Visitor and CCTV Privacy Notice

 1. Introduction

This Visitor and CCTV Privacy Notice ("Notice") has been developed in accordance with the requirements of the General Data Protection Regulation (EU Regulation 2016/679 of April 27, 2016 or GDPR - General Data Protection Regulation) and applies to the Accelleron Group of companies, which means Accelleron Switzerland Ltd, Switzerland and each entity in which Accelleron Switzerland Ltd, Switzerland, directly or indirectly, has a majority holding or owns or controls the majority of voting rights. The Accelleron company that is hosting you (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 protection rights is a top priority. This Notice explains how we use personal data about you, how we process such data, and what rights you have regarding your personal data. 

In any case, in Russia, the principles for the processing of personal data described in this statement will be applied insofar as they do not violate the requirements of Russian law, including the Federal Law "On Personal Data" dated July 27, 2006 N 152-FZ and the Federal Law "On amending certain legislative acts of the Russian Federation on the application of information technology in the field of health protection" dated July 29, 2017 N 242-FZ.

Among other things, Accelleron Group companies operating in Russia will not collect, process and transmit your personal data without your consent, when required by law.

2. Who is responsible for the processing of your personal data?

Accelleron Switzerland Ltd and its subsidiary companies ((add hyperlink)) are responsible for your personal data. For applicable privacy and data protection laws, the primary controller of your data is the Accelleron subsidiary company, which is hosting 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.

Controllers located outside of the European Union (EU) have appointed a representative for EU data privacy matters. For details about your controller’s EU representative, please submit a request at www.accelleron-industries.com/privacy.

3. The types of information we collect and use?

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

• Identification data and business contact information, you share with us such as first name, last name, job/position/title, business email address, business address, telephone number, mobile telephone number, telefax number, private telephone number, gender, date of birth, vehicle license plate

• Additional information you provide to us related to or during your visit such as logging details for facilities and locations, employee hosting, purpose of visit, records relating to your visit.

• Image and video recordings from closed circuit television system (CCTV) footage.

• Electronic identification data and information collected by the communications systems, IT applications and website browser (where visitor has access or is affected by such systems or applications) such as information technology usage (system access, IT and internet usage), device identifier (mobile device ID, PC ID), registration and login credentials, IP address, login data and log files, Analytics ID, time and url, searches, website registration and cookie data.

The below mentioned types of personal data are only collected and processed, if at all, in accordance with applicable local laws in your country of residence and where relevant depending on your visit.

• To the extent necessary to fulfil our obligations, data obtained from publicly accessible sources or which are legitimately transmitted by other third parties.
  

4. Why we use your personal data?

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

• visitor management, registration and visitor access management including related contact interaction;

• health and safety management including medical emergencies;

• closed circuit television system (CCTV) capture for the purposes of public and staff safety, building security and crime prevention and detection;

• access control system providing electronically controlled ingress and/or egress for authorized individuals to locations that have access restrictions and a registry of personnel on site in case of emergencies;

• maintain and protect the security of products, facilities, services, systems, networks, computers and information, preventing and detecting security threats, and fraud or other criminal or malicious activities;

• references on documents, such as drawings, purchase or sales orders, invoices, reports;

• reorganization, acquisition and sale of activities, business units and companies;

• monitoring and auditing compliance with Accelleron’s corporate policies, contractual obligations and legal requirements;

• carrying out audits, reviews and regulatory checks to meet obligations to regulators; and

• manage IT resources, including infrastructure management including data back-up, information systems’ support and service operations for application management, end user support, testing, maintenance, security (incident response, risk, vulnerability, breach response), master data and workplace including user accounts management, software licenses assignment, security and performance testing and business continuity.

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

5. 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 your visit at Accelleron (as described above), Accelleron will not be able to adequately ensure the safety of you and other persons in the facility and monitor the security of the facilities 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 your visit, such as not being able to allow you to enter certain or all Accelleron facilities and locations.

6. 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 will rely on our legitimate interests to process your personal data within the scope of your visit at Accelleron, if they do not unduly affect your interests or fundamental rights and freedoms. Our legitimate interests to collect and use the personal data for this purpose are to: 

  • conduct, management, development and furtherance of our business in the broadest sense possible including visitor, facilities and locations management, ensuring safety and security, acquisition and sale of activities, business divisions and companies;

  • monitor, investigate and ensure compliance with legal, regulatory, standard and Accelleron internal requirements and policies;

  • prevent fraud and criminal activity including investigations of such activity, misuse of Accelleron assets, products and services, and as strictly necessary and proportionate for ensuring network and information security; and

  • transmitting personal data within the Accelleron group for internal administrative purposes as necessary for example to provide centralized services.

  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.
  

• In some cases, we process your personal data on the basis of legal obligations and statutory requirements, for example, on the basis of safety obligations, cooperation obligations with authorities, statutory retention periods or the disclosure of personal data within the scope of official or judicial measures may be required for the purposes of taking evidence, prosecution or enforcement of civil law claims.

7. Parties we share your personal data with (in and outside the EEA)

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 outside the European Economic Area ("EEA"), 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), Privacy Shield certification (read more here), and the Binding Corporate Rules that some of our suppliers have adopted (read more here). We have taken additional measures for the transfer of data outside the EEA 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.

You may obtain a copy of the safeguards which we use to protect your personal data by submitting a request at www.accelleron-industries.com/privacy.

8. 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 for as long as necessary for the purposes described in this privacy notice. In general, personal data is kept for the duration of 3 to 12 months. Certain personal data will be kept for longer period if required by local laws and regulatory requirements or to respond to legal claims.  Some of Accelleron's buildings and sites use CCTV systems to monitor their inside and outside for security and operational purposes. We do not keep the footage for more than one month, unless this is necessary, for example to handle a security incident.

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.

9. 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:

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 have any questions about how we use your personal data or wish to make a complaint about how we handle it, you may 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 contact the Data Privacy Authority in your country of residence or work or where you believe an infringement of data privacy laws may have taken place.

Date of publication:  March [4], 2020