At DKSH Group, we are committed to respecting and safeguarding your privacy by handling your personal data responsibly and in accordance with applicable laws. To fully comply with the EU Regulation 2016/679 General Data Protection Regulation (GDPR) and other applicable laws including but not limited to the Swiss Federal Act on Data Protection (FADP) and the UK Data Protection Act (UK DPA), we have updated our data protection notices and processes which regulate how we collect and use your personal data.
- Data Controller
In principle, the Data Controller is the DKSH Group entity with whom you are signing the contract with or with whom you have a contract in place at the time you are reading this Privacy Notice.
- Data Protection Officer Contact Details
In certain countries, DKSH Group has nominated a DPO who can be reachable at the following e-mail address: dataprotection@dksh.com (Attn. “DPO” or “Data Protection Officer”).
- What personal data about you do we collect and why do we collect it?
DKSH collects and processes certain types of personal data about you, depending on the relationship that you have with us as well as applicable laws, and as far as this is necessary to pursue our legitimate business interests (such as to support our internal operations, to communicate with you and to otherwise carry out our normal business operations), to comply with a legal obligations, or to perform any contract with you or as agreed by you.
We may collect the following personal data about you:
Personal data category |
Types of personal data |
General and contact information |
your name (including prefixes and suffixes which may indicate your gender), address, telephone, fax, e-mail, social network information (e.g. Facebook, Twitter, LinkedIn) and other relevant contact details; job and educational information as well as information about the preferred way and time of communication |
Financial and transactional information |
information collected in connection with sales and promotional activities; financial information including transaction details, bank and credit card details, payment methods and terms, travel information for invoicing purposes and quality reporting concerning products
|
- How we collect your personal data.
We may collect your personal data directly from you, via our contractual relationship, at congresses or via our contact forms or indirectly from public sources or third-parties, such as LinkedIn.
- Processing activities.
We may process your personal data for the following reasons, and other compatible reasons:
Reason for processing |
Description |
Legal basis |
Facilitating our interactions with you |
This includes maintaining our business relationship by providing you with information related to our products and services, sales and delivery of products and, inviting you to a congress and soliciting expert advice regarding new products and services.
|
Legitimate interest (in case contract is in place)
Otherwise: explicit consent
|
Managing our relationship
|
This includes managing our product and service delivery, contract management and related financial transactions including invoicing for services, travel and expense management and carrying out quality reporting concerning our products
|
Contract
|
Complying with legal requirements and DKSH policies
|
This includes processing your personal data for income tax and national insurance deductions, record-keeping and reporting obligations, conducting audits, complying with inspections and other requests from law enforcement or other public authorities;
|
Legitimate interest
|
Claim and litigation management
|
This includes processing your processing data for protecting ourselves in case a claim or a lawsuit is brought against us, responding to legal processes such as subpoenas; pursuing legal rights and remedies; defending litigation and managing any internal complaints or claims, etc.
|
Legitimate interest
|
Research and insights
|
This includes strategic internal research and data analytics based on aggregated data
|
Legitimate interest
|
- Who may have access to your personal data and why?
Due to our global operations, we may share, or otherwise disclose your personal data to our affiliated companies and further to trusted clients from which we buy products and/or to which we provide services, customers that purchase products from us or business partners providing services on our behalf, such as for technical support, to evaluate the usefulness of our website, for marketing purposes or other types of service delivery. We have contracts in place with these parties to ensure that personal data is processed based on our instructions and in compliance with this Privacy Notice and any other appropriate confidentiality and security measures.
We only share your personal data with the parties mentioned above and other third parties, including governmental authorities, as far as this is reasonably necessary for the purposes as outlined in this Privacy Notice. We may share personal data about you, as necessary in the case of a reorganization or divestiture of our business through sale, merger or acquisition, to protect your, our, or others’ rights, property or safety, to maintain the security of our services or if we are required to share your personal data to comply with applicable laws, court or other governmental regulations, or if such disclosure is otherwise necessary for support of any legal or criminal investigation or legal proceeding.
Please note that DKSH companies and subsidiaries, as well as authorities, customers and suppliers to whom we may disclose your personal data, may be located outside of your country of domicile, including countries in Asia and potentially the United States of America, whose data protection laws may differ from those in the country in which you are located. In such cases, we will ensure that appropriate safeguards are in place to protect your personal data by implementing appropriate legal mechanisms, such as EU Standard Contractual Clauses. For more information, please contact us as described in the section “How to contact us”.
- How long will your personal data be stored?
DKSH will store your personal data as long as necessary for the purposes outlined in this Privacy Notice, unless a longer or shorter retention period is required or permitted by law.
In principle, personal data are stored as long as there is a contractual relationship with you and, after such period has elapsed, for an additional ten (10) year period. Please note that this period may vary based on the applicable local legislation (it can be extended or lowered).
Personal data processed for marketing purposes are generally stored as long as you do not withdraw your consent and/or enforce your data privacy rights (please see below at section 9).
- How is your personal data secured?
DKSH has implemented technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss or alteration and unauthorized disclosure or access to your personal data. These measures include training of our personnel who may have access to your personal data.
- What rights do you have in respect to your personal data?
You have the right to request information on what personal data we hold about you (s.c. right of access – art. 15 GDPR) and to request the correction (art. 16 GDPR) or deletion (art. 17 GDPR) of your personal data that is held by a third party with whom we conduct business or by us. Also, you have the right, under certain circumstances, to object to the processing of your personal data, where such processing is based on our legitimate interest and to request the restriction of the processing of your personal data. Further, you have a right to data portability and the right to lodge a complaint to your supervisory authority. If the processing is based on your consent, you have the right to withdraw your consent at any time. Please note that the withdrawal of consent will not affect the processing which has already occurred. Also, please note that these privacy rights are not absolute, and we reserve the right to enforce the restrictions imposed by law.
To make such a request, please contact us as described in the section “How to contact us” below. After providing proof of identity, we will respond to your requests generally within one month.
- How to contact us?
In case of doubt you can always send us an e-mail to: dataprotection@dksh.com.
Please bear in mind that your controller may vary depending on the contractual relationship you currently have with DKSH Group.
The full list of DKSH entities present with the European territory is available at the following link: https://www.dksh.com/global-en/home/about-us/what-we-do/locations.
This Privacy Notice is effective from January 2024
Version: 2.0