1. Controller and contact
The controller is the company that decides why and how your data is processed.
For this website, the controller is Sanjco, based in La Tour-de-Trême, in the canton of Fribourg.
You can write to us at any time with a question about your personal data.
[Clarify with the lawyer whether Sanjco must appoint a representative in the European Union.]
Our contact details are as follows.
- Company name: Sanjco SA
- Address: Route du Closalet 14, La Tour-de-Trême
- Email: info@sanjco.ch
- Telephone: +41 26 565 47 00
- Data protection contact: [name of the data protection officer to be completed]
2. Data collected during your visit
Every page view leaves a technical trace in the server logs, that is, the files that record activity on the site.
This information is used to operate the site, to ensure its security and to measure its traffic.
Sanjco does not seek to identify you from this data.
The following information is recorded on each visit.
- Your IP address, that is, the number that identifies your connection
- The date and time of access
- The pages viewed and the files downloaded
- The type of browser and the operating system used
- The website from which you arrived, if it is transmitted
3. Data submitted via the forms
The site offers contact forms and demonstration request forms.
You are free to choose the information that you send us.
Mandatory fields are marked. Without them, we cannot process your request.
We use this data to reply to you, to prepare a quote and to follow up on the exchange.
If you subscribe to our newsletter, your email address is used solely for sending it. Every message contains an unsubscribe link.
The data usually requested is as follows.
- Your surname and first name
- The name of your company and your job title
- Your business email address
- Your telephone number, if you provide it
- The content of your message
4. Purposes and legal bases
Sanjco processes your data only for specific reasons.
Under Swiss law, processing is lawful when it is proportionate, recognisable and carried out in good faith.
If you are established in the European Union, the General Data Protection Regulation (GDPR) may apply. Sanjco then relies on your consent, on the performance of a contract or on its legitimate interest in making its services known.
Your data is neither sold, rented nor exchanged.
No fully automated decision producing legal effects is taken on the basis of your data.
The purposes pursued are as follows.
- Responding to your requests and preparing quotes
- Performing our contracts and providing support
- Ensuring the security and proper functioning of the site
- Measuring page traffic
- Sending you our newsletter, if you have requested it
5. Cookies and audience measurement
A cookie is a small file placed on your device by the website you are visiting.
Sanjco uses technical cookies, which are necessary for the site to function. They do not require your consent.
Audience measurement cookies count visits and show which pages interest visitors. They are placed only with your consent.
The measurement tool chosen is [audience measurement tool to be completed]. [Specify whether IP addresses are truncated and where the data is stored.]
You can withdraw your consent at any time via the cookie management window, which is accessible at the bottom of every page.
Your browser also allows you to block or delete cookies. Some features of the site may then no longer work.
Sanjco does not use advertising cookies. [Point to be confirmed according to the tools actually installed on the site.]
6. Website hosting in Switzerland
The sanjco.ch website is hosted by Infomaniak Network SA, a Geneva-based company.
The servers and backups are located in Switzerland.
Your data therefore remains subject to Swiss law.
The hosting provider accesses the data only in order to maintain the service. It acts as Sanjco’s processor, on the basis of a written contract.
[Check the exact data centre and the data processing agreement signed with Infomaniak.]
7. Processors and data transfers
A processor is a company that processes data on behalf of Sanjco, in accordance with its instructions.
Sanjco chooses processors that offer sufficient guarantees in terms of security.
Each relationship is governed by a written contract.
Certain services may involve a transfer outside Switzerland, for example to a software publisher established in the European Union.
A transfer takes place only to a country offering adequate protection, or with recognised contractual safeguards, for example standard data protection clauses.
The categories of processors concerned are as follows.
- Hosting of the website and backups: Infomaniak Network SA, Geneva
- Email and office tools: [provider to be completed]
- Website audience measurement: [audience measurement tool to be completed]
- Newsletter distribution: [provider to be completed]
- Publishers of software integrated by Sanjco, in connection with support: [list to be completed]
8. Retention period
Sanjco retains your data for as long as the purpose requires.
It is then erased or anonymised.
Accounting records are kept for ten years, as required by Swiss law.
The retention periods provided for are as follows.
- Server logs: [period to be completed]
- Contact requests not followed up: [period to be completed]
- Client data: for the duration of the contractual relationship, then ten years for accounting records
- Newsletter subscriptions: until you unsubscribe
- Audience measurement cookies: [cookie lifetime to be completed]
9. Data security
Sanjco protects your data by means of technical and organisational measures.
These measures are reviewed regularly and adapted as risks evolve.
No system is completely secure. Sanjco therefore cannot guarantee absolute security.
In the event of a security breach resulting in a high risk to your rights, Sanjco reports the incident to the Federal Data Protection and Information Commissioner. The data subjects concerned are informed where the law so requires.
The main measures in place are as follows.
- Encryption of communications between your browser and the site (HTTPS protocol)
- Access restricted solely to the people who need it
- Strong passwords and two-factor authentication
- Regular backups, stored in Switzerland
- Raising staff awareness of data protection
10. Your rights over your data
The law grants you several rights over the data concerning you.
To exercise any of these rights, write to info@sanjco.ch.
As a rule, Sanjco responds within thirty days.
We may ask you for proof of identity, so as not to hand over your data to another person.
Exercising these rights is free of charge. A manifestly unfounded or repeated request may give rise to a contribution towards costs.
In the cases provided for by law, a request may be refused or restricted. Sanjco then explains the reason to you.
You can assert the following rights.
- Ask which data concerning you is being processed
- Have inaccurate data corrected
- Request the erasure of your data
- Object to processing or withdraw your consent
- Receive your data in a common format, or have it transmitted to a third party
11. Right of recourse to the FDPIC
If you believe that Sanjco is processing your data incorrectly, contact us first. Most situations are resolved through direct dialogue.
You can also report the matter to the Federal Data Protection and Information Commissioner (FDPIC) in Bern.
The FDPIC is the Swiss authority responsible for supervising the application of the Federal Act on Data Protection.
Its full contact details can be found on the FDPIC’s official website.
If you reside in the European Union, you can also refer the matter to the supervisory authority in your country.
Recourse to the courts remains open in all cases.
12. Changes to this policy
Sanjco may adapt this policy, for example if the site changes or a new tool is introduced.
The applicable version is the one published on sanjco.ch.
The date of the last update appears at the top of this page.
In the event of a significant change, Sanjco informs you of it prominently on the site.
This version is dated [update date to be completed].
Working version of the prototype, to be reviewed by a lawyer before publication.