Privacy and Cookie Policy

Art. 1  Our Business

2CS SA is the data controller for the information you provide. Our address is:

Consulting, Convergence & System SA

Avenue de Champel 29

1206 Geneva

Switzerland

We can be contacted at info@2cs.ch.

Art. 2  Scope of our Privacy Policy

This Privacy Policy informs you about how 2CS SA collects and uses your data. It applies to any information we collect by any means, including through our Site, the use of cookies, e-mail, telephone or information provided orally. If you disagree with the specifications provided by the Policy, please notify us immediately at info@2cs.ch. Without such notification, the use of this Site signifies that you agree with all terms of this Policy.

Art. 3  Collected Information

3.1 When Using Our Services

When you use our services, we may ask you to provide us with certain personal information needed for your identification, such as:

• your name and, if applicable, the name of the company you represent
• your occupation
• your full address
• your e-mail
• data relating to the payment of potential invoices, such as bank or credit card details, data related to your tax system (tax ID, domiciliation, etc.)

We need such personal data to be able to contact you, to perform the contract with you related to our services or because you have asked us to take specific step before entering into a contract in respect to these services.

It is our policy to collect only the minimum information required to handle and complete your requests and inquiries. If you do not agree with one or more aspects of this data collection Policy, please be aware that our services may be drastically reduced or unavailable.

For security reasons and to prevent any fraud, we may ask you for additional information to check your identity, your address, your solvency or such other similar information, imperative for the risk management and for the compliance with the regulatory aspects governing the performance of our services. This falls under the scope of our legitimate interests as a business.

When you voluntarily exchange business contact details with us, we will use your personal data for advertising and marketing if we have your consent to do so, or if we consider it in our legitimate interests to maintain a business relationship with you or the company you represent.

3.2 Use of Cookies

By using various cookies, our Site automatically receives and records information about your connection to our Site, including:

• your IP address
• date and time of visit
• country location
• the type of search engine used
• country

The cookies indicated above help us administer the Site, improve your browsing experience by personalizing the Site and conduct market research. They are thus collected on the basis of the legitimate interests of 2CS SA. We believe that your experience of the site would be adversely affected if you opted out of the cookies we use.

Any additional cookies, such as interest-based advertising cookies, require your consent. You can choose which types of cookies you agree to, and withdraw your consent at any time, as seen under art. 8 of the present Policy.

3.3 Legally Required Data Collection

2CS SA does not intend to collect sensitive information through its Site unless it is legally required to do so. Examples of sensitive information include:

• date on the intimate sphere,
• race or ethnic origin,
• political opinions,
• religious or philosophical beliefs,
• trade union membership,
• physical or mental health,
• genetic data,
• biometric data,
• sexual life or sexual orientation,
• social security measures,
• administrative or criminal proceedings and sanctions,
• and criminal records.

2CS SA asks that you do not provide sensitive data of such nature when using its Site.

Art. 4  Use of your Personal Data

We use the information mentioned in Art. 3.1 and 3.2 to:

• Check if you already exist in our databases
• Stay in touch with you and be able to contact you regarding the services you have requested
• Be able to analyze your request for services and provide you, if necessary, with a detailed estimate.
• To inform you of the status of your orders (e.g. production notice, delivery notice, billing notice, etc.)
• To manage the feedback and quality process, billing and order closing procedures
• To provide you with new offers, services, promotions or details about new products we consider that may be of interest to you. You can at any time notify us that you do not wish to receive this type of communication at info@2cs.ch. You can unsubscribe from emails at any time by clicking the ‘unsubscribe’ button at the bottom of an email.

4.1 Access within 2CS SA

We may disclose your personal data to our employees who are in contact with you or who are responsible for marketing. Statistical data about our Site’s visitors may also be accessed by our employees in marketing and/or our IT department who are responsible for analyzing such data and for improving our Site.

2CS SA limits the access to the collected data on the “need to know” principle.

4.2 Sharing with Third Parties

2CS SA does not sell to third parties data provided directly or indirectly by its customers.

Our third-party agents and contractors may have access to your personal information to help carry out the services they are performing for us and in order to achieve our mandate in the most effective manner possible. We will only use third-party agents and contractors who can provide adequate safeguards to ensure your data is stored and handled securely.

We may disclose your personal information in response to legal action, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or act regarding illegal activities, and as otherwise required by law.

4.3 External web services

We use Google Analytics to track visitors.

You can read Google Analytics terms of service here.

Visitor comments may be checked through an automated spam detection service.

Some external web services may be embedded on our Site, such as for example Google Maps. These sites may use information about usage of embedded content. If you are not logged in to these external services, then they will not know who you are but are likely to gather anonymous usage information.

Our Site also links to other websites. 2CS SA is not responsible for the privacy practices or the content of such other websites. If you provide any personally identifiable information through any such third-party website, your transaction will occur on such third party’s website (and not on this Site) and the personally identifiable information you provide will be collected by and controlled by the privacy policy of that third party. We recommend that you review the privacy policy of these sites.

4.4 Retention of Data

We will keep hold of your data for no longer than necessary. The length of time we retain it will depend on any legal obligations we have, the nature of any contracts we have in place with you, the existence of your consent or our legitimate interests as a business.

The information that you send for the purpose of an inquiry will be kept for as long as is required to respond and complete your inquiry, and for a further 12 months before deleting your information, unless you provide consent for future contact during your inquiry.

The data that you send during the processing of an order will be saved for a maximum period of six months.

After termination of a contract, we retain that information for a period of 10 years following the end of the financial year during with the contract was completed. This is the period of retention required by Swiss law.

Backup copies in our systems are, if not required differently by law, erased after a period of 10 years. This is the period of retention required by Swiss law. For contractual data, processing is limited after termination of the contract.

We are also obliged to maintain records in accordance with our legal or regulatory obligations, such as audits and certifications. If you would like to know which information is concerned by this, you can contact us at info@2cs.ch

4.5 Transfer Overseas and Safeguards

As a general rule, we do not transfer your data to a third country. A third country means a country outside the EU. If such a case arises, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred overseas, in accordance with applicable data protection and privacy laws.

Art. 5  Scope of our Liability (3rd Level)

You should not, under any circumstances, share any sensitive or personal information via our Site, unless specifically required by one of our officers. You are personally responsible for keeping your eventual login credentials confidential and of any activity that occurs through our Site from your account.

Our confidentiality commitment is limited to the information that 2CS SA collects from its current or prospective customers. We exclude all liability for the information contained in the documents eventually provided to 2CS SA for the performance of its services. You are solely responsible for anonymizing, if necessary, the content of such documents or for providing us with the necessary instructions regarding the confidentiality of such documents.

Art. 6  Data Protection and Storage

2CS SA data is stored in Switzerland with ISO 27001 security standards-compliant proprietary infrastructure and firmware. The data is protected by physical means, such as alarm and video surveillance systems on our premises, external security companies for the surveillance of our premises, electronic means of protection, such as physical firewalls and software, processes and means of data encryption and internal procedures, such as the sharing of information with our employees on a “need to know” basis.

2CS SA strives to ensure the highest security of the data provided. However, we cannot guarantee absolute security or full protection against systemic risks, such as possible cyber-attacks and data theft.

We will notify you of the intrusion in our system concerning your personal data, within 48h from its discovery, by using the contact information you have provided to us.

We are available to assist our customers in the traceability of their data. Requests in this respect can be sent to us at info@2cs.ch.

Art. 7  Your Rights as a Data Subject

You have rights as a data subject. These rights are:

• The right to be informed – this means we must inform you how we are going to use your personal data. We do this through this Privacy Policy and by informing you how your data will be used each time we collect it.
• The right of access – you have the right to access your personal data (e.g. data that is about you) that we hold. This is called a subject access request. We must respond to your request within one month. To request access to your data, please email info@2cs.ch. It is very helpful if you tell us what of your personal data you are seeking.
• The right to rectification – if you think the data we hold on you is incorrect, tell us so we can put it right.
• The right to erasure – you have the right to request that we delete your data. We will do so, provided that we do not have a compelling reason for keeping it. To request this, please email info@2cs.ch
• The right to restrict processing – you can change your communication preferences (therefore restricting how we communicate with you) by contacting info@2cs.ch. There are also certain other circumstances in which you can suppress the processing of your personal data. To request this, please email info@2cs.ch
• The right to data portability – you can obtain and reuse your personal data for your own purposes across different services. To request this, please email info@2cs.ch
• The right to object – you have the right to object to :
  • direct marketing from 2CS SA or from third parties we have shared your data with for direct marketing purposes. You can opt out of direct marketing any time by contacting info@2cs.ch. There will also be instructions on how to unsubscribe included in any direct marketing message that we send to you.
  • Any processing where our lawful basis is of legitimate interest (see above). If you would like to formally object to any of our legitimate interest processing, please email info@2cs.ch
• Rights in relation to automated decision making and profiling – this is not something we do at 2CS SA. If that ever changes, this Policy will be updated accordingly.

At 2CS SA we are committed to upholding your rights as a data subject. If you think we have not done so, please contact info@2cs.ch

Art. 8  Consent

Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us at info@2cs.ch.

If you would like to withdraw your consent or object to receiving any direct marketing to which you previously opted-in, you can do so using the unsubscribe tool in that communication (if it is an email), or by writing to us. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

If you have provided consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to amend your preferences. 

Art. 9  Integrality

Our Privacy Policy is to be read in conjunction with the Terms of Use of our Site. Together, they apply to anyone using the Site. Unless a written communication to info@2cs.ch is received in the case of a disagreement, they are deemed to be read and accepted.

Art. 10  Severability

If any provision of this Policy is found to be unenforceable, only such provision will be void. The remainder of the Policy shall stand fully enforceable.

2CS SA

Revised and approved in Geneva

22 September 2022