Last revised: 22 August 2023. To see prior version, click here.
Synpulse Holding AG and its subsidiaries are the entities within Synpulse Network are providing this Privacy Notice and are referred to herein as “we”, “us”, or “our”. Synpulse is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative, and physical security measures.
This privacy notice below explains what information we gather about you, what we use it for and who we share it with (the “Privacy Notice”). It also sets out your rights and who you can contact for more information or queries.
We may process information about you that: (i) you provide to us, (ii) that we obtain from third parties or (iii) that is publicly available. This information may include your name, age, gender, date of birth and contact details. It may also include ‘sensitive’ or ‘special categories’ of personal data, such as dietary requirements or mobility information. For a more detailed description of the information about you that we may process, please see below.
We collect and process information about you and/or your business to enable us, Synpulse Holding AG and any if its subsidiaries’ to:
For a more detailed description of how we use information about you, please see below.
When we send you information we think you might be interested in, you have the right to unsubscribe at any time by contacting us as set out here, or by following the unsubscribe instructions in our communications.
We may share information about you across the Synpulse Network, and with some third parties. For more information please see below.
We may transfer some information about you to countries outside the European Economic Area that have less stringent data protection laws. When we do this, we will make sure your information remains adequately protected. For more information please see below.
Your rights under data protection laws include the right to:
For more information about your privacy rights please see below.
If you have any questions or comments about privacy issues, or wish to exercise any of the rights set out above, please write to Head of Data Protection Officers, Synpulse Holding AG, Sonnenbergstrasse 19, CH-6052 Hergiswil, Switzerland, or email email@example.com.
Scroll down to see the privacy notice in full to take you to the more detailed sections of the notice.
In this statement:
“Data Protection Legislation” means (i) the Swiss Federal Act on Data Protection of 19 June 1992 (FDPA), (ii) the New Swiss Federal Act on Data Protection (nFADP) of 01 September 2023, and (iii) the EU General Data Protection Regulation 2016/679 (GDPR); together with all other applicable legislation relating to privacy or data protection and including any statute or statutory provision which amends, extends, consolidates or replaces the same.
EU-US and Swiss-US Data Privacy Framework
Synpulse participates in the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework*. Click here to learn more.
*We will not rely on the Swiss-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework until they enter into force, but we adhere to their required commitments in anticipation of their doing so“Synpulse Network” refers to one or more Synpulse entities, organized as a Swiss privately held group of legal entities held by one holding company. Synpulse Holding AG is a company registered in Switzerland with registered number CHE-103.557.601 and registered office at Sonnenbergstrasse 19, 6052 Hergiswil, Switzerland.
“Process” means any operation performed on information about you, including to collect, record, organize, structure, store, alter, use, transfer, destroy or otherwise make available.
This privacy notice applies to Synpulse Holding AG with registered office address Sonnenbergstrasse 19, 6052 Hergiswil, Switzerland, and the entities we own or control (“Synpulse”, “we”, “us” or “our”).
We are committed to protecting your privacy and handling your information openly and transparently.
This privacy notice explains how we will collect, handle, store and protect information about you when:
When we refer to “our website” or “this website”, we mean the specific webpage of synpulse.com and any webpage with such ending and specific webpages which contain:
Our website comprises various global, country, regional and practice-specific information. All of this is provided by Synpulse Holding AG or one of its subsidiaries or their related entities (collectively, the “Synpulse Network”). To learn more about Synpulse, its member firms, and their related entities, please see Legal Information.
This privacy notice also contains information about when we share your personal data with other members of the Synpulse Network and other third parties (for example, our service providers).
In this privacy notice, your information is sometimes called “personal data”. We may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.
If you provide us with information via the Synpulse website or when using Synpulse apps, you agree, in accordance with Art. 6 (1) (a), 7 of GDPR (General Data Protection Regulation), that we may use your personal data in the context of the principles laid down below. This also applies to a possibly required transfer of personal data to foreign member firms of the Synpulse Network. Please note in this regard that certain links (electronic links) on this website leads to websites of third parties, which, because of their national autonomy and independence as well as potential differences in local law, are not subject to the content of this privacy notice. Synpulse accepts no liability for the content and / or data protection treatment of data put on these other websites.
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.
When we provide services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you. We may also collect personal data from you when you use this website.
We may process your data because:
The personal data we process may include your:
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:
We may also process personal data relating to ethnic or racial origin (for example, any multicultural networks you belong to), or about your political opinions (inferred from information you give us about political associations you belong to or have donated to).
We will typically seek separate permission from you in writing to process these special categories of personal data.
If you choose not to provide, or object to us processing, the information we collect (see section 10 below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
When our client or another third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy notice.
If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
We process information about you and/or your business to enable us and other members of the Synpulse Network to provide our services to you, and to meet our legal or regulatory obligations.
Some of your personal data may be used for other business purposes. Below are some examples.
Use of personal data to provide services to our clients
We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:
We may also use your personal data to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:
Use of personal data for other activities that form part of the operation of our business
We may also use your personal data in connection with:
(a) sending you thought leadership or details of our products and services;
(b) contacting you for feedback on services;
(c) sending you event invitations; and
(d) other marketing or research purposes;
(a) the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
(b) the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
Use of personal data collected via our website
In addition to the above, we may also use your personal data collected via our website:
We are required by law to set out in this privacy notice the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:
(a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
(b) to prevent fraud;
(c) to protect our business interests;
(d) to ensure that complaints are investigated;
(e) to evaluate, develop or improve our services or products; or
(f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
In respect of personal data of data subjects resident in a EU country, legal basis for processing of data described above (to the extent such data is to be considered personal data) are:
In connection with any of the purposes outlined in the “How we use your personal data?” section above, we may disclose details about you to:
Our website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these social media applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these social media applications might not be handled in line with this privacy notice.
Information we hold about you may be transferred to other countries (which may include countries outside the European Economic Area (“EEA”):
Such countries may have less stringent privacy laws than the EEA or Switzerland, so any information held can become subject to such laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, several countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
When we, or our permitted third parties, receive or transfer your personal data outside the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.
We may also transfer your personal data when:
If your personal data is transferred outside the EEA in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
We may share non-personal, anonymized and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
The transmission of data over the internet (including by e-mail) is never completely secure. So, although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
We seek to ensure that we only keep your personal data for the longest of:
You have various rights in relation to your personal data. In particular, you have a right to:
If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations about your rights as a data subject.
To help us ensure that your information is up to date, let us know if any of your personal details change using the contact details set out in section 12.
You may also use the contact details in section 12 if you wish to make a complaint relating to your privacy.
We and other members of the Synpulse Network may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of interest to you.
You may, at any time, ask us and/or other members of the Synpulse Network not to send marketing information to you by following the unsubscribe instructions in communications from us, or contacting us in the way described in section 12 below.
If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about privacy issues, or you wish to raise a complaint about how we are using your information you can contact us in the following ways:
We may modify or amend this privacy notice from time to time.
When we make changes to this privacy notice, we will amend the revision date at the top of this page. The modified or amended privacy notice will apply from that date. We encourage you to review this notice periodically to remain informed about how we are protecting your information.