Privacy Policy

1. Principle

We take the protection of your privacy seriously. The following privacy policy details which of your personal data we process if you visit our website, obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA». However, the application of these laws depends on each individual case.

Based on Article 13 of the Swiss Federal Constitution and the data protection regulations of the Federal Government (Data Protection Act, DSG) and in accordance with GDPR, every person is entitled to protection of their privacy and to protection against misuse of their personal data. We comply with these terms. Personal data will be kept strictly confidential and will not be sold or passed on to third parties.

You may contact us at any time for data protection concerns and to exercise your rights under Section 9. Responsible for the data processing that we describe here is

Shulga Natalia
CREAL SA 
Chemin de la Dent d’Oche 1A
1024 Ecublens 
Switzerland
info@creal.com

2. Personal data we collect.

We process various categories of data about you. The main categories of data are the following:

  • Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser that you use to access our electronic offerings. This can help us to provide an appropriate layout of the website. We know through which provider you access our offerings (and therefore also the region) because of the IP address, but usually this does not tell us who you are. Examples of technical data include protocols («logs») that are created in our systems (for example the log of user logins to our website).
  • Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details, the metadata of the communication and  usually also its content (i.e. the content of e-mails, letters, chats, etc.). If we have to determine your identity, for example in relation to a request for information, a request for press access, etc., we collect data to identify you (for example a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years. 
  • Master data includes data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, social media profiles, photos and videos, copies of ID cards; moreover, details of your relationship with us (customer, supplier, visitor, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (for example from the media), or official documents (for example excerpts from the commercial register, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number and credit card data. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives.

In relation to contact persons and representatives of our customers, suppliers and partners, master data includes, for example, name and address, information about the role or function in the company, qualifications and (where applicable) information about superiors, co-workers and subordinates and information about interactions with these persons.

Master data is not collected comprehensively for all contacts. The data collected in an individual case depends mostly on the purpose of the processing activity.

  • Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
  • Behavioral and preference data: Depending on our relationship with you, we try to get to know you better and to tailor our products, services and offers to you. For this purpose, we collect and process data about your behavior and preferences. We do so by evaluating information about your behavior in our domain, and we may also supplement this information with third-party information, including from public sources. Based on this data, we can for example determine the likelihood that you will use certain services or behave in a certain way. The data processed for this purpose is already known to us (for example where and when you use our services), or we collect it by recording your behavior (for example how you navigate our website. We anonymize or delete this data when it is no longer relevant for the purposes pursued, which may be – depending on the nature of the data – between 2 weeks and 24 months (for product and service preferences). This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in Section 10.
    Behavioral and preference data are analyzed on a non-identifiable basis (for example for market research or product development).
  • Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example at events, trade shows, etc.). The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from 6 months for contact tracing and visitor data to several years or more for reports about events with images.

Moreover, we collect and process data about our shareholders and other investors, in addition to master data, including information for registers, in relation to the exercise of their rights and events (for example general meetings). Data relating to you as a shareholder or investor is kept in accordance with corporate law, but in any case for as long as you are invested.

Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.

As far as it is not unlawful we also collect data from public sources, commercial registers, the media, or the internet including social media) or receive data from other companies, from public authorities and from other third parties (such as contractual partners, internet analytics services, etc.). 

3. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 10 and 11 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 4.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 9) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data. We keep this data to document our communication with you and for follow-up inquiries.

We process data for the conclusion, administration and performance of contractual relationships. We conclude various contracts with our business and private customers, suppliers, subcontractors and other parties, such as partners in projects or parties in legal proceedings. In particular, we process master data, contract data and communication data.

In the run-up of a business relationship, personal data – in particular master data, contract data and communication data – is collected from potential customers or other contractual partners (for example in an order form or a contract) or results from a communication. In connection with the conclusion of a contract, we process data to assess creditworthiness and to start a customer relationship. In some cases, this information is reviewed in order to comply with legal requirements.

As part of performing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security service providers, advertising service providers, banks, insurance companies or credit information providers, who may in turn provide data to us), for consulting and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the performance, as are accounting, termination of contracts and public communication.

We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events, exhibitions, etc.) You can object to such contacts at any time or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 10). 

We further process your data for market research, to improve our services and operations, and for product development.

We may also process your data for security and access control purposes.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

This includes, for example, the implementation of health security concepts or the regulated fight against money laundering and terrorist financing. In certain cases, we may also be required to make certain clarifications about our customers («Know Your Customer») or to report to the authorities. Disclosure and information or reporting obligations, for example in connection with supervisory and tax obligations, also require or entail data processing, for example archiving obligations and the prevention, detection and investigation of criminal offenses and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example by a law enforcement or supervisory authority or by a mandated private entity. Furthermore, we process data in order to serve our shareholders and other investors and to fulfill our obligations in this regard. For all these purposes, we process in particular master data, contract data and communication data, but also, under certain circumstances, behavioral data and data from the category of «other data». The legal obligations may arise under Swiss law but also under foreign regulations to which we are subject, as well as self-regulations, industry standards, our own «corporate governance» and instructions and requests from authorities.

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

We may process your data for further purposes, for example as part of our internal processes and administration

4. The basis for processing your data.

Where we ask for your consent for certain processing activities, we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by sending an e-mail to us; see our contact details in Section 1. For withdrawing consent for online tracking, see Section 10. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 3 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law).

Where we receive sensitive personal data (for example health data), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.       

5. Data sharing.

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

  • More
  • Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, shipping companies, advertising service providers, login service providers, banks, insurance companies, This may include health data. For the service providers used for the website, see Section 10. Key service providers in the IT area are Google and Microsoft. Service providers inform about their independent data processing activities in their own privacy statements.
  • Contractual partners including customers: This refers to customers and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate.
  • Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. This may include health data. These authorities act as separate controllers.
  • Other persons: This means other cases where interactions with third parties follow from the purposes set out in Section 3, for example service recipients, the media and associations in which we participate or if you are included in one of our publications.

If we cooperate with the media and share materials with them (for example photos), this may also affect you depending on the circumstances. The same applies if we publish content (for example photos, interviews, quotes, etc.), for example on our website or in our other publications. As part of our business development, we may sell businesses, parts of businesses to others or acquire them from others or enter into partnerships, which may also result in the disclosure of data (including from you, for example as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In relation to communicating with competitors, industry organizations, associations and other bodies, data may be exchanged that also affects you.

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

In many cases, the disclosure of secret data is necessary in order to perform contracts or provide other services. Likewise, non-disclosure agreements generally do not exclude such disclosures of data nor disclosures to service providers. However, depending on the sensitivity of the data and on other circumstances, we ensure that these third parties handle the data appropriately. We cannot comply with your objection to the disclosure of data where the disclosure in question is necessary for our activities.

In addition, we may enable certain third parties to collect personal data from you on our website and at events organized by us (for example press photographers, providers of tools on our website, etc.). Where we have no control over these data collections, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 10 for the website. 

6. Personal data disclosed abroad.

As explained in Section 5, we may disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in the United States; in exceptional cases, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

7. How long do we process and keep your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 2, and for cookies in Section 10. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes. 

8. Data protection.

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely; residual risks are unavoidable.

9. Affected rights

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  •  The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights;

If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 1. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 9 and additional information in Section 10.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example by redacting content that concerns third parties or our trade secrets).

If you do not agree with the way we handle your rights or with our data protection practices, please let us know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here. You can reach the UK supervisory authority here. You can reach the Swiss supervisory authority here.

10. Online tracking.

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data.  However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»).

Cookies are individual codes (for example a serial number) that our server or a server of our service providers or advertising partners transmits to your system when you connect to our website, and that your system (browser, cell phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognized even if your identity is unknown.

Whenever you access a server (for example when you use a website, or because an e-mail includes a visible or invisible image), your visits can therefore be «tracked». If we integrate offers from an advertising partner or a provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in a particular case.

We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» :

  • Strictly necessary cookies: Some cookies are necessary for the functioning of the website. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. These cookies have an expiration date from 1 day of up to 24 months.
  • Performance and Analytics cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent. You can withdraw consent at any time through the cookie settings. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.

We currently use offers from Google Analytics service provider: 

  • Google Analytics: Google Ireland Ltd. (located in Ireland) is the provider of the service «Google Analytics» and acts as our processor. Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both «Google»). Google collects information about the behavior of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals option». Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries. Information about data protection with Google Analytics can be found here and if you have a Google account, you can find more details about Google’s processing here.

11. Processing your data on social network platforms.

We may operate pages and other online presences on social networks and other platforms operated by third parties and collect the data about you described in Section 2 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We process this data for the purposes set out in Section 3, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 10) and for market research. You will find information about the applicable legal basis in Section 4. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the following platforms:

  • Linkedin
    On Linkedin we operate the page www.linkedin.com/company/creal3d. The controller for the operation of the platform for users from Europe is LinkedIn Ireland Unlimited Company, Dubln, Ireland. Their privacy notice is available at www.linkedin.com/legal/privacy-policy. Some of your data will be transferred to the United States. With regard to the data collected and processed when visiting our site for «page insights”, we are joint controllers with LinkedIn Ireland Unlimited Company, Dubln, Ireland. As part of page insights, statistics are created about the actions visitors perform on our site (comment on posts, share content, etc.). It helps us understand how our page is used and how to improve it. We receive only anonymous, aggregated data. 
  • YouTube
    Our website sometimes uses plugins under / or content from YouTube (belonging to Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). When you open our website, it connects directly to the servers of YouTube through your browser. This will transmit to YouTube the information that you have accessed our website. If you are logged in to your YouTube account, your visit to our website, as well as all of your interactions with the plugin (eg, clicking the YouTube button), can be associated with your YouTube profile and saved to YouTube – even if you have not YouTube profile, it can not be ruled out that YouTube will save your IP address. Please also note the YouTube privacy policy: www.google.com/intl/en/policies/privacy. To prevent YouTube from collecting the data when you visit our website, log out before visiting YouTube. To prevent YouTube from gaining general access to your information about websites, you can exclude YouTube plug-ins with an add-on for your browser (e.g., www.youtube.com/user/disconnecters).
  • Twitter
    Functions of the Twitter service are sometimes included on our website. These features are provided by Twitter Inc., Twitter, Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and shared with other users. This data is also transmitted to Twitter. We point out that as a provider of our website we are not aware of the content of the transmitted data and their use by Twitter. For more information, see the Twitter Privacy Policy at www.twitter.com/privacy. You can change your privacy settings on Twitter in the Account Settings at www.twitter.com/account/settings. To prevent Twitter from collecting data when you visit our website, log out before visiting Twitter. In order to prevent Twitter from accessing your personal information via internet pages, you can exclude Twitter social plug-ins with an add-on for your browser (eg “Twitter Blocker”, www.disconnect.me).

12. Privacy Policy update.

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Last updated: 01.09.2023