PRIVACY POLICY
DT SWISS GROUP

WHY AND FOR WHAT PURPOSE?

This Privacy Policy regulates the processing and the storage of personal data provided to DT Swiss.


This Contract complies with EU Regulations, particularly with Article 6(1) point f of the Regulation (EU) no. 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). 

Furthermore the privacy policy does comply with the California Consumer Privacy Act (CCPA).

This Policy applies to all the DT Swiss group companies all over the world, regardless of whether they are based in the European Union.


Biel/Bienne, February 2024

Frank Böckmann
President of the Board of Directors

Maurizio D’Alberto
Vice-President of the Board of Directors

OUR PRIVACY POLICY

PRINCIPLES

Responsible treatment of physical and electronic data is very important to DT Swiss; this applies to personal and company data.

This Policy defines the principles pursuant to which DT Swiss collects, processes, stores and uses personal and company data.

The Policy applies to DT Swiss group companies all over the world.


SCOPE OF PROCESSING

We process our contact partners’ personal data only to the extent required for rendering contract services. Personal data of our contact partners’ is generally only processed with the prior consent of the user. An exception applies in cases where prior consent cannot be obtained for practical reasons and statutory regulations permit processing of the data.


LEGAL BASES

Where we obtain consent from the data subject for personal data processing operations, point (a) of Article 6(1) of the EU General Data Protection Regulation (GDPR) is the legal basis for personal data processing.

If processing personal data is necessary for the performance of a contract to which the data subject is party, Article 6 (1), point (b) GDPR serves as a legal basis. This also applies to processing operations that are necessary in order to take steps prior to entering into a contract.

Where personal data processing is necessary for compliance with a legal obligation to which our company is subject, the legal basis is Article 6(1), point (c) GDPR.

If processing is necessary for the purposes of any legitimate interest pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, the legal basis for processing is Article 6(1), point (f) GDPR.

Furthermore the specific legal requirements of the California Consumer Privacy Act (CCPA) were fulfilled.


DATA PROCESSING

The following list shows important personal data processing areas with DT Swiss and the related contents and purposes:

AREA

ACTIVITY EXTENT OF
DATA COLLECTION
PURPOSE

TERM/WITHDRAWAL/ERASURE

Marketing

Website Statistical values via
Google Analytics
Web use analysis

Withdrawal via the below link:
https://tools.google.com/dlpage/gaoptout?hl=en

  Facebook Facebook pixels
Personal contact data
Personalised advertising

Communications to
marketing@dtswiss.com

  Newsletter Personal contact data Personalised newsletters

Newsletter un-subscription

Personnel

JobAbo Personal contact data JobAbo delivery

JobAbo un-subscription

  TalentPool Personal contact data Personalised newsletters

Communications to
youngtalent@dtswiss.com

  Application Personal contact data;
application documents
Applications for posts

Automatically upon recruiting
process termination of
communications to
personal@dtswiss.com

  Work contract Personal data relevant
for employment
Employment relationship

Pursuant to legal requirements

  PrivatOrders Personal data relevant
for employment
Order processing

At the end of the legal retention
period

Sales

Orders Personal data relevant
for employment
Order processing

At the end of the legal retention
period

Purchasing

Orders Personal data relevant
for employment
Order processing

At the end of the legal retention
period

Service

Service
processing
Personal data relevant
for employment
Service ticket processing

At the end of the legal retention
period

IT

IT operation Relevant personal data IT services
maintenance/monitoring

Pursuant to legal require

STORAGE DURATION

The data subject’s personal data will be erased or blocked once the purpose of storage ceases to apply. In addition, the data can be stored if this has been provided for by European or national legislators in union law regulations, laws or other legislation which is governed by the controller. The data will also be blocked or erased once a retention period specified by the aforementioned standards expires, unless further retention of the data is required for the conclusion or performance of a contract.


RIGHT TO ERASURE

a) Erasure obligation
You may demand the controller to erase your personal data without undue delay and the controller is obliged to erase such data without undue delay where one of the following grounds applies:

  • (1) the personal data concerning you is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
  • (2) you withdraw your consent on which the processing is based according to Article 6(1), point (a) or of Article 9(2), point (a) of the GDPR, and where there is no other legal ground for the processing
  • (3) you object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR;
  • (4) the personal data concerning you has been unlawfully processed;
  • (5) Your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • (6) the personal data concerning you has been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

b) Information to third parties

c) Where the Controller has made your personal data public and is obliged pursuant to Article 17(1) of the GDPR to erase them, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copies or replications of those personal data.

d) Exceptions
The right to erasure does not apply to the extent that processing is necessary

  • (1) for exercising the right of freedom of expression and information;
  • (2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • (3) for reasons of public interest in the area of public health in accordance with Article 9(2), points (h) and (i) as well as Article 9(3) of the GDPR;
  • (4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the GDPR insofar as the right referred to in point (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • (5) for the establishment, exercise or defence of legal claims.

The right to erasure also complies with the right to delete of the California Consumer Privacy Act (CCPA).

 

RIGHT TO BE INFORMED

If you have exercised the right to rectification, erasure or restriction of processing vis-à-vis the controller, the latter is obliged to notify all recipients, to whom your personal data have been disclosed, of such rectification or erasure of the data or restriction of processing, unless this proves to be impossible or produces disproportionate burdens.
You have the right vis-à-vis the controller to be informed of such recipients.

The right to be informed also complies with the right to know of the California Consumer Privacy Act (CCPA). Furthermore the right to non-discrimination of the California Consumer Privacy Act (CCPA) is fulfilled at any time and for all respective usages of personal data.

RIGHT TO DATAPORTABILITY

You have the right to receive any personal data related to you that has been provided by you to the controller in a structured, commonly used and machine-readable format. Moreover, you have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided, where

(1) the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR or on a contract pursuant to point (b) of Article 6(1) GDPR; and

(2) the processing is carried out by automated means.

In exercising such right, you further have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. This must not adversely affect the rights and freedoms of other persons.
The right to data portability does not apply to any personal data processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.


RIGHT TO OBJECT

You have the right to object, on grounds relating to your particular situation, at any time, to any processing of your personal data which is based on Article 6(1), point (e) or (f) of the GDPR, including profiling based on those provisions.
The controller no longer processes your personal data, unless the controller demonstrates compelling legitimate grounds for processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where your personal data are processed for direct marketing purposes, you have the right to object at any time to any processing of your personal data for such marketing, which includes profiling to the extent that it
is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.
In the context of the use of information society services—and notwithstanding Directive 2002/58/EC— you may exercise your right to object by automated means using technical specifications.

The right to object also complies with the right to correct and the right to limit the use of the California Consumer Privacy Act (CCPA).


RIGHT TO WITHDRAW THE CONSENT

You have the right to withdraw your declaration of consent under data protection laws at any time. The withdrawal of consent will not affect the Lawfulness of processing based on consent before its withdrawal.

The right to withdraw the consent also complies with the right to opt-out of the California Consumer Privacy Act (CCPA).


RIGHT TO LODGE A COMPLAINT

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.
The supervisory authority with which the complaint has been lodged informs the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy according to Article 78 GDPR.

 

DATA CONTROLLER

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other legal data protection provisions is:


DT Swiss Group AG
Längfeldweg 101
2504 Biel/Bienne
Switzerland
Tel.: +41 32 344 79 37
Email: dataprotection@dtswiss.com
Website: www.dtswiss.com


The Group Chief Financial Officer was appointed as the data protection officer. Please send any queries or comments by email to dataprotection@dtswiss.com.


DATA PROTECTION OFFICER

DT Swiss AG
Längfeldweg 101
2504 Biel/Bienne
Switzerland
Michael Schütz, Chief Financial Officer
Email: mschuetz@dtswiss.com

DT Swiss Polska Sp. z o. o.
ul. Towarowa 36
64-600 Oborniki
Poland
Tomasz Gil, General Manager
Email: tgil@dtswiss.com

DT Swiss Deutschland GmbH
Albert-Einstein-Strasse 3
59302 Oelde
Germany
Marcel Ratering, General Manager
Email: mratering@dtswiss.com

DT Swiss (France) S.A.S
Parc d'activités de la Sarrée
06620 Le Bar sur Loup
France
Philippe Esquirol, General Manager
Email: pesquirol@dtswiss.com

DT Swiss Inc.
2943 Industrial Blvd.
81505 Grand Junction, Colorado
USA
Chip Barbieri, General Manager
Email: cbarbieri@dtswiss.com