Global Privacy Policy

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.

beqom provides this Global Privacy Policy to describe our procedures regarding the collection, use and disclosure of personal data we collect or receive from the visitors of the Site.

2. Definitions

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

3.1.1 Purpose

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.

3.1.2 Extent

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;

(xvi) to prevent potentially prohibited or illegal activities; to enforce the Terms of Use of the Site; and as otherwise described to you at the point of collection;

(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.

3.4 Subcontractors

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.

Like many other websites, beqom also uses cookies, embedded URLs and embedded pixels to capture additional information. Cookies are small data files, which are transferred to a computer's hard disk in order to memorize information like registration IDs and passwords. We further utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by users. We will utilize cookies for identifying your language settings of your device, the promotional offers you subscribed to in and/or session cookies. Session cookies are, unlike persistent cookies, deleted from your computer when you log off from the Site and then close your browser. Please note that you can always choose not to receive a cookie file by enabling your Web browser to refuse cookies or to prompt you before accepting a cookie. However, if you refuse cookies you may not be able to use all portions of the Site or all functionality of the services.

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.

By using the Site, you acknowledge and agree that Personal Data you submit to beqom will be hosted by beqom or a third party of its choice for an indefinite period of time within the European Economic Area or Switzerland. You hereby agree that your Personal Data may be transferred to European Economic Area countries or Switzerland - and maintained on - computers located in the European Economic Area territory or Switzerland, where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of Personal Data represent your explicit agreement to such transfer.

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: [security.officer@beqom.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 [security.officer@beqom.com] 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 and its controlled U.S. subsidiaries (beqom) comply with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area and Switzerland to the United States, respectively. beqom has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. 

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

The data controller in the meaning of the European Directive 95/46 EC, of the European Regulation 2016/679, and of the Swiss Federal Act on Data Protection 1992 is beqom SA, Boulevard de Pérolles 21 c/o Fidexis, CH- 1700 Fribourg, Switzerland.

12. Acceptance of the Policy

beqom reserves the right to make any changes to this policy as beqom deems necessary or desirable without prior notification to you. Users will be informed of the new Privacy Policy, but it is your responsibility to verify regularly this policy to be informed of any changes. Your continued use of the services after any such changes or after explicitly accepting the new Privacy Policy upon using the Site and/or the services shall constitute your consent to such changes.

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 [security.officer@beqom.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