Investor Relations Privacy Notice

Subject: Accelleron Investor Relations privacy notice

Dear Madam or Sir,

Accelleron is fully committed to protecting your privacy and respecting your rights to control how your personal data is used. In this context, we wish to inform you about the Accelleron privacy notice. This message contains a summary of our notice which applies to Turbo Systems Switzerland Ltd, and all its subsidiary companies and members of staff.

Summary

The Accelleron company that is communicating with you is responsible for your information and controls how it is used, in accordance with this Privacy Notice. In the context of our relationship with you, we collect and process certain information about you in order to maintain our relationship with you, organize meetings and invite you to our events, send you financial and company related investor information and register you for our information calls. In the context of an online inquiry, we collect and process certain information about you in order to allow us to respond to your requests and inquiries, send you the requested materials.

Our Investor Relations Privacy Notice contains more details on which information we may collect from you, for which purposes and on the basis of what legal ground. Furthermore, the Privacy Notice sets out with whom we may share your data, and whether this includes any transfer of your data outside your country of residence (especially where this is outside the European Union, EU and European Economic Area, EEA) and which safeguards Accelleron has taken in order to adequately protect your data in case of such international transfer. You will also find more information in the Investor Relations Privacy Notice about how long we keep your data.

Lastly, our Investor Relations Privacy Notice describes the various data protection rights that you have and how you can exercise these rights with regard to any information we process from you, such as the right to access or receive a copy of your information or to request deletion or correction of your information.

For more details about how we process your personal data and on your data privacy rights, please read our full Privacy Notice further below.

We thank you for your continued trust in Accelleron.

Best regards,

Your Accelleron Investor Relations team

 

Accelleron Privacy Notice

Introduction

This Investor Relations Privacy Notice ("Notice") applies to the Accelleron Group of companies, which means Turbo Systems Switzerland Ltd, Switzerland and each entity in which Turbo Systems Switzerland Ltd, Switzerland, directly or indirectly, has a majority holding or owns or controls the majority of voting rights. The Accelleron company that is communicating with you or to which you are providing goods or services (referred to as "Accelleron" or "we"), is responsible for the processing of your personal data and controls how it is used, in accordance with this Notice.

At Accelleron, respecting your data privacy rights is a top priority. This notice explains why and how we collect personal data about you, how we process such data, and what rights you have regarding your personal data. 

Who is responsible for the processing of your personal data?

Turbo Systems Switzerland Ltd and its subsidiary companies are responsible for your personal data. For applicable data protection law, the primary controller of your data will be the Accelleron subsidiary company which is providing services or communicating to you. Other subsidiary companies of Accelleron may also receive and process your personal data, either in the capacity of controller or processor and this Notice applies equally to them.

The types of information we collect and use?

We collect and use personal data that concerns you in connection with the relationship with you. We may collect the following categories of personal data:

  • The business contact information you share with us: name, title, job title, email address, business address, telephone number, mobile telephone number;
  • Additional information you provide to us in the course of our business relations, such as: registration information provided at events, fairs;
  • Information your browser makes available when you visit an Accelleron website: IP address, the source of your site visit, time spent on the website or a particular page, links clicked, comments shared, browser type, date and time of visit, etc.;
  • To the extent necessary to fulfil our obligations, data obtained from publicly accessible sources or which are legitimately transmitted by other third parties (e.g. custodian): share register data.

In case you would like to be provided with information about a specific personal data processing activity, you can request that by submitting a request at www.accelleron-industries.com/privacy.

What we use your personal data for

We may use your personal data as described above for the following purposes:

  • maintain and cultivate our relationship with you;
  • invite you to our events;
  • to organize meetings between you and our executives;
  • to run investor relation campaigns, including webinars, workshops and presentations at events;
  • send you financial and company related investor information and register you for our information calls (such as alerts for press releases, event invitations, etc.);
  • respond to your requests and inquiries and send you any requested materials or information.

We collect only the personal data from you that we need for the purposes described above. For statistical purposes, improvement of our services and testing of our IT systems we use as much as reasonably possible anonymized data. This means that these data can no longer (in)directly identify you or single you out as an individual.

What happens if you do not provide us with the information we had asked you for or if you ask us to stop processing your information

Where it concerns processing operations related to the relationship with you (as described above), Accelleron will not be able to adequately establish, conduct or terminate a business relationship with you or your company and generally perform the purposes described above without certain personal data. Although we cannot obligate you to share your personal data with us, please note that this then may have consequences which could affect the business relationship in a negative manner, such as not being able invite you to Investor Relations events or provide you with requested materials or information.

The legal basis we rely on

We use your personal data for the purposes described in this notice based on one of the following legal bases, as applicable:

  • We may process your personal data for the fulfilment of contractual obligations resulting from contracts with you or your company, or as part of pre-contractual measures we have been asked to take;
  • We may process your personal data on the basis of statutory requirements, for example, on the basis of tax or reporting obligations, cooperation obligations with authorities or statutory retention periods;
  • We will ask your consent for the activities described in this privacy notice when required by applicable law, for example when we process your data in order to send you the requested material as we don’t have an existing business relationship with you or your company; or
  • We will rely on our legitimate interests to process your personal data within the scope of the business relationship with you or your company or your organization. Our legitimate interests to collect and use the personal data for this purpose are management and furtherance of our business.

You may obtain a copy of our assessment of why we may process your personal data for these interests by submitting a request at www.accelleron-industries.com/privacy

Parties we share your personal data with (in and outside the EU and EEA or outside the country where the Accelleron company that controls your data is located)

We only share your personal data with other Accelleron affiliates or third parties as necessary for the purposes described in the table below. Where we share your personal data with an affiliate or third party so that it is transferred to or becomes accessible from outside the European Union (“EU”) and the European Economic Area ("EEA") or outside the country where the Accelleron company that controls your data is located, we always put adequate safeguards in place to protect your personal data. Examples of these safeguards are an adequacy decision of the European Commission (read more here), Standard Contractual Clauses (read more here) and the Binding Corporate Rules that some of our services providers have adopted (read more here). We have taken additional measures for the transfer of data from within to outside the EU, EEA and outside the country where the Accelleron company that controls your data is located to protect your personal data. If you would like an overview of the safeguards which are in place, please submit a request at www.accelleron-industries.com/privacy.

Recipient   name or – for non-EU countries – recipient category Recipient   location Purpose
Accelleron affiliates and subsidiaries See the list of Accelleron subsidiaries The purposes described in this privacy notice
Accelleron business partners, distributors, and agents EU/EEA and non-EU/EEA (global) The purposes described in this privacy notice
Service providers EU/EEA and non-EU/EEA (global) IT services, marketing agencies, payment processors, customer support providers working on Accelleron’s behalf
Potential or actual acquirers of Accelleron businesses or assets EU/EEA and non-EU/EEA (global) For the evaluation of the business or assets in question or for the purposes described in this privacy notice
Recipients as required by applicable law or legal process, to law enforcement or government authorities, etc. EU/EEA and non-EU/EEA (global) Where required by applicable law or a legitimate request by government authorities, or a valid legal requirement

How long we keep your personal data

Based on mandatory legislation, Accelleron must keep certain personal data for a minimum period of time. We only keep your personal data that we have collected in the course of the event registration, for as long as necessary for the purposes described in this privacy notice.

At the same time, applicable data protection laws require that we do not keep personal data in an identifiable form for any longer than is necessary for the purpose for which the personal data is being processed. Through the setting of IT applications and policies we ensure that our keeping of your personal data is deleted when we no longer need it. Any information about dietary requirements will be deleted immediately after the event as this information can reveal special categories of personal data (e.g. religion, allergies, etc.).

Your data privacy rights

Depending on the jurisdiction in which you are located and in which your personal data is processed, you may have the following rights:

Data privacy rights What it means
The right to access your data You are entitled to ask Accelleron for an overview of or to obtain a copy of the personal data we hold about you.
The right to have your data corrected You may request immediate correction of inaccurate or incomplete personal data we hold about  you.
The right to have your data erased You may request that personal data be erased when it is no longer needed, where applicable law obliges us to delete the data or the processing of it is unlawful.
The right to restrict   data processing You have the right to restrict the processing of your personal data in specific circumstances.
The right to data portability You have the right to receive your personal data in a structured, machine-readable format for your own purposes, or to request us to share it with a third party.
The right to object  to the data processing You have the right to object to our processing of your personal data where we rely on our legitimate interests as the basis for our processing, where your data privacy rights outweigh our reasoning for legitimate interests. 
The right to withdraw consent Where Accelleron has asked for your consent to process personal data, you may withdraw your consent at any time. The withdrawal of   consent will not affect the lawfulness of processing based on consent before its withdrawal.

Please note that the rights described above are not absolute, and that your request cannot always be met entirely. For example, sometimes we cannot delete or restrict the processing of your personal data as we may have legal obligations or contractual obligations to keep certain such personal data.

You may request to enforce your data privacy rights at www.accelleron-industries.com/privacy.

Contact and further information

If you want to access your personal data, make use of any of your other rights mentioned above or if you have any questions or concerns about how Accelleron processes your personal data, please contact our Group Data Protection Officer at privacy@accelleron-industries.com, or submit your complaint at www.accelleron-industries.com/privacy.

Should you not be satisfied with our response or believe we are processing your personal data against the law, you may also have the right to file a complaint with the Data Privacy Authority in your country of residence or work, or seek a remedy through the courts where you believe an infringement of data privacy laws may have taken place.

Changes to this Notice 

Please note this Privacy Notice will change from time to time. We expect most such changes to be minor, but there may be changes that are more significant. Where appropriate and possible we will notify you of such changes by email.