Privacy policy focusright Ltd
focusright · Februrary 2024
1. Purpose of the privacy policy
focusright ltd is a consulting company based in Zurich, Switzerland.
Its business activities focus on anchoring and implementing responsible business practices and human rights due diligence in corporate processes and supply chains.
This privacy policy provides information on how focusright ltd collects and processes personal data.
Personal data refers to all information relating to an identified or identifiable person. As part of its business activities, focusright ltd obtains and collects personal data, in particular from customers, business partners, associated persons, website visitors, event participants and applicants. This is not an exhaustive list; other documents (e.g. general terms and conditions, conditions of participation, NDAs) may regulate specific circumstances.
If personal data of other persons (e.g. employees or other associated persons) is made available, focusright ltd assumes that the person providing the data has ensured that they are authorised to provide the data (through the consent of the person concerned) and that the data is correct. It is also assumed that the data subject has been made aware of this privacy policy.
2. Responsibility at focusright ltd
The responsible body for the processing described in this privacy policy is:
Management
focusright ltd
contact@focusright.ch
Zweierstrasse 35
8004 Zurich - CH
3. Principles of the collection and processing of personal data
focusright ltd uses personal data collected primarily to conclude and process contracts with customers and business partners, i.e. mainly in the context of its main activity and the other associated services. Various categories of personal data may be collected and processed when individuals or companies utilise services, use the website or make contact in any other way.
3.1 Purpose of data processing
In principle, data can be obtained and processed for the following purposes in particular:
◦ Communication: Customer data is processed so that focusright ltd can communicate with persons such as customers or partners (e.g. to answer enquiries, as part of the consultation process and to initiate or process contracts). In particular, the content of the communication, contact data, marginal data as well as image and audio recordings may be processed. In the event of possible processing for the purpose of communication in special formats (e.g. webinars or training courses), focusright ltd will make specific reference to this. Data subjects have at any time the option to object to data processing in the context of communication activities with the responsible body (see section 2) of focusright ltd.
◦ Initiation and conclusion of contracts: With regard to possible preparatory actions for the conclusion of a contract and the effective conclusion of a contract with a person, their client or employer, in particular names, contact details, authorisations, information about third parties, contract contents and other data that have been made available or otherwise collected (e.g. by third parties or public sources) may be obtained and processed.
◦ Administration and processing of contracts: Personal data may be obtained and processed in order to fulfil contractual obligations and to provide the promised services to customers and other business partners. This data may come from various sources, such as data provided by customers to ensure the fulfilment of services, data generated as part of project work, public sources and third parties. Examples can be meeting and consultation minutes, notes, internal or external correspondence, contract documents, etc. Data provided by business partners for processing is covered by so-called "Confidentiality and Non-Disclosure Agreements" ("NDAs" for short) and may oblige focusright ltd to fulfil a number of contractual obligations when handling data.
◦ Operation of the website and IT: To ensure the secure and stable operation of the website, technical data such as IP address, operating system details and region, time and type of use may be collected, as well as data on visitor behaviour and preferences on the homepage for traceability and analysis purposes. Data may be collected and processed to ensure appropriate IT security and the associated infrastructure, e.g. by monitoring and controlling electronic access to IT systems as well as system and error checks.
In order to use certain offers and services (newsletters, webinars, seminars, etc.), registration (directly with focusright ltd or with external service providers) is required, whereby the data provided will be processed. It is possible that further data may be collected during the use of the offers and services.
◦ Job applications: When persons apply for jobs at focusright ltd, the relevant data is collected and processed to review the application, to carry out the application process and, if the application is successful, to prepare and conclude a contract. In addition to contact details and information from communication and application documents, additional data from job-related social networks, the Internet, media and references provided may also be processed.
◦ Other purposes: Other purposes include, for example, training and education purposes as well as administrative purposes. focusright ltd may listen to or record telephone or video conferences for training, evidence and quality assurance purposes. In such cases, this will be indicated separately (e.g. by a display during the video conference in question) and the persons concerned will be informed that a notification is required if no recording is desired or the communication is to be terminated. In addition, personal data may be processed for the organisation, implementation and follow-up of events, in particular lists of participants and the content of presentations and discussions, as well as image and audio recordings made during these events.
3.2 Legal basis for data processing
If consent has been given for the processing of personal data for specific purposes (e.g. by registering to receive a newsletter), the personal data will be processed within the scope of and based on this consent, unless another legal basis exists and is required. Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place - data subjects can contact the responsible body (see section 2) to revoke their consent.
3.3 Duration of storage of personal data
focusright ltd processes and stores personal data for as long as it is necessary for the fulfilment of its contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship, for example, and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data will be stored for the period during which claims can be asserted against focusright ltd and insofar as focusright ltd is otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as far as possible. For internal processing purposes, data may be stored until the purpose has been completed , after which it will be irrevocably deleted. It should be noted that the purpose of certain business relationships may relate to several projects and therefore a longer period of time.
3.4 Data security and disclosure
focusright ltd takes appropriate technical and organisational security precautions to protect personal data from unauthorised access and misuse, such as issuing internal instructions on the processing of data, training employees, suitable IT and network security solutions where required and general internal data protection security controls.
In principle, no personal data collected by focusright ltd will be passed on unless explicitly stated in this privacy policy. If it is necessary to pass on collected data, the data subjects will be specifically informed and made aware of their rights.
3.5 Rights of the data subject
Persons from whom personal data is collected or processed have the right to information, correction, deletion, the right to restrict data processing and the right to object to data processing. This applies in particular in consideration of the legitimate interests of the data subject in the processing and to the disclosure of certain personal data for the purpose of transfer to another organisation (so-called data portability).
focusright ltd reserves the right to assert any legal restrictions and points out that the exercise of these rights may be in conflict with contractual agreements and that this may have consequences such as premature cancellation of the contract or cost consequences. In addition, certain conditions, exceptions or restrictions apply to the rights affected in this section (e.g. protection of third parties, business secrets or due to a professional duty of confidentiality). Accordingly, certain restrictions on the processing of data in the event of enquiries (redactions or only extracts) are reserved.
The exercise of such rights requires that the identity of the person concerned can be clearly proven (e.g. by means of a copy of an identity document). For the assertion of rights, please refer to the responsible body named in section 2. Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
4. Specific data collection by focusright ltd
4.1 Homepage and newsletter
focusright ltd operates a website on which visitor data can be collected. Direct data collection occurs, for example, when people contact focusright ltd via the contact form on the homepage. The data entered in the contact form is recorded and processed. To subscribe to the newsletter offered on our website, interested persons can register using the form on the homepage. focusright ltd uses the transmitted data exclusively for sending the newsletter, which may contain information and offers. The homepage and the newsletter service of focusright ltd are operated with the help of the provider Squarespace. Data is therefore transmitted to Squarespace. Squarespace is prohibited from using data for purposes other than sending the newsletter. Squarespace is not permitted to pass on or sell data. Squarespace is a certified provider of newsletter software that fulfils the requirements of the GDPR and Swiss data protection regulations.
Consent to the storage of data and its use for sending the newsletter can be revoked at any time, for example via the unsubscribe link in the newsletter or by contacting the controller named in section 2.
For further data protection information, please refer to Squarespace's privacy policy.
4.2 Social media
focusright ltd operates pages on social networks and other platforms operated by third parties and processes data from visitors to these pages in this context. Data is transmitted directly by visitors (through direct interaction with focusright ltd content) or by platforms operated by third parties (e.g. statistics). The providers of the platforms can analyse visitor usage and process this data for their own purposes (e.g. market research or platform administration). The platforms act as their own controllers in this processing and focusright ltd refers to the corresponding data protection declarations of the respective platforms for further information on such data processing.
focusright ltd uses the LinkedIn platform and refers to LinkedIn's privacy policy for further information.
5. Changes
This privacy policy may be amended at any time without prior notice. The current version published on this website shall apply. If the privacy policy is part of a contractual agreement, the contracting party will be informed of the change by e-mail or other suitable means in the event of an update.