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 intended to comply with the Swiss Federal Act on Data Protection («FADP») and its implementing ordinance («DPO») and, where applicable, the EU General Data Protection Regulation («GDPR»). Which laws apply depends on the circumstances of the relevant processing.

We process personal data in accordance with applicable data protection law and the principles of lawfulness, good faith, transparency, proportionality, purpose limitation and data security. We do not sell personal data. We may disclose personal data to third parties where necessary for the purposes described in this Privacy Notice and in accordance with applicable law.

You may contact us at any time for data protection concerns and to exercise your rights under Section 9. The controller responsible for the processing described in this Privacy Notice is:

CREAL SA
Chemin de la Dent d’Oche 1A
1024 Ecublens Switzerland

Privacy contact:
Natalia Shulga
natalia.shulga@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. Business correspondence and records are retained for the period required by applicable legal or contractual retention obligations and CREAL’s retention schedule. Where a 10-year statutory retention period applies, relevant records may be kept for that period. Other communications are deleted or anonymized when no longer necessary, subject to legitimate documentation and evidentiary needs.
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 behaviour (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 2 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 (for example, legal or contractual 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.

Where lawful and proportionate, we also collect data from public sources, commercial registers, the media or the internet (including social media), or receive data from other companies, public authorities and other third parties (such as contractual partners and internet analytics services).

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 may process your data for further compatible purposes, for example as part of our internal processes and administration, provided that the processing remains lawful, proportionate and transparent.

This includes, for example, the implementation of health and safety requirements and, where applicable to CREAL’s activities, legally required sanctions, anti-money-laundering or know-your-customer checks and reporting obligations. 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.

Under Swiss law, private-sector processing is governed by the principles and requirements of the FADP. Where processing would otherwise unlawfully infringe personality rights, a justification may be required, such as consent, an overriding private or public interest, or a legal basis. Where the GDPR applies, we rely on an applicable legal basis under Article 6 GDPR and, for special categories of data, Article 9 GDPR.

Where we ask for consent, we will inform you about the relevant processing purposes. You may withdraw consent at any time with effect for the future using the contact details in Section 1 or, for online tracking, the cookie settings described in Section 10. Withdrawal does not affect processing carried out lawfully before withdrawal and does not prevent processing based on another applicable justification or legal basis.

Depending on the circumstances, our processing may be necessary to enter into or perform a contract, to comply with legal obligations, to protect legitimate interests of CREAL or third parties, or for another purpose permitted by applicable law. Where the GDPR applies, the relevant legal basis may include Article 6(1)(b), (c) or (f) GDPR.

Our legitimate interests may include operating and improving our business and website, information security, prevention of misuse, relationship management, marketing within legal limits, establishment and defence of legal claims, and compliance and corporate governance, subject to the interests and rights of the persons concerned.

Where we process sensitive personal data, we apply the additional requirements of the FADP and, where applicable, the GDPR. We limit such processing to what is necessary and use an appropriate justification or legal basis, for example express consent where required, compliance with legal obligations, or the establishment, exercise or defence of legal claims.

In relation to our contracts, website, services and products, legal obligations, legitimate interests and the other purposes set out in Section 3, we may disclose your personal data to third parties, in particular to the following categories of recipients:

Service providers: We work with service providers in Switzerland and abroad that process personal data on our behalf, jointly with us or as independent controllers, depending on the service and allocation of responsibilities (for example IT and cloud providers, shipping and logistics providers, advertising and analytics providers, login providers, banks and insurers). Where a provider acts as our processor, we require it contractually to process personal data only as permitted and to implement appropriate data-security measures. This may include sensitive personal data where necessary. For website providers, see Section 10. Key IT providers currently include 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, recipients may be located outside Switzerland. The principal destination states for the services described in this Privacy Notice include countries in the EU/EEA and the United States. Additional destination states may apply depending on the relevant provider or transaction; where required by Article 19(4) FADP, we provide information on the destination state and the applicable safeguards.

We disclose personal data abroad in accordance with Articles 16–18 FADP. Where the Federal Council recognises an adequate level of protection, data may be transferred on that basis. For transfers to the United States, adequacy applies to recipients certified under the Swiss-U.S. Data Privacy Framework. Where the destination or recipient is not covered by an adequacy decision, we use appropriate safeguards, such as standard contractual clauses recognised by the FDPIC with the necessary Swiss adaptations, or another mechanism permitted by the FADP.

In limited circumstances, an exception under Article 17 FADP may permit a transfer without an adequacy decision or the safeguards described above, for example where the statutory conditions for consent, contract performance, overriding public interest, legal proceedings or data made generally accessible by the data subject are met.

Internet communications may technically be routed through other countries. We take reasonable measures to ensure that transfers for which CREAL is responsible are handled in accordance with the FADP and the safeguards described above.

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.

If a data-security breach occurs, CREAL assesses the risks without undue delay. Where a breach is likely to result in a high risk to the personality or fundamental rights of affected persons, CREAL will notify the Federal Data Protection and Information Commissioner (FDPIC) as soon as possible in accordance with Article 24 FADP and will inform affected persons where required for their protection or by the FDPIC.

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 about whether and what personal data we process about you and the information required by Article 25 FADP;

The right to request correction of inaccurate personal data;
The right to request deletion or destruction of personal data, or cessation of unlawful processing, subject to applicable retention obligations and other legal limitations;
The right, where the statutory conditions are met, to obtain personal data you provided to us in a commonly used electronic format or request its transfer to another controller;
The right to withdraw consent with effect for the future where processing is based on consent;
Where applicable, rights relating to automated individual decisions, including the right to express your point of view and request review by a natural person in the cases provided by law;
Any additional rights available under the GDPR where that law applies, including the right to object to certain processing and, in applicable cases, to request restriction of processing.

If you wish to exercise these rights, please contact us using the details in Section 1. We may take proportionate steps to verify your identity. Requests under the FADP are generally answered within 30 days, subject to statutory extensions, limitations and exceptions.

You may also have rights in relation to parties that process personal data as separate controllers. Please contact them directly regarding their processing. Information on categories of recipients appears in Section 5 and information on website and platform providers appears in Sections 10 and 11.

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 cookies and similar technologies in accordance with applicable Swiss data-protection and telecommunications requirements. Technologies that are strictly necessary for the website may be used without consent where legally permitted. Where consent is required, including for processing that cannot otherwise be justified or for certain tracking, profiling or personalised-advertising uses, the relevant technology is activated only after valid consent. You may withdraw or change your choices at any time through the cookie settings, without detriment unrelated to the processing purpose.

We distinguish the following categories of «cookies» :

Strictly necessary cookies: These technologies are required to provide the website or a function expressly requested by you, maintain security or remember essential settings. Session cookies normally expire when the browser session ends; persistent necessary cookies are retained only for the period needed for their stated purpose. Current durations should be displayed in the cookie settings or cookie list.
Performance and analytics cookies: To optimise our website and understand its use, we may use analytics technologies, including services provided by third parties. Where these technologies require consent, they are not activated before consent is given. You can withdraw consent at any time through the cookie settings. The current provider, purpose and retention period for each non-essential technology should be shown in the cookie settings or cookie list.

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.

Google Analytics is used only where the required consent has been obtained. Personal data may be processed in Ireland, the United States and other locations used by Google. Cross-border disclosures for which CREAL is responsible are handled in accordance with Section 6, including an adequacy mechanism such as the Swiss-U.S. Data Privacy Framework where the recipient is certified, or other appropriate safeguards where required. Information about Google Analytics and Google’s own processing is available in Google’s privacy information.

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. For users in Switzerland and LinkedIn’s other “Designated Countries”, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, is the platform controller. LinkedIn’s current privacy information is available at www.linkedin.com/legal/privacy-policy. LinkedIn may process data in the United States and other countries under its applicable transfer mechanisms. Where CREAL and LinkedIn act as joint controllers for page-insight functions, the allocation of responsibilities is governed by the applicable platform terms.
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).
X (formerly Twitter) CREAL may link to or embed functions from X. For users in the EU, EFTA States (including Switzerland) and the United Kingdom, X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, is the controller identified by X for its platform processing; X also lists a Swiss representative. Interactions with X features may allow X to receive information about your visit and associate it with an X account where applicable. For current information about X’s processing, international transfers and privacy controls, please refer to X’s Privacy Policy at https://x.com/en/privacy. Where optional X content or tracking is embedded on our website, it should be loaded only in accordance with the cookie/consent rules described in Section 10.

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: 18.08.2026