Statement
DKSH has established a binding Privacy Policy Framework for personal data processing to observe your privacy in line with the European General Data Protection Regulation (GDPR) and the Swiss New Act on Federal Data Protection (nFADP), regardless of where your personal data is processed. This policy is DKSH’s global privacy standard for all DKSH and across all DKSHs affiliated entities.
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how DKSH collects and processes your personal data collected by DKSH online, such as through this website, email and other online tools and applications, but not to offline collection. This Privacy Notice also explains how we safeguard your personal data and interact with third parties that may have access to your personal data and finally, how you can contact us in case of questions or requests.
Name and contact details of controller
The controller within the meaning of Art. 4 (7) of the EU General Data Protection Regulation (GDPR) and Artilce 5 (j) of the nFADP for the processing of your personal data is
DKSH Holding Ltd
Wiesenstrasse 8, P.O. Box 888, 8034 Zurich, Switzerland
Legal basis and personal data we collect about you
As part of your interactions with us, we may collect personal data about you as far as it is necessary to conduct our legitimate interests, to comply with a legal obligation or as agreed by you.
Most of our services do not require any form of registration, allowing you to visit our website without providing us with any information about you. However, some services may require you to register and therefore to provide us with your personal data. The types of personal data we collect depend on the interactions you have with us and the services you use, they may include your title, first name, last name, company, department, email address, phone, street, building number, zip code, city and country.
We may also collect your personal data by tracking how you interact with our website, for example by using cookies. We may collect the Internet Protocol (IP) address, a number assigned to your computer whenever you access our website to conduct system administration and report aggregated information to affiliates, business partners and/or vendors who conduct website analysis and website performance reviews on our behalf. We may further collect your utilization data, e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed. In some instances, we may ask for your consent for collecting and using your personal data for the purposes as outlined in this Privacy Notice, in particular for sending you marketing materials, such as explanatory brochures and information or newsletters or when you submit contact forms or participate in any online survey.
How we use your personal data
We will only collect and use personal data about you as described in this Privacy Notice and as necessary.
- To provide you with our services and to process your order.
- To respond to your requests.
- To manage our customer relationship with you.
- To send you relevant marketing materials.
- To invite you to register for an event.
- To invite you to participate in an online survey.
- To provide you with our media and investor relations information.
- To prevent fraud or other illegal activities, such as willful attacks to DKSH information technology systems.
- To establish or preserve a legal claim or defense or to support any legal or criminal investigation.
- And otherwise to the extent as permitted or required by applicable laws.
We may further anonymize, and aggregate data collected through this website for statistical purposes to help us improve our products and services. Subject to your specific permission that we may collect separately and to your right to request that we cease such activities at any time, we may also use your personal data to send you promotional material or newsletters that we think may be of interest to you.
We may also use data collected through this website to build a profile of your interests and show you relevant content or adverts on other sites.
Cookies and usage tracking
We use cookies, small text files that are automatically placed on your computer’s hard drive when you access certain websites and similar technologies, directly or through third parties, such as web analytics services like Google Analytics. For more information on the cookies we use and to set your preference with respect to cookies please read out Cookie Policy.
Who we share your personal data with
We operate globally and may transfer your personal information to other companies of the DKSH Group or to approved partners in locations around the world. We want you to have the best service and customer experience. For this purpose, we may have to share your personal information outside the country where you have first shared it with us. We only share your personal data with the parties mentioned above and other third parties, including governmental authorities, as far as this is necessary to provide any services that you have requested or authorized by accepting the terms of this Privacy Notice, 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, courts or other governmental regulations, or if such disclosure is otherwise necessary in support of any legal or criminal investigation or legal proceeding.
The personal information we collect from you will be mainly stored in servers located in Malaysia where it will be afforded the level of protection required by applicable privacy legislation.
When we share, use, or transfer personal information outside the country in which the information is collected, we will put in place appropriate measures to legitimize such transfer under applicable privacy legislation, which may include, as applicable, obtaining your consent or implementing adequate contractual safeguards.
In particular, if we transfer your personal data outside the European Union, Switzerland or your country of residence, as applicable, we will take steps to ensure that your data will receive the same level of protection, security measures, and legal enforceability including rights of data subject and effective legal remedies as if it was being processed within the European Union, Switzerland or your country of residence, as applicable. For example, we may include standard contractual clauses adopted by the European Commission in our contracts with third parties or our group companies to ensure there are safeguards in place to protect your personal data.
How we secure your personal data
DKSH has implemented technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, or alteration and against unauthorized disclosure or access to personal data we store. This includes training of our personnel who may have access to your personal data.
How long we store your personal data
We will store your personal data as long as required to fulfill the purposes outlined in this Privacy Notice, unless a longer or shorter retention period is required or permitted by law.
Your rights in respect to your personal data
- Right to Access - you have the right to request access to any of your personal data that DKSH may hold, and to obtain information about the processing of that data.
- Right to Correct - DKSH will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified). You also have a responsibility to ensure that changes in personal circumstances are notified to DKSH so that we can ensure that your personal data is up-to-date.
- Right to Withdraw Consent - in the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Data Portability - where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to DKSH in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to Erasure - you are entitled to have your personal data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal data is unlawfully processed.
- Right to Restriction of Processing - you have the right to restrict our processing of your personal data (that is, allow only its storage) where:
- you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
- the processing is unlawful but you do not want us to erase the personal data;
- we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defence of legal claims; or
- you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether DKSH has compelling legitimate grounds to continue processing.
- Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defence of legal claims.
- Right to Object to Processing Justified on Legitimate Interest Grounds - where we are relying upon our legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- You may also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Data infringes applicable law.
How to contact us
If you have any questions, comments, or concerns about this Privacy Notice, or want to request access to your personal data or exercise your privacy rights, please contact us at:
DKSH Holding Ltd.
Wiesenstrasse 8
8034 Zurich
Switzerland
Online communication channel for privacy inquiries or dataprotection@dksh.com
