We are dedicated to protecting the confidentiality and privacy of information entrusted to us. We comply with applicable Data Protection Regulations including in particular the Swiss Federal Act on Data Protection (FADP).
This website is operated by KALEIDOSCOPE INTERNATIONAL SARL, a Swiss legal entity.
1. Who are we?
2. Who can you contact for privacy questions or concerns?
KALEIDOSCOPE INTERNATIONAL SARL
Data Privacy Officer
Case Postale 158
1000 Lausanne 12
To report concerns you may have about our data handling practices you can contact the responsible data protection supervisory authority:
Switzerland: Federal Data Protection and Information Commissioner
3. How do we collect personal data?
Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host, visit our offices or apply for open positions. We may also obtain personal data directly when, for example, establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, prospects, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
Public sources – Personal data may be obtained from public registers (such as Commercial Registers), news articles, sanctions lists, and Internet searches.
Social and professional networking sites – If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
Business clients – Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility and pension services. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
Recruitment services – We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
4. What categories of personal data do we collect?
Personal data. Here is a list of personal data we commonly collect to conduct our business activities.
Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address)
Professional details (e.g., job and career history, educational background and professional memberships, published articles).
Family and beneficiary details for mobility, official approvals and permits, insurance and pension planning services (e.g., names and dates of birth).
Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
Sensitive personal data. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes. Examples of sensitive personal data we may obtain include:
– Personal identification documents that may reveal race or ethnic origin, religious beliefs or physical health, and possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
– Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.
– Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
– Information provided to us by our clients in the course of a professional engagement.
– Dietary restrictions when registering for events that reveal religious beliefs or physical health.
– Children data. Although, our sites and services are not intentionally designed for or directed at children, we may occasionally receive details about children e.g. as part of an engagement to provide professional services or children attending events we host with their parents or guardians.
– Location-based data. We may process geographical locations, e.g. when you are using our website to locate an office near you.
5. What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
Contract – We may process personal data in order to perform our contractual obligations.
Consent – We may rely on your freely given consent at the time you provided your personal data to us.
Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
Delivering services and products – To deliver the services and products our clients have engaged us to provide.
Marketing – To deliver timely industry insights and professional knowledge, offerings and invitations we believe are welcomed by our business clients, prospects, subscribers and other individuals.
Recruitment – To seek for qualified candidates.
Legal obligations and public interest – We may process personal data in order to meet regulatory and public interest obligations or mandates.
6. Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
Providing professional advice and delivering reports and services related to our tax, advisory, audit and assurance, pension scheme administration, legal, restructuring, mergers and acquisitions and other professional services and products.
Promoting our professional services, products and capabilities to existing and prospective business clients.
Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
Personalising online landing pages and communications we think would be of interest based on interactions with us.
Administering, maintaining and ensuring the security of our information systems, applications and websites.
Authenticating registered users to certain areas of our sites.
Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
Contacting journalists regarding market insights, corporate news, invitations to press conference, highlighting messages that may be of interest on specific industry topics.
Travel arrangement assistance.
Complying with legal and regulatory obligations relating to sanctions, embargo assessment, countering money laundering, terrorist financing, fraud and other forms of financial crime.
Preventing fraud or criminal activity, safeguarding our IT systems and handling of claims.
Employment of personnel and work processes.
Seeking for qualified candidates.
In some situations the provision of personal data is required to provide the services in such cases this is indicated on the Website accordingly or pointed out in the disclaimers or contractual agreements. Furthermore, we may be required to collect certain personal data by law. If you fail to provide such data, we may not be able to provide the services, or we may have to cancel a product or service you have with us.
7. Do we share personal data with third parties?
We may share personal data with trusted third parties to help us deliver efficient and quality services and products. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
– Parties that support us as we provide our services and products (e.g. providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services, scanning services).
– Our professional advisers, including lawyers, auditors and insurers.
– A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger/acquisition of part or all of our business or assets, or any associated rights or interests.
– Payment services providers.
– Marketing services providers.
– Law enforcement or other government and regulatory agencies (e.g. FAOA, FINMA) or to other third parties as required by, and in accordance with, applicable law or regulation.
– Recruitment services providers.
8. Do we transfer your personal data outside Switzerland?
We store personal data on servers operated by GoDaddy; GoDaddy’s 37,000 servers live in a total of nine facilities around the world. The company owns one of its data centers and leases the rest from wholesale .
We may transfer personal data to reputable third party organisations situated inside or outside Switzerland, when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and applicable data protection legislation. Such safeguards may include transfer to countries that have been deemed to provide an adequate level of protection according to lists of countries published by the Federal Data Protection and Information Commissioner; applying standard data protection model clauses, binding corporate rules or other standard contractual obligations which provide for appropriate protection of data; with providers in the US, use of companies that use the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
10. What are your data protection rights?
If KALEIDOSCOPE INTERNATIONAL SARL processes personal information about you, you have the rights listed below. Before responding to your request, we may ask for proof of identity. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for sufficient information about your interactions with us so that we can locate your personal information.
Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected and no retention requirements exist
Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it.
Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data in electronic form if technically feasible.
Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or which significantly affected you.
Right to Object to Marketing including Profiling – You can object to our use of your personal data for marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
Right to Object to Active Sourcing – You can object to our use of your personal data for active sourcing purposes. We may need to keep some minimal information to comply with your request to cease recruiting activities
Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes of processing your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
To submit a data request please direct your correspondence to:
KALEIDOSCOPE INTERNATIONAL SARL
Data Privacy Officer
Case Postale 158
1000 Lausanne 12
We aim to respond within 30 days from the date we receive privacy-related communications.
No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
11. What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. KALEIDOSCOPE INTERNATIONAL SARL’s protection of client data in relation to the provision of professional services, including people, processes and technologies for the engineering, deployment operations, and support of the data processing infrastructure is certified according to ISO 27001:2013. We limit access to personal data in general. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymization, de-identification and anonymization techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
12. How long do we retain personal data?
We retain personal data to provide our services, make offerings, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. We retain personal data for so long as the personal data is needed for the purposes for which it was collected or in line with legal and regulatory requirements or contractual arrangements. We will dispose of personal data when we no longer need it.
13. Do we link to other websites?
1. Automatic collection of personal information
1.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.
Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.
Deleted automatically after 90 days or presenting survey invite.
Social sharing We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service. For further details on our use of social media widgets and applications, see below. Persistent, but will be deleted automatically after two years if you no longer visit KALEIDOSCOPE-INT.com
Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
1.3 Google Analytics
KALEIDOSCOPE INTERNATIONAL SARL uses Google Analytics. More information about how Google Analytics is used by KALEIDOSCOPE INTERNATIONAL SARL can be found here.
1.4 Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. KALEIDOSCOPE INTERNATIONAL SARL only uses web beacons in accordance with applicable laws.
KALEIDOSCOPE INTERNATIONAL SARL or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.5 Location-based tools
KALEIDOSCOPE INTERNATIONAL SARL may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
2. Social media widgets and applications
KALEIDOSCOPE INTERNATIONAL SARL web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of KALEIDOSCOPE INTERNATIONAL SARL web sites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, KALEIDOSCOPE INTERNATIONAL SARL web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any KALEIDOSCOPE INTERNATIONAL SARL social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
3. Policy up-dates and changes