service providers to process your payments to us.
When your personal data is processed by third parties as data processors on behalf of GIST Impact, GIST Impact has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link somewhere on our website, the processing is typically based on their policies and standards.
(ii) FOR LEGAL REASONS AND LEGAL PROCESSES
If GIST Impact is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
(iv) WITH YOUR EXPLICIT CONSENT
We may share your personal data with third parties outside GIST Impact when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
GIST Impact does not store your personal data longer than is legally permitted and necessary for the purposes of providing you the Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
Most personal data relating to a registered User will be deleted after a period of 6 months has lapsed after the User in question has terminated their registration with the Services. Thereafter, some of the personal data may be stored by us only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes.
We will store Analytics Data of unregistered Users for a period of 6 months.
(i) RIGHT TO ACCESS
You have the right to access and be informed about your personal data processed by us. We give you the possibility to request a copy of your personal data.
(ii) RIGHT TO WITHDRAW CONSENT
In case the processing is based on a consent granted by the User, like some parts of our website (including the Services), request for grant of consent for the processing of personal data; the User may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our website and the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
(iii) RIGHT TO RECTIFY
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
(iv) RIGHT TO ERASURE
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
(v) RIGHT TO OBJECT
You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the provision of our website or the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our website and the Services.
(vi) RIGHT TO RESTRICTION OF PROCESSING
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our website and the Services.
(vii) RIGHT TO DATA PORTABILITY
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
HOW TO USE YOUR RIGHTS
The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
The User has the right to prohibit us from using the User’s personal data for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in all our direct marketing messages.
LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Switzerland, the local supervisory authority is The Federal Data Protection and Information Commissioner (FDPIC)(https://www.edoeb.admin.ch).
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test our website and the Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.