Privacy Policy

In this privacy policy, we, PSM Paper Solutions Manfioletti GmbH (hereinafter referred to as PSM Paper Solutions Manfioletti GmbH, we, or us), describe how we collect and process personal data. This privacy policy does not constitute a final description; other privacy-related statements may regulate specific matters. For the purposes of this privacy policy, personal data refers to any information that relates to an identified or identifiable individual.

1. Responsible Party and Contact Information

The responsible entity for the data processing described here is Paper Solutions Manfioletti GmbH, unless stated otherwise in individual cases. Privacy inquiries can be directed to us via mail or email, accompanied by a copy of the ID or passport for user identification: Täfernstrasse 18, 5405 Baden-Dättwil / +41 56 470 08 87 / info@ps-m.ch. +41 56 470 08 87 / info@ps-m.ch.

2. Collection and Processing of Personal Data

We primarily process personal data in the following categories of processing:

• Customer data from clients for whom we provide or have provided services.
• Personal data indirectly obtained from our customers during service delivery.
• Data collected during visits to our website
• Data from newsletter usage
• Participation data from events we organize
• Data from communications or visits
• Data from other contractual relationships, such as suppliers, service providers, or consultants.
• Data from applications
• Data we are required to collect for legal or regulatory reasons.
• Data processed to fulfill our due diligence or other legitimate interests, such as avoiding conflicts of interest, preventing money laundering, ensuring data accuracy, checking creditworthiness, ensuring security, or enforcing our rights.

For more detailed information, please refer to the respective processing categories described in section 5.

3. Categories of Personal Data

The type of personal data we process depends on your relationship with us and the purpose for which we process the data. In addition to your contact information, we also process other information about you or individuals related to you. In some cases, this information may include particularly sensitive personal data.

We collect the following categories of personal data, depending on the purpose for which we process it:

• Contact Information (e.g., name, first name, address, phone number, email).
• Customer Information (e.g., date of birth, nationality, marital status, occupation, title, job title, passport/ID number, AHV number).
• Risk Assessment Data (e.g., credit information, commercial register data).
• Financial Information (e.g., bank account details).
• Mandate Data depending on the assignment (e.g., tax information, statutes, protocols, projects, contracts, employee data such as salary, social security, accounting data, beneficial ownership, ownership structures).
• Website Data (e.g., IP address, device information (UDI), browser information, website usage data (analytics and plugin usage).
• Application Data (e.g., resume, work certificates).
• Marketing Information (e.g., newsletter sign-up).
• Security and Network Data (e.g., visitor lists, access control, network and email scanning, phone call lists).

Where permitted, we also obtain data from publicly accessible sources (e.g., debt collection registers, land registers, commercial registers, press, internet) or receive such data from our clients, their employees, authorities, courts, and other third parties. In addition to the data you provide to us directly, the categories of personal data we receive from third parties about you include in particular information from public registers, data obtained in connection with administrative and judicial proceedings, information related to your professional roles and activities (so that we can, for example, conclude and execute transactions with your employer), information from correspondence and meetings with third parties, credit information, information provided by persons close to you (e.g., family, advisors, legal representatives), information to comply with legal requirements such as anti-money laundering and export restrictions, information from banks, insurers, distributors, and other contractual partners in connection with the use of services by you (e.g., payments made, purchases made), and information from the media and internet (if relevant in a specific case, such as in the context of an application).

4. Purposes of Data Processing and Legal Basis

4.1. Provision of Services

We primarily process personal data that we receive in the context of our mandate relationships with our clients and other contractual relationships with business partners, as well as from additional parties involved.

The personal data of our clients generally includes the following information:

• Contact Information (e.g., name, first name, address, phone number, email, and other contact information).
• Personal Information (e.g., date of birth, nationality, marital status, occupation, title, job title, passport/ID number, AHV number, family circumstances, etc.).
• Risk Assessment Data (e.g., credit information, commercial register data, sanction lists, specialized databases, internet data).
• Financial Information (e.g., bank account details, investments, or ownership stakes).
• Mandate Data depending on the assignment, e.g., tax information, statutes, protocols, employee data (e.g., salary, social security), accounting data, etc.
• Particularly Sensitive Personal Data: This may include particularly sensitive personal data, such as health data, religious beliefs, or social assistance measures, particularly if we provide services in payroll processing or accounting.

‍

We process this personal data for the described purposes based on the following legal grounds:

• Performance or execution of a contract with the individual concerned or in favor of the individual concerned, including contract initiation and any enforcement (e.g., consulting, fiduciary services).
• Fulfillment of a legal obligation (e.g., when we act as auditors or are required to disclose information).
• Protection of legitimate interests (e.g., for administrative purposes, improving our quality, ensuring security, risk management, enforcing our rights, defending ourselves against claims, or checking for potential conflicts of interest).
• Consent (e.g., to send you marketing information).

‍

4.2. Indirect Data Processing from Service Delivery

When we provide services to our clients, we may also process personal data that we have not directly collected from the individuals concerned or personal data of third parties. These third parties are typically employees, contact persons, family members, or individuals otherwise associated with the client or the individuals concerned. We need this personal data to fulfill contracts with our clients. We receive this personal data from our clients or third parties commissioned by our clients. The individuals whose data we process for this purpose are informed by our clients about the processing of their data. Our clients may refer to this privacy policy for that purpose.

The personal data of individuals related to our clients generally includes the following information:

• Contact Information (e.g., name, first name, address, phone number, email, other contact information, marketing data).
• Personal Information (e.g., date of birth, nationality, marital status, occupation, title, job title, passport/ID number, AHV number, family circumstances, etc.).
• Financial Information (e.g., bank account details, investments, or ownership stakes).
• Mandate Data depending on the assignment, e.g., tax information, statutes, protocols, employee data (e.g., salary, social security), accounting data.
• Particularly Sensitive Personal Data: This may include particularly sensitive personal data, such as health data, religious beliefs, or social assistance measures, particularly if we provide services in payroll processing or accounting.
• We process this personal data for the described purposes based on the following legal grounds:
• Performance or execution of a contract with the individual concerned or in favor of the individual concerned (e.g., when we fulfill our contractual obligations).
• Fulfillment of a legal obligation (e.g., when we act as auditors or are required to disclose information).
• Protection of legitimate interests, particularly our interest in providing optimal service to our clients.

‍

4.3. Website Usage

To use our website, no personal data needs to be disclosed. However, the server captures a range of user information with every visit, which is temporarily stored in the server log files.

There is no association with a specific person during the collection of this general information/data. The collection of this information/data is technically necessary to display our website and ensure its stability and security. This information is also collected to improve the website and analyze its usage.

This includes the following information in particular:

• Contact Information (e.g., name, first name, address, phone number, email).
• Other information you provide to us via the website.
• Automatically transmitted technical information, user behavior, or website settings (e.g., IP address, UDI, device type, browser, number of clicks on the page, opening the newsletter, clicking on links, etc.).

‍

We process this personal data for the described purposes based on the following legal grounds:

• Protection of legitimate interests (e.g., for administrative purposes, improving our quality, analyzing data, or promoting our services).
• Consent (e.g., for the use of cookies or the newsletter).

‍

4.4. Newsletter Usage

If you subscribe to our newsletter, we will use your email address and other contact details to send you the newsletter. You can subscribe to our newsletter with your consent. Mandatory information for sending the newsletter includes your full name and email address, which we store after your registration. The legal basis for processing your data in connection with our newsletter is your consent to receive the newsletter. You can withdraw this consent and unsubscribe from the newsletter at any time.

4.5. Event Participation

When you participate in an event organized by us, we collect personal data to organize, conduct, and potentially provide you with additional information afterward. We also use your information to inform you of further events. During the events, we may take photographs or videos, and this material may be published internally or externally.

This includes the following information in particular:

• Contact Information (e.g., name, first name, address, phone number, email).
• Personal Information (e.g., occupation, function, title, employer, dietary preferences).
• Images or Videos.
• Payment Information (e.g., bank account details).

‍

We process this personal data for the described purposes based on the following legal grounds:

• Performance or execution of a contract with the individual concerned or in favor of the individual concerned, including contract initiation and enforcement (enabling participation in the event).
• Protection of legitimate interests (e.g., conducting events, promoting information about our events, providing services, efficient organization).
• Consent (e.g., to send marketing information or create image material).

‍

4.6. Direct Communication and Visits

When you contact us (e.g., via phone, email, or chat), or we contact you, we process the necessary personal data for that purpose. We also process personal data when you visit us. In such cases, you may be required to provide your contact details before your visit or at reception. These details will be retained for a certain period to protect our infrastructure and information.

For conducting telephone conferences, online meetings, video conferences, and/or webinars ("Online Meetings"), we generally use the "Microsoft Teams" service.

We process the following information in particular:

• Contact Information (e.g., name, first name, address, phone number, email).
• Communication metadata (e.g., IP address, duration of the communication, communication channel).
• Recordings of conversations, e.g., during video conferences.
• Other information uploaded, provided, or created by the user during the use of the videoconferencing service, as well as metadata used for maintaining the provided service. For additional information on the processing of personal data by Microsoft Teams, please refer to their privacy policy.
• Personal Information (e.g., occupation, function, title, employer).
• Time and Reason for the Visit.

‍

We process this personal data for the described purposes based on the following legal grounds:

• Performance or execution of a contract with the individual concerned or in favor of the individual concerned, including contract initiation and enforcement (providing a service).
• Protection of legitimate interests (e.g., ensuring security, traceability, and managing and administering customer relationships).

‍

4.7. Applications

You can submit your application for a position with us by post or via the email address provided on our website. Application documents and all personal data disclosed to us as part of the application process will be treated with strict confidentiality, will not be disclosed to third parties, and will only be processed for the purpose of handling your application for a position with us. Unless you give us contrary consent, your application file will be returned to you or deleted/destroyed after the application process, unless it is subject to statutory retention obligations. The legal basis for processing your data is your consent, the fulfillment of the contract with you, and our legitimate interests.

We process the following information in particular:

• Contact Information (e.g., name, first name, address, phone number, email).
• Personal Information (e.g., occupation, function, title, employer).
• Application Documents (e.g., cover letter, certificates, diplomas, resume).
• Evaluation Information (e.g., assessment by personnel consultants, references, assessments).

‍

We process this personal data for the described purposes based on the following legal grounds:

• Protection of legitimate interests (e.g., hiring new employees).
• Consent.

‍

4.8. Suppliers, Service Providers, Other Contractual Partners

If we enter into a contract with you to provide a service for us, we process personal data from you or your employees. This data is necessary for communication and for us to use your services. We may also process this personal data to check whether there is a conflict of interest related to our activities and to ensure that we do not assume any unintended risks, such as money laundering or sanctions.

We process the following information in particular:

• Contact Information (e.g., name, first name, address, phone number, email).
• Personal Information (e.g., occupation, function, title, employer).
• Financial Information (e.g., bank account details).

‍

We process this personal data for the described purposes based on the following legal grounds:

• Performance or execution of a contract with the individual concerned or in favor of the individual concerned, including contract initiation and enforcement.
• Protection of legitimate interests (e.g., avoiding conflicts of interest, protecting the company, enforcing legal claims).

‍

5. Tracking Technologies

We use cookies on our website. These are small files that your browser automatically creates and stores on your device (laptop, tablet, smartphone, etc.) when you visit our website.

The information stored in the cookie is related to the specific device being used. However, this does not mean that we immediately know your identity through this information. The use of cookies serves, on the one hand, to make the use of our services more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited certain pages on our website. These cookies are automatically deleted after you leave our website.

Additionally, we use temporary cookies to optimize user-friendliness, which are stored on your device for a specific period. If you visit our website again to use our services, it will automatically recognize that you have already visited us and which inputs and settings you made, so you do not have to enter them again. On the other hand, we use cookies to statistically record the use of our website and evaluate it for the purpose of optimizing our services for you. These cookies enable us to automatically recognize that you have already visited our site when you return. These cookies are automatically deleted after a defined time.

The data processed by cookies is necessary for the mentioned purposes. Most browsers automatically accept cookies. However, you can configure your browser to prevent cookies from being stored on your computer or to always display a warning before a new cookie is created. However, completely disabling cookies may prevent you from using all the features of our website.

6. Web and Newsletter Analysis

To gain insights into the use of our website, improve our online services, and advertise to you on third-party websites or social media, we use the following web analysis tools and re-targeting technologies: Google Analytics and Squarespace (newsletter).

These tools are provided by third-party vendors. The information collected about website usage through cookies or similar technologies is typically transmitted to the third-party provider’s server. Depending on the third-party provider, these servers may be located abroad.

Transmission of data usually occurs with truncated IP addresses, preventing identification of individual devices. Such information transfers by third-party providers occur only due to legal requirements or in the context of data processing agreements.

6.1. Google Analytics

We use Google Analytics, the web analytics service of Google LLC, Mountain View, California, USA, for our websites, with Google Limited Ireland responsible for Europe ("Google"). To disable Google Analytics, Google provides a browser plug-in at https://tools.google.com/dlpage/gaoptout?hl=en. Google Analytics uses cookies. These are small text files that make it possible to store specific user-related information on the user's device. These allow Google to analyze the use of our website. The information collected by the cookie about your use of our website (including your IP address) is generally transmitted to and stored on a Google server in the USA. Please note that Google Analytics has been extended on this website with the code "gat._anonymizeIp();" to ensure the anonymized collection of IP addresses (so-called IP masking). When IP anonymization is active, Google shortens IP addresses within member states of the European Union or other contracting states of the European Economic Area Agreement, so no conclusions about your identity can be made. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. Google may associate your IP address with other data from Google. For data transfers to the USA, Google has committed to signing and complying with the EU Standard Contractual Clauses.

6.2. Google Maps

We use Google Maps (API) from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, with Google Limited Ireland responsible for Europe) on our website. Google Maps is a web service for displaying interactive (land) maps to visually present geographical information. By using this service, our location is displayed to you, and it makes navigation easier. When you access subpages containing Google Maps, information about your use of our website (such as your IP address) is transmitted to and stored on Google's servers in the USA. This occurs regardless of whether Google provides a user account that you are logged into or whether there is no user account. If you are logged into Google, your data will be directly associated with your account. If you do not want your data to be linked to your Google profile, you must log out before activating the button. Google stores your data (even for users not logged in) as user profiles and analyzes them.

For data transfers to the USA, Google has committed to signing and complying with the EU Standard Contractual Clauses.

6.3. Social Media Plugins

We use so-called social media plugins ("plugins") from third parties on our website. The plugins are recognizable by the logo of the respective social network. Through the plugins, we offer you the ability to interact with social networks and other users. We use the following plugins on our website: LinkedIn and Instagram. When you access our website, your browser establishes a direct connection to the third-party provider's servers. The content of the plugin (e.g., YouTube videos) is transmitted directly from the respective third-party provider to your browser and embedded in the page.

Data transfer to display content (e.g., publications on Twitter) occurs regardless of whether you have an account with the third-party provider and are logged in. If you are logged in to the third-party provider, the data collected by us is also directly assigned to your existing account with the third-party provider. If you activate the plugins, the information is also published in the social network and displayed to your contacts there. For the purpose and scope of the data collection and further processing and use of the data by the third-party provider, as well as your rights and options for protecting your privacy, please refer to the privacy notices of the third-party providers. The third-party provider stores the data collected about you as user profiles and uses it for advertising, market research, and/or demand-oriented design of its website. This evaluation also takes place for users who are not logged in to display demand-oriented advertising and inform other users of the social network about your activities on our website. If you want to prevent third-party providers from associating the data collected on our website with your personal profile in the respective social network, you must log out of the corresponding social network before visiting our website. You can also completely prevent the plugins from loading using specialized add-ons for your browser, such as "Ghostery" (https://www.ghostery.com/) or "NoScript" (http://noscript.net/).

6.4. Newsletter Tracking

We use the software Squarespace for sending our newsletters. This software allows newsletters to be sent and analyzed. To perform this analysis, we collect device and access data. To collect this data, the newsletter contains a pixel [[if this applies to your tool]]. The newsletter or the websites accessed through it are also tracked with cookies. A pixel is an image file that is saved on the recipient's device.

Using these technologies, we obtain information about whether the newsletter was delivered, opened, and which content was clicked. We use this information to improve our newsletter and our offerings. You can prevent the placement of a pixel by disabling HTML in your email program (this may vary depending on the email program).

7. Data Sharing and Data Transmission

We only share your data with third parties if it is necessary to provide our service, if these third parties provide a service for us, if we are legally or administratively obligated to do so, or if we have an overriding interest in sharing the personal data. We will also share personal data with third parties if you have consented or requested us to do so.

Not all personal data is transmitted in encrypted form by default. Unless explicitly agreed with the customer otherwise, accounting data, payroll administration data, and payroll statements are transmitted unencrypted.

The following categories of recipients may receive personal data from us:

• Service providers (e.g., IT service providers, hosting providers, suppliers, consultants, lawyers, insurers).
• Third parties within the scope of our legal or contractual obligations, authorities, government agencies, courts.

‍

We conclude contracts with service providers who process personal data on our behalf, obligating them to ensure data protection. Our service providers are mostly located in Switzerland or the EU / EEA. Certain personal data may also be transmitted to the USA (e.g., Google Analytics data) or, in exceptional cases, to other countries worldwide. If data transfer to countries without an adequate level of data protection is necessary, it will be based on the EU Standard Contractual Clauses (e.g., in the case of Google) or other appropriate instruments.

8. Retention Period of Personal Data

We process and store your personal data for as long as necessary to fulfill our contractual and legal obligations or for the purposes pursued with the processing, i.e., for the duration of the entire business relationship (from initiation and processing to the termination of a contract) and beyond in accordance with legal retention and documentation obligations. It is possible that personal data will be retained for the period during which claims can be made against our company (i.e., particularly during the statutory limitation period) and as long as we are otherwise legally obliged or have legitimate business interests in retaining the data (e.g., for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned 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.

9. Data Security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, and controls.

10. Obligation to Provide Personal Data

In the context of our business relationship, you must provide the personal data necessary to establish and carry out a business relationship and fulfill the associated contractual obligations (you are generally not legally required to provide us with data). Without this data, we will not be able to conclude or process a contract with you (or the entity or person you represent). The website also cannot be used if certain information necessary to ensure data transmission (such as IP address) is not disclosed.

11. Your Rights

In connection with our processing of personal data, you have the following rights:

• Right to information about the personal data stored about you, the purpose of the processing, the origin, as well as the recipients or categories of recipients to whom personal data is disclosed.
• Right to rectification if your data is incorrect or incomplete.
• Right to restrict the processing of your personal data.
• Right to request the deletion of the processed personal data.
• Right to data portability.
• Right to object to data processing or withdraw consent to the processing of personal data at any time without giving a reason.
• Right to file a complaint with a competent supervisory authority, if provided by law.

‍

To exercise these rights, please contact the address provided in section 1.

Please note, however, that we reserve the right to invoke the legal limitations provided, for example, if we are obliged to retain or process certain data, have an overriding interest in doing so (as far as we are entitled to rely on it), or require it to assert claims. If there are any costs for you, we will inform you in advance.

12. Changes to the Privacy Policy

We explicitly reserve the right to change this privacy policy at any time.

Last updated: February 2024.