Privacy Policy
I. What do we do?
philoro GLOBAL TRADING AG, Rothusstrasse 23, 6331 Huenenberg is the operator of the website www.philoro-global.com (hereinafter referred to as «we»). On this website we offer services and information in connection with the sustainable supply of precious metals.
We are responsible for the collection, processing and use of your data and ensure compliance with Swiss law and the European Data Protection Regulation (GDPR). The protection of your personal data is of great concern to us.
II. What do we inform about?
- What data is collected on www.philoro-global.com
- Under what circumstances we may process your data and for what purpose;
- How long we may keep your data;
- In which cases we pass on data to third parties;
- How we process your data;
- When and how you can object to data processing;
- What rights you have in connection with our data processing and how you can assert them.
III. General principles
- What data do we collect from you and from whom do we receive this data?
First and foremost, we process personal data that you provide to us or that we collect when operating our website. We may also receive personal data about you from third parties. This may include the following categories:
- Personal master data (name, address, dates of birth, etc.);
- Contact details (mobile phone number, email address, etc.);
- Financial data (e.g. account details, credit information, etc.);
- Online identifiers (e.g. cookie identifier, IP addresses, etc.);
This data may originate from the following sources:
- publicly available sources (e.g. media, Internet);
- public registers (e.g. commercial register, debt collection register, land register);
- administrative or judicial proceedings;
- Information concerning your professional functions and activities;
- correspondence and meetings with third parties;
- Information about you that is given to us by people close to you so that we can conclude or process contracts with you;
- the use of our website.
2. Under what conditions do we process your data?
We process your data in good faith and for the purposes set out in this privacy policy. In doing so, we ensure a transparent processing that is limited to the necessary information.
The legal basis could be:
- your consent;
- the fulfilment of a contract or pre-contractual measures;
- the fulfilment of legal requirements;
- our legitimate interests, unless your interests do not prevail;
- the safeguarding of vital interests of you or another person or for the performance of a task in the public interest;
- other relevant legal bases.
You may be required to provide us with certain personal information in order for us to do business with each other. Without such data, we are usually not able to fulfill a contract.
The website may not fully function if certain traffic security information, such as your IP address, is not disclosed.
3. How can you withdraw consent?
If you have given us your consent to process your personal data for specific purposes, we will process your data within the scope of this consent, unless there is another legal basis.
You can revoke your consent at any time by sending an e-mail to dataprotection@philoro-global.com. The revocation is only effective for the future, data processing that has already taken place is not affected.
4. In which cases can we pass on your data to third parties?
a. In general
We may rely on the services of third parties or affiliates to process your information. We ensure that third parties and affiliated companies comply with the requirements of data protection. We may also be required to disclose your information to government authorities.
We will only share your personal information if:
- you consented;
- this is necessary for the fulfilment of the contract or the implementation of pre-contractual measures;
- this is necessary to enforce our rights;
- we have a legitimate interest in doing so and your interests do not prevail;
- there is a legal obligation to do so or another legal permission exists.
b. International transfer
Under certain circumstances, your personal data may be transferred to affiliated companies or subcontractors abroad. These companies are obligated to data protection to the same extent as we are. The transfer may take place worldwide.
If the level of data protection does not correspond to that in the EEA area, we carry out a prior risk assessment and ensure that the same level of protection is guaranteed as in the EEA area (e.g. by means of the new standard contractual clauses [SCCs] of the EU Commission or other measures prescribed by law). If our risk assessment indicates that the SCCs do not provide sufficient safeguards, we will take additional technical measures to protect your data. You can access the EU Commission’s SCCs at: https://ec.europa.eu/info/system/files/1_en_annexe_acte_autonome_cp_part1_v5_0.pdf
5. How long do we keep your data?
We store personal data only for as long as is necessary to fulfill the individual purposes for which the data was collected.
Data that we store when you visit our website is kept for twelve months. An exception is made for analytics and tracking data, which may be retained for longer.
We store contract data for longer, as we are obliged to do so by legal regulations. In particular, we must retain business communication, contracts and accounting vouchers for up to 10 years. As far as we no longer need such data from you to perform the services, the data will be blocked and we will only use it for accounting and tax purposes.
6. How do we protect your data?
We will keep your information secure and take all reasonable steps to protect your information from loss, access, misuse or alteration.
Our subcontractors and employees who have access to your data are obliged to comply with the provisions of data protection law. In some cases it will be necessary for us to pass on your enquiries to affiliated companies. In these cases, too, your data will be treated confidentially.
Within our website we use the SSL procedure (Secure Socket Layer) in connection with the highest encryption level supported by your browser.
7. What rights do you have?
a. Right to information and data transmission
You can request information about the data we hold about you at any time. We kindly ask you to send your request for information together with proof of identity to dataprotection@philoro-global.com
You also have the right to receive your data in a commonly used file format or (if technically feasible) to have your data transferred to a third party if we process your data automatically and if:
- you have given your consent for the processing of this data; or
- you have disclosed data in connection with the conclusion or fulfilment of a contract.
b. Right to erasure and rectification
You have the possibility at any time to request the deletion or correction or completion of your data, provided that there are no legal obligations to retain data or a legal reason for permission to do so.
Please note that the exercise of your rights may, under certain circumstances, conflict with contractual agreements and have corresponding effects on the execution of the contract (e.g. premature termination of the contract or cost consequences).
c. Restriction of processing
You also have the right to request that processing be restricted if you dispute the accuracy of the data, the processing is unlawful, the data is no longer required or if you object to the processing.
If the processing of the data is restricted, it may only be stored. Further processing may only be carried out with your consent, for the assertion, exercise or defense of legal claims, to protect the rights of another person or for reasons of important public interest. In the event that the restriction is lifted, you will be notified.
d. Right to object
You have the right to object at any time, on grounds relating to your particular situation, to processing (including profiling) that is carried out on the basis of our legitimate interests. This right also applies to processing for the purpose of direct advertising.
e. Complaint
If you are affected by the processing of personal data, you have the right to enforce your rights in court or to lodge a complaint with the competent supervisory authority. The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner: http://www.edoeb.admin.ch.
IV. Data processing operations when visiting the website
- Provision of the website and creation of log files
What information do we receive and how do we use it?
By visiting www.philoro-global.com, certain data is automatically stored on our servers or on servers of services and products that we obtain and / or have installed, for system administration purposes, for statistical or backup purposes or for tracking purposes. These are:
- the name of your Internet service provider;
- your IP address (under certain circumstances);
- the version of your browser software;
- the operating system of the computer used to access www.philoro-global.com;
- the date and time of access;
- the website from which you are visiting www.philoro-global.com;
- the search terms you used to find www.philoro-global.com.
Why are we allowed to process this data?
This data cannot be assigned to a specific person and there is no consolidation of this data with other data sources. The log files are stored in order to guarantee the functionality of the website and to ensure the security of our information technology systems. This is our legitimate interest according to Art. 6 (1) f GDPR.
How can you prevent data collection?
The data is only stored for as long as is necessary to achieve the purpose for which it was collected. Accordingly, the data is deleted after the end of each session. The storage of the log files is absolutely necessary for the operation of the website, you therefore have no possibility to object to this.
2. Cookies
How do cookies work?
Our website uses cookies. Cookies are text files that are stored on the operating system of your device with the help of the browser when you visit our website. Cookies do not cause any damage to your computer and do not contain viruses.
What information do we receive and how do we use it?
Most of the cookies we use are so-called „session cookies“. They are automatically deleted after the end of your visit. Other cookies remain stored on your terminal device until you delete them. These cookies enable us to recognize your browser on your next visit. This allows us to save certain settings (such as language settings or location information) so that you do not have to re-enter them the next time you visit the website.
Why may we use cookies?
We use cookies so that we can make our website more user-friendly, effective and secure. The use of cookies and the related processing of your data is based on our legitimate interests pursuant to Art. 6 (1) f GDPR.
How can you prevent data collection via cookies?
You will have to consent to third party and tracking cookies when accessing our website in order to proceed. The cookies are stored on your computer. You therefore have full control over the use of the cookies. You can delete them completely or deactivate or restrict the transfer by changing the settings in your browser. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.
3. Tracking-Tools: Google Analytics
How does Google Analytics work?
Our website uses Google Analytics, a service provided by Google Inc. from the United States. Google Analytics is integrated with Google Tag Manager.
Google uses cookies that are stored on your device and enable an analysis of your behavior on our website. The information generated by the cookie about your behavior will be transmitted to and stored by Google on servers in the United States.
Why may we use Google Analytics?
Google evaluates the collected data on our behalf, so that we can get a picture of the visits and user behavior on our website. This enables us to improve our services and the website content as well as its design. This is done on the basis of our legitimate interests pursuant to Art. 6 (1) f GDPR.
How can you prevent Google Analytics from collecting your data?
You can prevent the storage of cookies by adjusting the settings in your browser accordingly (see our comments on cookies). You can deactivate Google Analytics by downloading and installing the Google browser add-on.
V. Data processing operations in the event of contact
- Contact form
What information do we receive and how do we use it?
On our website you can contact us via an electronic contact form. The data you enter in the input mask, such as name, e-mail address, etc., will be transmitted to us and stored.
The data you provide will be used to process your request.
Why are we allowed to process this data?
The legal reason for this is pre-contractual measures or our legitimate interests in the processing of the enquiry.
2. Email
What information do we receive and how do we use it?
You have the possibility to contact us by e-mail. If you contact us by e-mail, the following data will be processed:
- e-mail address;
- content, subject and date of your email;
- contact data provided by you (e.g. name, telephone number, address, if applicable).
Why are we allowed to process this data?
Your details will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. The legal reason for this is pre-contractual measures or our legitimate interests in the processing of the enquiry.
Security note: We would like to point out that e-mails can be read or changed unauthorized and unnoticed during transmission. The spam filter can reject e-mails if they are identified as spam by certain characteristics.
VI. Does our privacy policy always remain the same?
We may change this privacy policy at any time. The changes will be published on www.philoro-global.com, you will not be informed separately.
VII. Disclaimer
The contents of this website have been created and checked with the greatest possible care. Nevertheless, we cannot be held liable for any material or immaterial damage resulting from the use or non-use of the information contained therein or access to it. The same applies to the accessing of links and content included on this website.
We are not liable for the content of other Internet sites, regardless of whether such sites refer to this website or are referred to by this website.
We exclude liability for the correctness, accuracy, completeness, timeliness or reliability of the published information to the extent permitted by law. We may change, delete or temporarily not publish content at any time, in whole or in part.
By accessing the freely accessible content published on this website, no contractual relationship of any kind is established between the user and the provider.
Getting in touch with us: We would like to point out that e-mails can be read or changed unauthorized and unnoticed during transmission. The same applies to information sent via contact form. If you wish to send us sensitive information, please contact us via an encrypted channel or by telephone.
VIII. How can you get in touch with us?
If you have any questions or concerns about how we protect your information, you can reach us at any time by e-mail at dataprotection@philoro-global.com
Responsible for the data processing carried out through this website is:
philoro GLOBAL TRADING AG
Rothusstrasse 23
6332 Huenenberg
Switzerland
Tel. +41 (0) 41 562 82 00
global-trading@philoro.com
Representative in the EU
Our representative in the EEA pursuant to Art. 27 GDPR is:
philoro EDELMETALLE GmbH
Waehringer Str. 26
1090 Wien
Austria
info@philoro.com
