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Privacy Policy

This policy outlines how Empowwer, the trading name of Wenestam, Switzerland (hereinafter referred to as “Empowwer”, “we”, “our” and “us”) works with privacy and integrity. We take privacy and integrity very seriously, and we only process personal data relating to an identified or identifiable natural person in accordance with applicable data protection legislations and this privacy policy.

Purpose of this policy

The purpose of this privacy policy is to provide you with information about how we use, capture and share your personal data. This privacy policy sets the data protection and security standards within Empowwer and applies worldwide, including all of our subsidiaries and is based on globally accepted principles on data protection. Our employees are obliged to adhere to this privacy policy as well as observe applicable local data protection legislations.

Data controller

Empowwer, with its registered office in Switzerland, and all its affiliates and subsidiaries is the data controller of our processing of your personal data. We are thus responsible to ensure that your personal data is processed in a safe manner and in accordance with applicable data protection legislation.

Where your personal data come from

Most personal data that we process comes directly from you. That could be data you provide to us when purchasing one of our services or communicating with us by e-mail. We may also collect personal data about you as a result of you visiting our web site, for example, we save visitor traffic and communication data. An example of such personal data is, your IP-address, type of device, operating system and browser. If you do not provide us with the personal data we ask for, we may not be able to provide our services to you. We will clearly mark when it is required to provide certain personal data.

Processing reliability and security

We only collect and process personal data about you if it is necessary to meet legal obligations, fulfil an agreement with you, or if it is in our legitimate interest or if you have explicitly given your consent to our processing. We are also committed to ensuring that personal data is secure regardless whether the data is processed electronically or in paper format. To prevent unauthorized access, disclosure or destruction we are committed to use appropriate physical, electronic and managerial procedures to safeguard and secure your personal data.

What personal data we collect

We collect the following personal data of current and prospective clients and their representatives, consultants, individuals who agree to participate in market research, registered users and website users (collectively referred to in this policy as “Individuals”).

We collect contact details such as name, address, mobile telephone and e-mail address of Individuals who request access to our services, information materials or reports, Individuals seeking to receive freelance consultancy engagements via our platform and Individuals being a contact person at our service providers, vendors and customers.

Purpose and legal basis

We will process personal data for the following purposes and based on the following legal basis:

Providing access to consultancy services via our web site.

Legal basis: Fulfillment of an agreement with you. Our legitimate interest in fulfilling our service agreement with you. Consent through an unambiguous affirmative action.

Customer surveys to monitor the impacts of our efforts, such as satisfaction surveys and specific investigations, for example after the delivery of a service.

Legal basis: Consent through an unambiguous affirmative action, for example when you chose to participate in a survey. 

Marketing purposes

  • Direct marketing, follow up by e-mail, telephone or mail with Individuals who have requested informational materials from our web site, to provide further information and send promotional e-mail or mail about our services as well as other information we assess you may find interesting
  • Marketing optimization, including, market research, analyzing and improving marketing campaigns and profiling internet users

Legal basis: Consent through an unambiguous affirmative action, for example when you chose to participate in a survey. 

To send communication via different digital channels to registered users based on:

  • Explicit interest
  • Browsing history 
  • Purchase of services

Legal basis: Fulfillment of an agreement with you. Consent through an unambiguous affirmative action.

To manage your user account:

  • Create and administrate your user account
  • Send e-mails to you based on how you use our services
  • Deliver the services you have requested

Legal basis: Fulfillment of an agreement with you.

Freelance consultancy engagement via our platform

  • To evaluate and engage consultants on our platform

Legal basis: Evaluation prior to entering into an agreement.

Accounting 

  • We may also use your personal data for our accounting.

Legal basis: To fulfil our legal obligations.

Who we may share your personal data with

As a general rule, we do not share your personal data with third parties. However, we may share your personal data to certain trusted third parties to be able to provide our services, including:

  • Third parties performing services on our behalf, inter alia, freelancers, consultants, authorized vendors, agents and representatives;
  • Suppliers to whom we outsource certain IT support services, such as IT infrastructure suppliers, document and workflow management systems and other similar systems;
  • Partners, collaborators, and service providers involved in our company operations;

All transfers of personal data will be in accordance with law and will only be used for the purposes it was collected for. We ensure that your personal data is processed in a lawful and correct way where the data is transferred outside the Switzerland / EU/EEA-area.

We may place ads on its websites, on publishers’ websites or within e-mail content, either directly through the publisher or via a third party. For Individuals interacting with the advertising content, ad server companies may collect information about Individuals such as domain type, IP address, clickstream data. This information is not identifiable by Individuals’ personal data other than their IP address

How long we will keep your personal data

Personal data collected for the purpose to provide services will be stored for maximum ten years after the assignment was fulfilled or for such longer time as motivated based on the nature of the services or customer relation.

Personal data collected for the purpose to administrate our contractual relationship with our suppliers, will be stored for maximum ten years after the contractual relation has ended unless we are required under law (book keeping or account legislation) to store the information for a longer period.

Personal data collected in connection with a recruitment process will be stored for as long as the recruitment process is open and thereafter for as long as a job applicant not being employed may take legal actions against us in respect of the recruitment process.

Personal data collected for marketing purposes and the purpose to provide you with invitations to seminars, events and delegation trips will be stored until you deregister or unsubscribe for such mailings.

Personal Data relating to registered users, will be deleted when the user account has been inactive for two years.

Your rights

We are based in Switzerland and primarily complies with the Swiss Data Protection Act (DSG). If personal data is processed by persons who have the right to invoke their own legal system – in particular the EU General Data Protection Regulation (GDPR) – we will also observe this legal system and grant these persons the respective legal system-specific rights.

Request for information and contact

If you have any questions or complaints regarding our processing of your personal data or if you wish to exercise any of your statutory rights, please contact us per email on [email protected].

Changes to this privacy policy

We may make additions and alterations to this privacy policy and we encourage you to review the content of this privcacy policy regularly.

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