Privacy Policy

This Privacy Policy (“Policy”) has been implemented to inform you how April Group SA, as data controller, which its registered address is Avenue de Tivoli 3, 1700 Fribourg, Switzerland, and its subsidiaries (“we” or “us”) process your personal data.

I. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include anonymous data.

If necessary, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows (hereinafter all the following groups of personal data are referred to as Personal Data):

  1. personal identity data – includes first name, last name, username or similar identifier, title, date of birth and gender, job and career history, educational background, family and beneficiary details, financial information including but not limited bank account number, salary.
  2. contact data – includes address, email address and telephone numbers.

We do not collect any special categories of your Personal Data about you (this includes details about your race or ethnicity, religious, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Information about person`s health data can only be collected for the appropriate employment processes.

II. PURPOSES FOR PROCESSING YOUR PERSONAL DATA

Other than as stated above, we may use your Personal Data for one or more of the following purposes:

  1. to contact you for your views and feedback on our services and to respond directly to you after you contacted us;
  2. to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect our rights (including to prevent fraud);
  3. to provide you with marketing communication and information about our company and services;
  4. to ensure appropriate employment of personnel and work processes and to seek for qualified candidates.

III. DIRECT MARKETING

Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your Personal Data to let you know about our other services that may be of interest to you and we may contact you to do so by email or by other means of communication that is in our disposal. Please inform us if you decide at any time that you no longer wish to receive such communications from us.

IV. THE LAWFUL BASES FOR PROCESSING PERSONAL DATA

We process your Personal Data for the above purposes relying on one or more of the following lawful grounds: a) Contract – we may process personal data in order to perform our contractual obligations.

  1. Consent – we may rely on your freely given consent at the time you provided your Personal Data to us.
  2. Legitimate interests – we may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced.
  3. Legal obligations and public interest – we may process personal data in order to meet regulatory and public interest obligations.

V. PERSONAL DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

However, April Group SA may retain Personal Data longer if this is necessary to comply with applicable law requirement, or if it is necessary to protect or exercise our rights.

VI. DISCLOSURE OF YOUR PERSONAL DATA

We routinely share Personal Data with:

  1. third parties (legal and natural persons) we use to help deliver our products and services to you;
  2. other third parties (legal and natural persons) we use to help us run our business;
  3. banks and third parties (legal and natural persons) approved by you, for example, third party payment providers.

We only allow third parties to handle your Personal Data if we are satisfied, they take appropriate measures to protect your Personal Data. We also impose contractual obligations on third parties to ensure they can only use your Personal Data to provide services to us and to you (if necessary).

We may also need to:

  1. share Personal Data with external auditors, for example, in relation to the audit of our accounts;
  2. disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

In all cases we always aim to ensure that your Personal Data is only used by third parties for lawful purposes and in compliance applicable data protection law.

VII. PERSONAL DATA SECURITY

April Group SA implements a variety of security measures in order to protect Personal Data from security incidents or unauthorized disclosure. These security measures are based on appropriate industry security standards and include, inter alia access controls, password, encryption and regular security assessments.

We also endeavour to take all reasonable steps to protect personal data from external threats such as malicious software or hacking. In the event of suspected Personal Data breach, we undertake to take all reasonable steps to stop and remedy the breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

VIII. INTERNATIONAL TRANSFERS

We share your Personal Data within the April Group SA group of companies. This may involve transferring your data outside the Switzerland.

Some of our external third parties are based outside the Switzerland so their processing of your Personal Data will involve a transfer of data outside the Switzerland.

Whenever we transfer your Personal Data out of the Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. we will transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data;
  2. where we use certain service providers, we may use standard contractual clauses approved by the European Commission which ensure that an adequate level of protection for Personal Data can be maintained. If necessary, we agree on supplementary measures.

IX. YOUR PRIVACY RIGHTS

As may be relevant according to applicable data protection law, you may request access, to be informed, rectification, deletion, portability of your Personal Data, limitation or opposition to the processing of your Personal Data or withdraw your consent. Please note that the exercise of such rights is not absolute and is subject to legal limitations.

If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that you have to properly identify yourself (e.g., through copy of your ID) before your request can be processed.

If you have any concern about your Personal Data or want to exercise your rights, please contact us.

You also have the right to lodge a complaint with your local supervisory authority or the competent regulator if you consider that the processing of your Personal Data infringes applicable law.

X. FINAL PROVISIONS

This Privacy Policy has been reviewed and came into force on 1th of January, 2023. April Group SA reserves the right to amend, adjust or suspend this Privacy Policy at any time. The amended, adjusted or suspended Privacy Policy will be posted on this page.

For any questions, comments, or concerns about this Policy, or in order to exercise your privacy rights permitted by applicable law related to Personal Data, please contact us in the Contacts section of the website (https://aprilgroup.ch/contacts/).

April Group SA will try to respond to all legitimate requests with one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you update.