At Pact Capital AG, including our affiliates and/or subsidiaries (hereinafter «PACT», «we», «us», «our»), as part of our commitment to privacy and transparency, we want to provide you with more information about how we collect and use personal information, in a more organized and readable format.
By accessing and continuing to use the Sites, you acknowledge that you have read and agree to the practices described herein.
Our headquarters mailing address is:
Rue du Rhone 67, 1207 Geneva, Switzerland
Our fundamental principles
We are careful about the personal information we ask you to provide and the personal information we collect about you through the operation of our services. We store personal information only for as long as is reasonable to maintain it. We seek to make it as simple as possible for you to control what information is shared publicly (or kept private). We seek full transparency in how we collect, use, and share your personal information. As the owner of personal data, you have the right to withdraw or refuse your consent at any time and, when we rely on legitimate interests, you have the right to object. Please note that «personal information» in the context of this document may also be referred to as: «data», «personal data» or «Personal Identifiable Information». In the event of any conflict between this document and any applicable local laws and/or regulations, and only to the extent that such local laws and/or regulations require a higher level of protection for your personal information, such applicable local laws and/or regulations shall prevail. The websites you visit often contain links to other sites. Please be aware that PACT is not responsible for the privacy practices or the content of third-party websites. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. When leaving the Sites, please read the privacy notices of each website that collects Personal Identifiable Information.
What personal data we collect and why we collect it
Depending on who you are (i.e., a customer, supplier, sub-supplier and/or Website visitor) and how you interact with us (e.g., online, offline, over the phone, through emails, and/or through our systems, tools, platforms, etc.), we may process the following personal data about you:
a. Personal Identifiable Information:
(i) Information you provide to us at the time of data collection, such as first name, last name, alias, signature, title, date of birth, Social Security number, driver’s license or state identification card number, passport number or other similar identifiers. (ii) We may collect personal information you provide to us by telephone, email, through a face-to-face conversation or through online and offline forms, such as subscription newsletters, surveys, attendance forms, event registration, contests. (iii) When you interact with PACT on social media, we may collect basic information about your profile, including your profile name and bio, your following number, your social sharing activity, and your content preferences from the social media platforms you use. (iv) We may also collect information from or about you from other public online and offline sources, such as LinkedIn, or information published in print or online media, in addition to your use of the Sites or when contact us. For example, when you attend one of our events, we may ask you for your contact information to follow up on other opportunities to participate.
b. Device and Location Information:
When you visit our Sites, certain information is automatically collected from the devices used to visit our Sites, including the IP address of your computer, the type of browser you use. We also obtain information about incoming domain names and pages visited. This data tells us what pages our users visit and what information they volunteer, such as survey information and/or site registrations.
d. Registered Users:
If you create an account on one of our sites, you will be asked to select a username and provide your e-mail address. When choosing a username, we strongly recommend that you do not use or include your real name. Usernames cannot be changed. Your username and e-mail address are stored in the Website database. Your email address is used to send you an email with a link to set your password or to send you an email with a link to reset your password if you forget it. Once you have created an account, you must contact us to have it deleted. Optionally, you can complete your profile by providing your first name, last name, website (URL) and/or biographical information. These additional details are also stored in the website database. You can edit these details, and your email address, in your profile at any time. You can also choose how your name (your screen name) is displayed to site visitors (for example, in comments you create) in your profile. Your username, first name, last name and e-mail address are accessible by site employees. If you attempt to log in to our site, we will set a temporary cookie to determine whether your browser accepts cookies at all. This cookie contains no personal data and is discarded when you close your browser. If you have an account and log in to a site, we will set several cookies to save your login information and some of your display choices. Login cookies last for two days, and display options cookies last for one year. If you select «Remember Me,» these cookies will persist for two weeks. If you log out of your account, the login cookies will be deleted. It is important that you log out if you are using a public computer. For users who register on one of our sites, we also store the data they provide in their profile indefinitely. All registered users can view, change, or delete most of that data at any time, except for their login name or nickname.
e. Contact/Chat/Email Forms:
g. Marketing Campaigns:
h. Paying Customers:
i. To comply with accounting and legal requirements, we keep financial transaction data in the systems for up to 10 years, depending on the PACT entity you are dealing with.
Use and purpose of the information
PACT processes your personal information for the purposes set out below:
– To comply with legal and/or contractual obligations.
– Create, maintain, customize, and secure your account with us.
– Contacting Third Parties in order to evaluate the quality of the products offered.
– Inform in a timely manner to customers or potential customers of its products and services, current and/or future, as well as the benefits they can access, through the various activities and promotions deployed by PACT.
– Conduct statistical studies to design improvements in the services provided.
– Manage basic administration tasks.
– Respond to specific requests from our customers and other commercial purposes directly or indirectly related to PACT’s own activity.
– To know the profile of the clients for a better market segmentation and to achieve a better commercial development.
– Manage the collection and payment of products and services marketed.
– Manage the entity’s invoicing.
– Conclude, execute and/or perform agreements and contracts with you.
– To develop our marketing activities.
– Comply with our legal obligations in the different jurisdictions where PACT operates.
-Establish, exercise, or defend PACT from legal claims (to which it is or may be subject).
– Publication of images in internal events and sending of information of interest about PACT.
– To protect your safety and PACT’s safety.
– Other activities related to the personnel at your service.
– To provide our services, for example, setting up and maintaining your account, hosting your website, backing up and restoring your website or charging you for any of our paid services.
– To further develop our services, for example, by adding new features that we believe our users will enjoy or that will help them create and manage their websites more efficiently.
– To monitor and analyse trends and better understand how users interact with our services, which helps us improve our services and make them more user-friendly.
– To monitor and protect the security of our services, detect, and prevent fraudulent transactions and other illegal activities, combat spam, and protect the rights and property of PACT and others.
– To share with you offers and promotions extended by PACT and others that we believe will be of interest to you, solicit your feedback or keep you updated about PACT and our products.
– To personalize your experience using our services, provide content recommendations and deliver relevant advertising.
With whom we share your data:
We share information about you in the limited circumstances detailed below and with appropriate safeguards to protect your privacy:
a. Subsidiaries, Affiliates, Employees, and Independent Contractors:
b. Third Parties:
We may share information about you with third parties who need to know your information to provide their services to us. This group includes third parties that help us provide our services to you (such as payment vendors that process your credit and debit card information) and those that help us understand and improve our services (such as analytics vendors). We require vendors to agree to privacy commitments in order to share information with them.
c. As required by law:
We may disclose information about you in response to a subpoena, court order or other governmental requests.
d. To Protect Rights and Property:
We may disclose information about you when we have a good faith belief that disclosure is necessary to protect the property or rights of PACT, third parties or the general public. For example, if we have a good faith belief that there is imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
e. Business Transfers:
f. With your consent:
We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with whom you authorize us to do so, such as social networking services to which you connect your site through our Publish feature.
g. Aggregated and de-identified (or «de-identified») information:
We may share information that has been aggregated or de-identified in a reasonable manner so that the information cannot reasonably be used to identify you. For example, we may publish aggregated statistics about the use of our services.
h. Other site owners:
If you have a WordPress.com account and leave a comment on a site that uses our services (such as a site created on WordPress.com or a site running Jetpack), your IP address and the email address associated with your WordPress.com account may be shared with the administrators of the site where you left the comment.
i. Published Support Requests:
If you submit a request to us (for example, through a support email or one of our feedback mechanisms), we reserve the right to post that request to help us clarify or respond to your request or to help us support other users.
j. Applicable Law:
We may also disclose your personal data when here permitted or required by applicable law.
Rights over personal data
a. Registered User:
If you are a registered user or have left comments on our site, you may request to view or download the data we have about you. Generally, for visitors who have left comments, the data will be their email address, any IP address assigned to them at the time they left comments, and the user agent strings of the browsers they used. All other data is public as posted by visitors. For registered users or paying customers, this will also include profile information and download, payment, and support histories.
b. Marketing communications:
You can also request to be «forgotten» or «unsubscribe» and we will delete any personal identifiable data we have about you. Of course, this excludes data that we need for administrative or security reasons or if we are required by law to retain some of the data.
c. Know, update, correct, amend, and/or rectify:
An individual seeking access, or seeking to know, correct, amend, or delete data, should direct his or her inquiry to firstname.lastname@example.org. We will respond within a reasonable period of time, not to exceed seven (7) business days.
d. Individual rights on personal data:
In any case, in accordance with applicable law, you have the right to:
– Know, update, and rectify your personal data at PACT at any time. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized.
– Request proof of the authorization given to PACT for the processing of data, except for the exceptions provided for in the applicable law.
– Be informed by PACT, upon request, regarding the use given to your personal data.
– To file before the competent authorities, complaints for violations of the provisions of the applicable law and other rules that modify, add, or complement it, after consultation or request before PACT.
– To revoke the authorization and/or request the deletion of the data at any time, except for the exceptions provided for in the applicable law.
You can control the type of information collected through our Sites, for example, by not accepting PACT cookies, by deleting all PACT cookies from your browser, or by not providing personal information when prompted. If you wish to update your personal information with us or change your communication preferences or if you no longer wish to receive communications from us, please click on the «unsubscribe» link in the email to unsubscribe, or inform us by email, phone, or written letter. Please include your exact name and contact details so that we can safely remove you from our mailing list.
Our postal address is: Pact Capital AG, Rue du Rhone 67, 1207 Geneva, Switzerland. You may also contact us by e-mail at email@example.com. If you are a resident of other jurisdictions and wish to exercise your rights, please see the respective section below.
Disclosure and Data Transfer
We disclose potentially personal identifiable information and personal identifiable information only to our employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on our behalf or to provide services, and (ii) that have agreed, in writing, not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using our websites and services, you consent to the transfer of such information to them. We will not rent or sell potentially personal identifiable information and personal identifiable information to anyone. We may be required to disclose an individual’s personal information in response to a lawful law enforcement request, including to meet national security or law enforcement requirements. If we ever do onward transfers of your data to third parties for a purpose other than that for which it was originally collected or subsequently authorized, we would offer you an opt-out option to limit the use and disclosure of your personal data.
How do we transfer your personal data internationally?
Notices to residents of a certain jurisdiction
EU and United Kingdom (UK) Residents
Under applicable law, you have the right to know what personal information we hold about you and you may ask us to make corrections to ensure that it is accurate and up to date. Under applicable law, you also have the right to request deletion of your personal information or to object to the processing of your personal information. If you wish to exercise your rights, please contact us as follows: firstname.lastname@example.org. You may also have the right to lodge a complaint with your data protection authority. PACT is based in Switzerland, but we transfer personal data to countries outside the EU or Switzerland through a series of business-to-business agreements that are based on standard contractual clauses in accordance with European Union law and applicable European Union regulations. If you are a resident of the United Kingdom, the processing of your personal data is subject to the Data Protection Act 2018 and the EU General Data Protection Regulation, both of which set out the obligation to obtain your consent to the processing of your personal data.
Supervisory authority and complaints
If you are a data subject in the EU or EEA and you have a concern that we are unable to resolve regarding our personal data processing practices, you have the right to file a complaint with the data protection authority where you reside or work, or where the alleged breach occurred, as appropriate, or you can contact the Irish authority that oversees data protection issues at https://www.dataprotection.ie/docs/Home/4.html, or +353 57 868 4800. If you are a data subject in the UK, you have the same rights and can exercise them by contacting the Information Commissioner’s Office at https://ico.org.uk/, or +44 303 123 1113.
Residents of Spain
If you have questions or concerns about the use of your personal data, you can contact us at email@example.com. You can also file complaints or claims with the Spanish Data Protection Agency. The processing of your personal data is subject to the Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights and its complementary rules, which establish the obligation to obtain your consent for the processing of your personal data.
Residents of Mexico
You may contact us at firstname.lastname@example.org to assert your privacy rights at any time, including to access your data, to request that your data be updated, amended, or deleted, and to object to the way we use your personal information. You may also contact us to request revocation of your previously granted consent to the extent permitted by law. Through the same contact details, we may inform you about the manner and procedure for dealing with the request submitted. You may also file complaints or claims before the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales. The processing of your personal data is subject to the Federal Law for the Protection of Personal Data in Possession of Individuals and its regulatory provisions, which establish the obligation to obtain your consent for the processing of your personal data.
Residents of Brazil
In accordance with the General Data Protection Law (13.709/2018), individuals whose personal data is collected or processed in Brazil can access, update, correct and delete it at any time. Please contact the Data Protection Officer at email@example.com.
How we protect your data
PACT has technical, physical, and administrative security measures in place to protect your personal information against damage, loss, alteration, destruction or unauthorized use, access, or processing.
Data breach procedures we have in place
If an event occurs where customer data has been lost, stolen, or potentially compromised, our policy is to alert our customers by email within 48 hours of our team becoming aware of the event. We will also report such incident to any required data protection authority. We will work closely with any affected customer to determine next steps, such as any end-user notifications, necessary patches and how to prevent any similar events in the future.