Ascom Privacy Policy

(Scroll down for the Ascom Product Privacy Policy)

1.      Introduction

1.1.   This Privacy Policy describes how the Ascom Holding AG an all its subsidiaries and
        branches (together “Ascom”) Process Personal Data (as defined subseq.).

1.2.   Ascom is committed to guarantee a high level of data protection (as required by the
        EU General Data Protection Regulation (“GDPR”)) for all its subsidiaries and
        branches, inclusive the ones located outside of the EU.

1.3.   This Privacy Policy is not necessarily a comprehensive description of the Processing
        within Ascom. It is possible that other data protection statements are applicable (e.g.
        employee information) or that the Processing is evident from the circumstances or is
        provided for by applicable law.

2.      Identity of the controller

2.1.   The person which determines the purposes and means of the processing of
        Personal Data is deemed as the controller according to the GDPR. The controller is
        mainly responsible for the Processing.

2.2.   For the purpose of this Privacy Policy, the controller is the respective subsidiary or
         affiliate of Ascom that obtains the Personal Data from its Customers (as defined
         below) by email, letter, telephone, personal contact etc. or operates the website or
         social media channel.

2.3.   Further information about the Ascom group and the country locations can be found
         on Ascom’s website:

https://www.ascom.com/ch/de-ch/about-us/locations.html

3.      Processing of Personal Data

3.1.   The term “Personal Data” shall mean all information relating to an identified or
        identifiable person, as set out section 3.5 hereinafter.

3.2.   The term “Process” respectively “Processing” shall mean any operation which is
         performed on Personal Data (such as collection, recording, storage, adapation, use,
         restriction, disclosure etc.).

3.3.   Ascom Processes Personal Data of:

  •  users of websites and social media channels of Ascom (“User”);
  •  parties (including their employees) purchasing and receiving or otherwise
     benefitting from products and services of Ascom;
  •  suppliers (including their employees) delivering products and services to Ascom;
  •  other collaborating parties (including their employees) of Ascom;
  •  potential parties (including their employees) interested in products and services of
     Ascom;
  •  recipients of newsletters or other electronical or printed information of Ascom;
  •  participants of courses, seminars or other events organized by Ascom;
  •  users of WIFI provided at Ascom locations;
    (all together “Customer”).

3.4.   Ascom collects the Personal Data generally directly from its Customer, meaning
         during the course of their use of the websites or other IT systems of Ascom or
         during their communication via email, telephone or in any other way with Ascom
         respectively its employees. However, Personal Data can also be collected indirectly,
         namely through distributors or resellers of Ascom or through other third party data
         sources (e.g. social media, address brokers etc.).

3.5.   In particular, Ascom Processes the following categories of Personal Data of its
         Customers:

  • Personal Data and contact information including, but not limited to, first and last name, maiden name, address, telephone number, email address, age, date of birth, gender, marital status, relatives, information regarding emergency contact, picture, place of birth, nationality, information regarding debt prosecution and regarding sanction lists, work permits and residence permits etc.;
  • data pertaining to orders and purchases including, but not limited to, payment information, credit card details and other payment details, billing and shipping address, Customer name and number, VAT registration number, services ordered and purchased, information connected to queries, complaints and disagreements relating to products and services or respective contracts entered into such as warranty claims, rescissions and disputes etc.;
  • data in connection with marketing including, but not limited to, information such as newsletter opt-ins and opt-outs, documents received, invitations to and participations at events and special activities, personal preferences and interests, photos, videos etc.;
  • data concerning the use of Ascom’s websites including, but not limited to, IP address and other identification such as e.g. user name of social media, mac (media-access-control) address of smartphones or computers, cookies, date and time of website visits, visited sites and contents, referring websites etc.;
  • data in connection with communication including, but not limited to, preferred means of communication, correspondence and communication (both in writing or orally disclosed) with Ascom etc.;
  • data in connection with job applications and recruitment including, but not limited to, first and last name, title, curriculum vitae, graduation, associate degree, education etc.

4.      Purposes of the Processing

4.1.   In accordance with applicable law, Ascom may Processes Personal Data namely for,
        but not limited to, the following purposes:

  • offering of products and services, conclusions and executions of contracts;
  • maintenance and development of customer relationships, communication, customer service and support (e.g. repair request took);
  • promotions, advertisement, events and marketing (including newsletters and mailing of promotional materials);
  • operation of websites, social media channels and further IT systems of Ascom;
  • security reasons, work place safety, safety and security of premises including entrance controls, system security;
  • statistics;
  • applicant management and recruitment, inclusive finding of suitable candidates;
  • compliance with legal and regulatory requirements and internal rules of Ascom, audits and controlling, financial accounting, enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, engaging in legal investigations and proceedings and responding to in­quiries of public authorities;
  • sale or acquisitions of business divisions, companies or parts of companies and other corporate transactions and the transfer associated therewith;
  • other purposes as far as a legal obligation requires the Processing and such Processing was evident from the circumstances or indicated at the time of the collection;
    (all together “Purposes”).

4.2.   Each Purpose for the Processing shall be applicable for the entire Ascom group, i.e.
         not only for the company which initially collected the Personal Data.

5.      Legal grounds for the Processing

5.1.   Ascom Processes the Personal Data on the following legal grounds:

  • compliance with legal obligations of Ascom;
  • performance of contracts;
  • consent of the Customer (only insofar as Personal Data is Processed after specific queries, can be withdrawn at any time, namely the receipt of newsletters for which the Customer has registered for);
  • legitimate interests of Ascom, including but not limited to

-  the protection of Customers, employees and other individuals as well as
   protection of data, secrets and assets of or entrusted to Ascom, security and
   safety of systems and premises of Ascom;

-  advertisement and marketing activities;

-  customer support, maintenance of contact and other communication with
   prospective Customers or other persons;

-­  statistics and understanding of customer behavior, activities, concerns, market
   studies;

­- development and improvement of both existing and new products and services;

-­  ensuring and maintenance of business operations, websites and other IT
   systems;

­-  corporate governance and development;

­-  successful sale and acquisition of business units, companies or parts of
   companies and other corporate transactions;

­-  compliance with legal and regulatory requirements and internal rules of Ascom,
   concerns regarding the prevention of fraud, offences and crimes as well as
   investigation in connection with such offences and other improper conduct,
   handling of claims and actions against Ascom, cooperation in legal proceedings
   and with public authorities as well as the prosecution, exercise of and defense
   against legal actions;

5.2.   Ascom may rely on one or several legal grounds for each individual Processing.

6.      Disclosure of the Personal Data

6.1.   In accordance with applicable data protection laws, Ascom may disclose Personal
        Data to the following categories of third parties:

  • service providers (within Ascom as well as external), including processors;
  • dealers, suppliers and other business partners;
  • Customers of Ascom;
  • local, national and foreign authorities;
  • media, public, including visitors of websites and social media of Ascom;
  • stock exchange;
  • industry organizations , associations, organizations and other committees;
  • competitors;
  • acquirers and prospective acquires of business divisions, companies and other parts of Ascom;
  • other parties in potential or actual legal proceedings;
    (all together “Third Parties”).

6.2.   The Third Parties Process the Personal Data in accordance with the Purposes on
         behalf of Ascom or for their own Purposes.

7.      Transfer of Personal Data

We may disclose your Personal Data within Ascom as well as to Third Parties in every country worldwide, including namely all countries in which Ascom is represented by companies, affiliates or other offices and representatives as well as to countries in which service providers of Ascom Process their data. If Personal Data is disclosed to countries that do not guarantee adequate protection, we will ensure adequate protection of Personal Data by way of putting adequate contractual guarantees in place, namely on the basis of EU standard clauses, binding corporate rules or it bases the transfer on the exceptions of consent, conclu-sion or performance of contract, the establishment, exercise or defense of legal claims, overriding public interests or it discloses the data in order to protect the integrity of these individuals.

8.      Storage of the Personal Data

As a rule, Ascom retains the Personal Data as long as the contractual relationship is ongoing and for ten years after the termination of the contractual relationship unless a longer statutory store obligation is applicable on a case-by-case basis. For operational data containing Personal Data (e.g. protocols, logs) shorter retention periods are applicable in general. Business records (including communication) will be retained as long as Ascom has an interest in them (namely an interest for reasons of proof in case of claims, docu-mentation of compliance with certain legal or other requirements, an interest in non-personalized analysis) or is obligated to do so (by way of contract, law or other provisions).

9.      Access, rectification or erasure of Personal Data

9.1.   Any affected Customer may request information from Ascom regarding the
        Processing of the Personal Data. In addition, the Customers have the right to request
        the correction, destruction or restriction as well as to object to the Processing of
        Personal Data (“Subject Rights”).

9.2.   Should the Processing of Personal Data be based on consent by Customer, the
         Customer may withdraw the consent at any time. However, such withdrawal shall
         not have retroactive effect.

9.3.   In countries of the EU and EEA, the Customer may, in certain cases, has the right to
         obtain Personal Data generated during the use of online services in a structured,
         common and machine-readable format which allows for further use and transfer.
         Request in this respect shall be submitted to the data protection officer of Ascom 
         (see para 11. subseq.).

9.4.   Ascom reserves the right to restrict the Subject Rights in accordance with applicable
         law (e.g. not to disclose comprehensive information or not to delete data).

9.5.   Ascom reserves the right to restrict the Subject Rights in accordance with applicable
         law (e.g. not to disclose comprehensive information or not to delete data).

9.6.   Any requests and queries regarding data protection shall be submitted to Ascom`s
         data protection officer (see para. 11 subseq.).

10.    Cookies and newsletters  

10.1. Ascom uses cookies within the legal framework to track User preferences and to
       improve the design of its websites. Cookies are a widespread technique that
       allocates an identification to the browser of the User of a websites which
       the User saves and shows upon request. The User may block the application of
       cookies on his browser or delete cookies there which may, however, impair the use
       of the website.

10.2. In accordance with applicable law, Ascom may send newsletters or other
        commercial communications in connection with its products and services to
        Customers. The respective Customer may object to a further mailing of
        newsletters or other commercial communications at any time by a link indicated in
        the mailing.

11.    Google Analytics

Ascom may use Google Analytics (or similar services) on its website. These applications are third party services which allow Ascom to measure and analyse the use of its website. The provider of such such services may be located in any country worldwide (e.g. in the U.S.). The service provider uses permanent cookies for these applications. Ascom will not disclose any personal data to the service provider. However, the service provider may monitor the use of the website by the User and combines this data with data from other websites monitored by the same service provider which the User has visited and the services may use there findings for its own benefits. The service provider knows the identiy of the User who has registered with the service provider. The service provider will provide data on the use of the website to Ascom.

12.    Data Protection Offcier and Customer requests

12.1. Ascom has appointed a data protection officer according to the provisions of GDPR.

12.2. Any requests and queries regarding data protection shall be submitted to Ascom`s
        data protection officer under the following contact: dpo@ascom.com.

13.    Changes of the Privacy Policy

13.1. Ascom is entitled to amend this Privacy Policy at any time and without prior notice or
       announcement. The latest version according to the website shall be applicable.

13.2. Should the Privacy Policy form part of an agreement with Customers, Ascom may
        inform them of an up-date by email or in another appropriate manner. The update
        shall be deemed to have been accepted by the Customer unless an objection is
        raised within 30 days of notification.

Ascom Product Privacy Policy

By downloading an App, you agree to the terms of this Product Privacy Policy.

1.      Identity of the controller
The person which determines the purposes and means of the processing of Personal Data is deemed as the controller according to the GDPR. The controller is mainly responsible for the Processing.

For the purpose of this Privacy Policy, the controller is the respective subsidiary or affiliate of Ascom that obtains the Personal Data from its Customers (as defined below) by the APP.

2.      Information we collect from you
Information you give us when you register to use this App:
This is information you give us by registering to use our app, or by corresponding with us (for example, by email), share data for a survey, and when you report a problem with the App. If you contact us, we will keep a record of that correspondence. The information you give us may include your full name, email address, user device platform, user profile picture and location (“Personal Data”).

3.      Information we collect about you and your device:
Each time you use the App we automatically collect the following information: Technical information, including the type of mobile device you use, your mobile operating system and the type of mobile browser you use (“Device Information”), details of your use of the App, not limited to traffic data, application data caches and other communication data (“Log Information”).

4.      Geolocation-based services
The APP might need to have information disclosed about user’s current location to function properly.  A data subject has to make the choice to enable location services - it is not set on by default. Such information is collected from user’s device GPS signal, or as inferred from nearby Wi-Fi networks, or mobile network transmitting stations, or other technologies to determine your devices’ approximate location. The information includes user’s geographical position and information identifying your device such as a phone or SIM card number. Ascom collects and processes geolocation information insofar as necessary for providing the service requested. If we use geolocation information for our own purposes such as analysis of the use of the service, we do so in statistical, non-personally identifiable form.

The user may at any time disallow the application or service to collect geographical location by selecting the appropriate setting in the relevant application or service or in user’s device operating system. The latter action will prevent user from accessing and relying on geolocation-based services.

5.      Uses made of the information
We may use your Personal Data, Device Information and Log Information to send you push notifications, monitor the App functionality and service levels, group users into region and other specific categories, undertake user and functionality analytics and/or send you notifications by email.

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

We do not disclose information about identifiable individuals to our third party analytic providers, but we may provide them with anonymous aggregate information about users to help us identify trends and useful metrics that willhelp us improve the App.

We may also use your personal information to enforce our End User Licence Agreement

6.      Where we store your personal data
The data we collect from you will be stored at a destination within the EU. All information you provide to us is stored on our provider’s secure servers. By submitting your personal data, you agree to this storing and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Any information that you provide through the App may also be stored on your local phone storage.

Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask that you not share this with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7.      Legal grounds for the Processing

7.1     Ascom Processes the Personal Data on the following legal grounds:

  • compliance with legal obligations of Ascom;
  • performance of contracts;
  • consent of the Customer (only insofar as Personal Data is Processed after specific queries, can be withdrawn at any time, namely the receipt of newsletters for which the Customer has registered for);
  • legitimate interests of Ascom, including but not limited to

-       compliance with legal obligations of Ascom;
-       performance of contracts;
-       consent of the Customer (only insofar as Personal Data is Processed after specific
        queries, can be withdrawn at any time, namely the receipt of newsletters for which
        the Customer has registered for);
-       legitimate interests of Ascom, including but not limited to
-       the protection of Customers, employees and other individuals as well as protection
        of data, secrets and assets of or entrusted to Ascom, security and safety of systems
        and premises of Ascom;
-       advertisement and marketing activities;
-       customer support, maintenance of contact and other communication with
        prospective Customers or other persons;
-       statistics and understanding of customer behavior, activities, concerns, market
        studies;
-       development and improvement of both existing and new products and services;
-       ensuring and maintenance of business operations, websites and other IT systems;
-       corporate governance and development;
-       successful sale and acquisition of business units, companies or parts of companies
        and other corporate transactions;
-       compliance with legal and regulatory requirements and internal rules of Ascom,
        concerns regarding the prevention of fraud, offences and crimes as well as
        investigation in connection with such offences and other improper conduct,
        handling of claims and actions against Ascom, cooperation in legal proceedings and
        with public authorities as well as the prosecution, exercise of and defense against
        legal actions.

7.2 Ascom may rely on one or several legal grounds for each individual processing.

8.      Your rights
The GDPR and Data Protection Act 2018 give you the right to access information held about you. You can access your name, email address, country and profile picture (as may be applicable) in your profile screen.

Any affected Customer may request information from Ascom regarding the Processing of the Personal Data. In addition, the Customers have the right to request the correction, destruction or restriction as well as to object to the Processing of Personal Data (“Subject Rights”).

Should the Processing of Personal Data be based on consent by Customer, the Customer may withdraw the consent at any time. However, such withdrawal shall not have retroactive effect.

In countries of the EU and EEA, the Customer may, in certain cases, has the right to obtain Personal Data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Request in this respect shall be submitted to the data protection officer of Ascom.

Ascom reserves the right to restrict the Subject Rights in accordance with applicable law (e.g. not to disclose comprehensive information or not to delete data).
Any requests and queries regarding data protection shall be submitted to Ascom`s data protection officer (dpo@ascom.com).

Please note that uninstalling the App from your device does not guarantee the deletion of personal information that we hold on your behalf in all cases.

9.      Transfer of Personal Data
We may disclose your Personal Data within Ascom as well as to Third Parties in every country worldwide, including namely all countries in which Ascom is represented by companies, affiliates or other offices and representatives as well as to countries in which service providers of Ascom Process their data. If Personal Data is disclosed to countries that do not guarantee adequate protection, we will ensure adequate protection of Personal Data by way of putting adequate contractual guarantees in place, namely on the basis of EU standard clauses, binding corporate rules or it bases the transfer on the exceptions of consent, conclusion or performance of contract, the establishment, exercise or defense of legal claims, overriding public interests or it discloses the data in order to protect the integrity of these individuals.

10.    Changes to the Privacy Policy
Any changes we may make to our privacy policy in the future will be posted on this page. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the services that we provide, as may be applicable.

11.    Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to dpo@ascom.com.