1. Purpose and Scope
beqom understands that the services provided to you or performed on your behalf involve a great deal of trust on your part. We take this trust very seriously, and make it our highest priority to ensure the security and confidentiality of the Personal Data provided to us. Please read the following policy to learn about our privacy practices. By downloading or using the beqom web sites (the "Site") or benefiting from the services available from the Site, you are accepting the practices described herein.
Personal data "(Personal Data") within this policy refers to any information relating to an identified or identifiable natural person in the meaning of:
(i) for data subjects residing in the EEA territory, the Directive (EU) 95/46 EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data;
(ii) for data subjects residing in Switzerland, the Swiss Federal Act on Data Protection 1992.
3. Collection and Use of Personal Data
3.1 Data Collection
The main reason why we collect Personal Data about you is to provide you the services and improve the Site features and content, to administer your user account and to enable you to enjoy and easily navigate the Site and using the services.
When you register through the Site to become a user, when you create or edit your user account and use a service, we will ask you for Personal Data. We may collect the Personal Data that you provide as part of registration and the administration and personalization of your user account, or Personal Data that you provide us by using the services.
beqom may collect the following Personal Data:
(iii) When you register through the Site to become a user, when you create or edit your user account and use a service, we will ask you for Personal Data. We may collect the Personal Data that you provide as part of registration and the administration and personalization of your user account, or Personal Data that you provide us by using the services;
(iv) Contact information, such as name, physical address, telephone number(s), email address, and company;
(v) Transactional information, including information about the products and services you purchase or download or about which you make an inquiry;
(vi) User preferences, such as product requirements, areas of industry interest, newsletters, community choices and other information you select in the customer profile when registering on the Site or indicated by your use of the Site;
We may supplement information you provide with information received from third parties.
3.2 Data Use
beqom uses Personal Data for the purpose of offering the services. The data transmitted to beqom by you may be hosted by beqom or a third party of its choice, as part of the services. We use your Personal Data for the following general purposes:
(vii) to fulfill your requests for services;
(viii) to personalize the promotional offers and content you see, in particular based upon your activity and your transaction history with the Site;
(ix) to improve the services;
(x) to conduct research and compile statistics on usage patterns;
(xi) to provide anonymous aggregate reporting for internal and external partners;
(xii) to manage your user account; to communicate with you in general;
(xiii) to respond to your questions and comments;
(xiv) to notify you about promotional offers and services that may be of interest to you;
(xv) to send you the beqom's newsletter;
(xvii) to comply with legal requirements.
3.3 Legal Requirements
beqom may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.
Your Personal Data may be transferred, accessed and stored as necessary for the uses stated above in accordance with this policy. While beqom may share your personal information with agents and contractors to perform the functions listed above, including order fulfilment and website management, we require that they treat your Personal Data, and limit its use, in accordance with the standards specified in this policy.
4. Electronic Communications Protocols and Cookies
In addition to the information specified above, beqom may collect information about your use of the Site through electronic communications protocols and cookies. As is true when you visit most websites, beqom may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), your IP address, referring website and date and time. Collecting this automatic information helps us customize your experience as a user. It allows us to monitor and analyze use of the Site and services and to increase the Site's functionality and user-friendliness.
We may re-associate the information provided by the technologies directly above with Personal Data.
5. Security Control
beqom is committed to the security of your Personal Data, and has in place physical, administrative and technical measures designed to prevent unauthorized access to that information. These measures, which are aligned with the highest standards in the industry, govern all areas of security applicable to Services and apply to all beqom employees.
In addition, beqom uses standard security protocols and mechanisms to exchange the transmission of sensitive data. When you enter sensitive information on our site, we encrypt it using secure socket layer (SSL) technology.
Where your Personal Data information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, beqom will promptly notify you of the breach by email, fax, or mail.
6. International Transfer
beqom will not transfer any Personal Data received from you outside the European Economic Area or Switzerland except with your prior written consent.
7. Information Sharing and Disclosure
We may share aggregated information that does not include Personal Data and we may otherwise disclose non-identifying information with third parties for analysis and other purposes. Any aggregated information shared in these contexts will not contain Personal Data.
Under certain circumstances, beqom may be required to disclose Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements. beqom may disclose Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency, or in the good faith belief that such action is necessary
(a) to comply with a legal obligation,
(b) to protect or defend our rights, interests or property or that of third parties,
(c) to prevent or investigate possible wrongdoing in connection with the Site or our services,
(d) to act in urgent circumstances to protect the personal safety of users of the Site, our services or the public; or
(e) to protect against legal liability.
Where it relates to Personal Data, we will attempt to refer any request for disclosure of personal information by public authorities, including those received for national security or law enforcement reasons, to the Data Subjects. beqom may, where legally obligated to do so, disclose Personal Data to law enforcement or other government authorities, in which case beqom will notify its Data Subjects of such a request unless prohibited by law to do so.
8. Right to Access your Personal Data
You may at any time, request access to user’s Personal Data collected by beqom, request that inaccurate information be amended, or that the collected personal data be erased. Such request for access must be sent by written notice to : beqom SA, Boulevard de Pérolles 21 c/o Fidexis, 1700 Fribourg, Switzerland or by e-mail at the following address: [email@example.com].
9. How to Delete your User Account
All users may review, update, correct or delete their Personal Data within their user account. If you would like us to delete your Personal Data in our system, please let us know by e-mail at the following address at [firstname.lastname@example.org] and we will attempt to accommodate your request if we do not have any legal obligation to retain the record.
Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request, as well as any content that you have posted transmitted to a third-party. This may be the case even though no Personal Data about your user account remains in our active users’ databases.
You acknowledge that the use of the Internet is not safe and that there are certain inherent risks to your Personal Data. beqom shall make reasonable efforts to protect your Personal Data but it cannot guarantee or warrant that data you provide to beqom is safe and protected from unauthorized third-party access and theft and, therefore, waives all liability in this respect.
10. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Contact requests originating from or relating to the United States of America are automatically forwarded for reply purposes to beqom teams located in the USA.
beqom's participation in the Privacy Shield applies to all Personal Data that is subject to the beqom Privacy Services Policy and is received from the European Union, the European Economic Area and Switzerland. beqom will comply with the Privacy Shield Principles in respect of such Personal Data.
beqom’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, beqom remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the Principles, unless beqom proves that it is not responsible for the event giving rise to the damage.
Please contact our Chief Privacy Officer to the address set out hereunder should you have a Privacy Shieldrelated (or general privacy-related) complaint.
For any complaints that cannot be resolved with beqom directly:
(a) In connection with the data protection of data subjects residing in the EU: beqom has chosen to cooperate with EU data protection authorities (DPAs) and comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints (as further described in the Privacy Shield Principles). Please contact our Chief Privacy Officer to be directed to the relevant DPA contacts.
(b) In connection with the data protection of data subjects residing in Switzerland: beqom commits to comply with the advice of, and cooperate with the Swiss Federal Data Protection and Information Commissioner in relation to such unresolved complaints (as further described in the Privacy Shield Principles).
As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. beqom is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
11. Data Controller
12. Acceptance of the Policy
beqom has been opted-in to 'The LeadLander Contact Network' to help us better profile our website visitors. The LeadLander Contact Network pools together contact information collected through beqom's forms or email campaigns and any other LeadLander opted-in website forms or email campaigns to identify a visitor to the beqom website. Whenever a visitor goes to ANY LeadLander opted-in website, LeadLander can display the visitor by their name and email address in its reports.
13. Contacting us
beqom has appointed a Chief Privacy Officer. If you believe your Personal Data has been used in a way that is not consistent with this policy, or if you have further questions related to this policy, please contact us at [email@example.com].
14. Validity and document management
The current version of this document is effective as of the last update set out in the Change History.
The owner of this document is the Head of Legal, who checks and, if necessary, updates the document at least once a year.
14. Revision History
V1.1: September 2014
V1.2: October 2014
V1.3: December 2014
V1.4: January 2016
V1.5: September 2016
V1.6: November 2016
V1.7: January 2017
V2.0: May 2017
V2.1: September 2017
V2.3: March 2018
V2.4: May 2018