PRIVACY POLICY

Version dated January 1, 2025

In this Privacy Policy, we, Swiss Relocation Services GmbH (hereinafter referred to as “we” or “us”), explain how we collect and otherwise process personal data.

Personal data refers to any information that relates to an identified or identifiable individual.

If you provide us with personal data about other individuals (such as family members or coworkers), please ensure that those individuals are aware of this Privacy Policy and only share their personal data with us if you are authorized to do so and if the personal data is accurate.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”) and the Swiss Data Protection Act (“DSG”). However, whether and to what extent these laws apply depends on the specific circumstances of each case.

The terms used are gender-neutral.

Authorized Representative

Unless otherwise specified in individual cases, Swiss Relocation Services GmbH is responsible for the data processing described here. If you have any data protection concerns, please contact us at the following address:

Swiss Relocation Services GmbH, Hubackerstrasse 31, 8105 Regensdorf, or to [email protected]

Collection and Processing of Personal Data

We primarily process personal data that we receive from our customers and other business partners—as well as from other individuals involved in our business relationships with them—or that we collect while operating our websites from its users. To the extent permitted, we also obtain certain data from publicly available sources (such as debt collection registers, land registers, commercial registers, the press, and the Internet), as well as from government agencies and other third parties (such as credit bureaus and address brokers).

In addition to the data you provide to us directly, the categories of personal data we receive about you from third parties include, in particular, information from public records, information we obtain in connection with administrative and judicial proceedings, information related to your professional roles and activities (so that we can, for example, enter into and conduct business with your employer with your assistance), information about you in correspondence and meetings with third parties, credit reports (to the extent that we conduct business with you personally), information about you provided to us by people in your circle (family, advisors, legal representatives, etc.) so that we can conclude or execute contracts with you or involving you (for example, references), Your delivery address, powers of attorney, information regarding compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, distribution partners, and other contractual partners of ours regarding your use of or provision of services (for example, payments made, purchases made), Information about you from media and the internet (to the extent this is appropriate in a specific case, for example in the context of a job application, press review, marketing/sales, etc.), your addresses, and, if applicable,

Purposes of data processing and legal bases

We use the personal data we collect primarily to enter into and fulfill our contracts with our customers and business partners, particularly in connection with the following activities:

the full range of relocation services

As part of our business operations, we collect personal data for transactions with our customers and for the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations both domestically and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this capacity.

Darüber hinaus bearbeiten wir Personendaten von Ihnen und weiteren Personen, soweit erlaubt und es uns als angezeigt erscheint, auch für folgende Zwecke, an denen wir (und zuweilen auch Dritte) ein dem Zweck entsprechendes berechtigtes Interesse haben:

• Offering and further developing our products, services, websites, and other platforms on which we are present;
• Communication with third parties and handling their inquiries (e.g., job applications, media inquiries);
• Reviewing and optimizing methods for needs analysis for the purpose of directly targeting customers, as well as collecting personal data from publicly available sources for the purpose of customer acquisition;
• Advertising and marketing (including the organization of events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you may object at any time, and we will then place you on a do-not-call list to prevent further promotional communications);
• Asserting legal claims and defending against legal disputes and administrative proceedings;
• Prevention and investigation of criminal offenses and other misconduct (for example, conducting internal investigations and analyzing data to combat fraud);
• Guarantees regarding our operations, particularly our IT systems, websites, apps, and other platforms;
• The purchase and sale of business units, companies, or parts of companies, as well as other corporate transactions and the associated transfer of personal data; measures for business management; and, to the extent necessary, compliance with legal and regulatory obligations as well as the internal policies of Swiss Relocation Services GmbH.

To the extent that you have given us your consent to process your personal data for specific purposes (for example, when you sign up to receive newsletters or undergo a background check), we will process your personal data within the scope of and based on this consent, provided that we have no other legal basis and that such a basis is required. Consent that has been given may be revoked at any time; however, this has no effect on data processing that has already taken place.

Cookies, tracking, and other technologies related to the use of our website

We typically use “cookies” and similar technologies on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by your web browser when you visit our website. When you visit this website again, this allows us to recognize you, even if we do not know who you are. In addition to cookies that are used only during a session and deleted after your visit to the website (“session cookies”), cookies can also be used to store user settings and other information over a specific period of time (for example, two years) (“persistent cookies”). However, you can set your browser to reject cookies, store them only for a single session, or delete them early. Most browsers are set by default to accept cookies. We use persistent cookies to save your user settings (such as language, auto-login), to better understand how you use our services and content, and to display offers and advertisements tailored to you (which may also occur on websites operated by other companies; however, these companies do not learn from us who you are—even if we ourselves know—because they only see that the same user is on their website who is also on a specific page of ours). (This can also happen on other companies’ websites; however, we do not disclose your identity to them—even if we know it ourselves—because they only see that the same user is on their website who was also on a specific page on our site.) Some of these cookies are set by us, while others are set by business partners with whom we collaborate.

If you block cookies, certain features (such as language selection, the shopping cart, and the checkout process) may no longer work.

In our newsletters and other marketing emails, we sometimes include visible and invisible image elements—where permitted—which, when loaded from our servers, allow us to determine whether and when you have opened the email. This helps us track and better understand how you use our offerings so that we can tailor them to your needs. You can block this in your email program; most are set up by default to do so.

By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these technologies. If you do not wish to do so, you must adjust the settings in your browser or email program accordingly.

We sometimes use Google Analytics or similar services on our websites. These are third-party services that may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), which relies on Google LLC (based in the U.S.) as a data processor (both “Google”, www.google.com), which allows us to measure and evaluate website usage (non-personally identifiable). For this purpose, permanent cookies set by the service provider are also used. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before being forwarded to the U.S., thereby preventing them from being traced. We have disabled the “Data Sharing” and “Signals” settings. Although we can assume that the information we share with Google does not constitute personal data for Google, it is possible that Google may use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles, and link this data to these individuals’ Google accounts. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its privacy policy. The service provider simply tells us how our respective websites are used (no information about you personally).

We also use plug-ins from social networks such as Facebook, Twitter, YouTube, Pinterest, Xing, LinkedIn, and Instagram on our websites. You can easily identify these (typically by the corresponding icons). We have configured these elements so that they are disabled by default. If you enable them (by clicking on them), the operators of the respective social networks can detect that you are on our website and where you are, and may use this information for their own purposes. The processing of your personal data is then the responsibility of that operator in accordance with its privacy policy. We do not receive any information about you from them.

Sharing of Data with Third Parties

In the course of our business activities and for the purposes set forth in Section 3, we may, to the extent permitted and as we deem appropriate, disclose such information to third parties, whether because they process it on our behalf or because they wish to use it for their own purposes. This applies in particular to the following entities:

• Our service providers (such as banks and insurance companies), including data processors (such as IT providers);
• Dealers, suppliers, subcontractors, and other business partners;
• Clients;
• domestic and foreign authorities, government agencies, or courts;
• Media;
• the general public, including visitors to websites and social media;
• Competitors, industry organizations, associations, organizations, and other bodies;
• Purchasers or parties interested in acquiring business units;
• other parties in potential or actual legal proceedings;

all recipients together.

If we share data with third parties, we comply with legal requirements and, in particular, enter into data processing agreements or similar arrangements with the respective recipients to protect your personal data.

Transfer of data abroad

We may disclose data to individuals, government agencies, organizations, companies, or other entities abroad. In particular, we may transfer personal data to any country where our data processors process personal data.

If a recipient is located in a country without adequate legal data protection, we contractually require the recipient to comply with applicable data protection laws (for this purpose, we use the European Commission’s revised Standard Contractual Clauses, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exception provision. An exception may apply, for example, in the case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires such disclosure, if you have consented, or if the data in question has been made publicly available by you and you have not objected to its processing.

Retention period for personal data

We process and store your personal data for as long as necessary to fulfill our contractual and legal obligations or to achieve the purposes for which the data is processed; this includes, for example, the duration of the entire business relationship (from the initiation and execution of a contract through to its termination) as well as any subsequent period required by statutory retention and documentation obligations. In this context, it is possible that personal data may be retained for the period during which claims can be asserted against our company and to the extent that we are otherwise legally obligated to do so or legitimate business interests require it (for example, for evidentiary and documentation purposes). As soon as your personal data is no longer required for the aforementioned purposes, it will generally be deleted or anonymized to the extent possible. For operational data (e.g., system logs), shorter retention periods of twelve months or less generally apply.

Data security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse.

We take the protection of personal data into account from the very beginning—during the development or selection of hardware, software, or processes—by implementing appropriate technical and organizational measures. Furthermore, we ensure that data protection is the default setting.

Obligation to Provide Personal Data

As part of our business relationship, you must provide the personal data necessary for establishing and conducting a business relationship and fulfilling the associated contractual obligations (you are generally not legally required to provide us with data). Without this data, we will generally not be able to enter into or fulfill a contract with you (or the entity or person you represent). Furthermore, the website cannot be used if certain information necessary to ensure data transmission (such as your IP address) is not disclosed.

Rights of the data subject

Under the data protection laws that apply to you, and to the extent provided for therein (such as in the case of the GDPR), you have the following rights:

• the right to request information from us regarding whether we process your data and, if so, what data we process;
• the right to have data corrected if it is inaccurate;
• the right to request the erasure of data;
• the right to request that we provide you with certain personal data in a commonly used electronic format or transfer it to another controller;
• the right to withdraw consent, to the extent that our processing is based on your consent;
• the right to request additional information necessary to exercise these rights.

Please note, however, that we reserve the right to invoke the legal restrictions provided for by law, for example, if we are required to retain or process certain data, have an overriding interest in doing so (to the extent we are permitted to invoke such an interest), or need the data to assert claims. If you incur any costs, we will inform you in advance. We have already provided information regarding the possibility of withdrawing your consent in Section 3. Please note that exercising these rights may conflict with contractual agreements and may result in consequences such as early termination of the contract or financial implications. In such cases, we will inform you in advance, unless this is already regulated by contract.

Exercising these rights generally requires that you provide clear proof of your identity (for example, by providing a copy of your ID if your identity is otherwise unclear or cannot be verified). To exercise your rights, you may contact us at the address provided in Section 1.

In addition, every data subject has the right to seek legal redress or to file 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).

Changes

We may update this Privacy Policy at any time without prior notice. The most recent version published on our website is the one that applies. If this Privacy Policy is part of an agreement with you, we will notify you of any changes via email or by other appropriate means in the event of an update.